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LECLAIR WEALTH PARTNERS WRAP BROCHURE 11-2024
Leclair Wealth Partners (CRD 332827), brochure dated February 13, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
LECLAIR WEALTH PARTNERS LLC
FORM ADV PART 2A, APPENDIX 1
WRAP FEE PROGRAM BROCHURE
Item 1 – Cover Page
6515 Longshore Loop, Suite 100
Dublin, Ohio 43017
888-277-5704
www.leclairwealthpartners.com
This wrap fee program brochure provides information about the qualifications and business practices of
LeClair Wealth Partners LLC. If you have any questions regarding the contents of this brochure, please
contact our Chief Compliance Officer, Keith Dwyer by telephone at 513-977-8196 or by email at
keith.dwyer@dinsmorecomplianceservices.com. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission or by any state securities authority.
LeClair Wealth Partners LLC is a registered investment adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain level of skill
or training. Additional information about LeClair Wealth Partners LLC is available on the SEC’s website
at www.adviserinfo.sec.gov.
February 13, 2026
LeClair Wealth Partners
Wrap Fee Program Brochure
Item 2 – Material Changes
Form ADV Part 2A, Appendix 1 requires registered investment advisers to amend their wrap fee program
brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s
wrap fee program disclosure brochure, the adviser is required to notify you and provide you with a
description of the material changes.
The following material changes occurred since the last filing on 2/5/2025:
-Item 4, added the addition of flat fee investment management for certain accounts
-Item 6, added additional investment management risks
-Item 9, added information about certain broker dealer licensed individuals who participate in investment
banking activities
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Item 3 - Table of Contents
Item 1 – Cover Page ...................................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................ 2
Item 3 - Table of Contents ............................................................................................................................ 3
Item 4 – Services, Fees and Compensation ................................................................................................... 4
Item 5 – Account Requirments and Types of Clients ................................................................................... 7
Item 6 – Portfolio Manager Selection and Evaluation .................................................................................. 8
Item 7 – Client Information Provided to Portfolio Managers ..................................................................... 16
Item 8 – Client Contact with Portfolio Managers ....................................................................................... 16
Item 9 – Additional Information ................................................................................................................. 16
LeClair Wealth Partners
Wrap Fee Program Brochure
Item 4 – Services, Fees and Compensation
LeClair Wealth Partners LLC (“LeClair Wealth Partners”, “LeClair” or the “Firm”) is a corporation
organized in the State of Ohio. LeClair Wealth Partners is an investment advisory firm registered with the
United States Securities and Exchange Commission (“SEC”). LeClair Wealth Partners is owned by LeClair
HoldCo LLC, a corporation organized in the State of Florida. LeClair HoldCo is owned by Steven LeClair.
The LeClair Wealth Partners wrap fee program (the “LeClair Wealth Partners Wrap Fee Program”) is an
investment advisory program sponsored by LeClair Wealth Partners. Investment management services are
provided to clients of LeClair Wealth Partners through the LeClair Wealth Partners Wrap Fee Program.
In addition to the LeClair Wealth Partners Wrap Fee Program, the Firm offers financial planning services,
investment management services through non-wrap programs and investment management to certain types
of qualified plan clients under different arrangements then those described in this Brochure. Information
about these services is contained in the Firm’s Form ADV Part 2A.
A.
Description of the LeClair Wealth Partners Wrap Fee Program
LeClair Wealth Partners offers investment management services on a discretionary basis and non-
discretionary basis. All investment advice provided is customized to each client’s investment objectives
and financial needs. The information provided by the client, together with any other information relating
to the client’s overall financial circumstances, will be used by LeClair Wealth Partners to determine the
appropriate portfolio asset allocation and investment strategy for the client. Financial planning services
also are provided, depending on the needs of the client. LeClair Wealth Partners provides investment
management services to clients through a wrap fee program (the “LeClair Wealth Partners Wrap Fee
Program”). See LeClair Wealth Partners’ Form ADV Part 2A, Appendix 1 for additional information
regarding the LeClair Wealth Partners Wrap Fee Program.
The securities utilized by LeClair Wealth Partners in the LeClair Wealth Partners Wrap Fee Program client
accounts mainly consist of registered mutual funds and exchange traded funds (ETFs), but we will also
invest in equity securities, corporate bonds, REITS, variable annuities, private funds/alternative
investments, closed end funds and structured notes, if we determine such investments fit within a client’s
objectives and are in the best interest of our clients.
LeClair Wealth Partners may further recommend to clients that all or a portion of their LeClair Wealth
Partners Wrap Fee Program investment portfolio be managed on a discretionary basis by one or more
unaffiliated money managers or investment platforms (“External Managers”). The client may be required
to enter into a separate agreement with the External Manager(s), which will set forth the terms and
conditions of the client’s engagement of the External Manager. LeClair Wealth Partners generally renders
services to the client relative to the discretionary selection of External Managers. LeClair Wealth Partners
also assists in establishing the client’s investment objectives for the assets managed by External Managers,
monitors and reviews the account performance and defines any restrictions on the account. The investment
management fees charged by the designated External Managers are exclusive of, and in addition to, the
annual advisory fee charged by LeClair Wealth Partners. For External Managers made available through
the B/D Custodian RJA, custody and securities transactions commissions are included within the LeClair
Wealth Partners Wrap Fee Program fee. If an External Manager is utilized that engages in brokerage
transactions and/or custody services with a broker-dealer/custodian other than RJA, the fees charged by
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that broker-dealer/custodian will be exclusive of, and in addition to, the annual LeClair Wealth Partners
Wrap Program fee.
LeClair Wealth Partners participates in the Raymond James and Associates, Inc. (“RJA”) Ambassador
Program custodial platform. LeClair Wealth Partners will recommend that LeClair Wealth Partners Wrap
Fee Program clients establish brokerage accounts with RJA to maintain custody of clients’ assets and to
effect trades for their accounts. RJA, member New York Stock Exchange/SIPC, is a “qualified
custodian” as that term is described in Rule 206(4)-2 of the Investment Advisers Act of 1940.
Note for IRA and Retirement Plan Clients: When LeClair Wealth Partners provides investment advice
to you regarding your retirement plan account or individual retirement account, LeClair Wealth Partners is
a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way LeClair
Wealth Partners makes money creates some conflicts with your interests, so LeClair Wealth Partners
operates under a special rule that requires LeClair Wealth Partners to act in your best interest and not put
LeClair Wealth Partners’s interest ahead of yours.
Note Regarding Tax or Legal Advice: In providing services, LeClair Wealth Partners does not offer or
otherwise provide tax or legal advice. LeClair Wealth Partners will, at a client’s direction and approval,
work with a client’s existing tax or legal professionals to assist in the provision of the services. Fees
charged by any tax, legal or other third-party professionals are the responsibility of the client. LeClair
Wealth Partners may refer professionals; however, there is no compensation to LeClair Wealth Partners
for these referrals, and clients are under no obligation to use the referred service providers.
The LeClair Wealth Partners Wrap Fee Program Fee
B.
The LeClair Wealth Partners Wrap Fee Program Fee covers LeClair Wealth Partners’s advisory services,
custody and commissions for securities transactions effected through RJA. The number of transactions
made in clients’ accounts, the size of the accounts, and the securities used to construct a portfolio, as well
as the commissions charged for each transaction, determines the relative cost of the LeClair Wealth Partners
Wrap Fee Program versus paying for execution on a per transaction basis and paying a separate fee for
advisory services. Participants in the LeClair Wealth Partners Wrap Fee Program may pay a higher or
lower aggregate fee than if the investment management and brokerage services are purchased separately.
LeClair Wealth Partners does not charge its clients higher advisory fees based on their trading activity, but
clients should be aware that LeClair Wealth Partners may have an incentive to limit its trading activities in
client accounts because LeClair Wealth Partners is charged for executed trades. LeClair Wealth Partners
addresses this conflict of interest by this disclosure and by its policies and procedures which work to ensure
that accounts are managed in accordance with clients’ goals and objectives without consideration of trading
costs incurred by LeClair Wealth Partners.
Cash and Margin Positions
At any specific point in time, depending upon perceived or anticipated market conditions or events
(there being no guarantee that such anticipated market conditions/events will occur), LeClair
Wealth Partners may maintain cash positions for defensive or other purposes. All cash positions
(money markets, etc.) will be included as part of assets under management for purposes of
calculating the LeClair Wealth Partners Wrap Fee Program Fee. In addition, LeClair Wealth
Partners does not reduce management fees for margin borrowing, regardless of whether the assets
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are in cash or other securities. LeClair Wealth Partners has a financial incentive to recommend that
clients borrow money for the purchase of additional securities for the client’s account managed by
LeClair Wealth Partners or otherwise not liquidate some or all the assets LeClair Wealth Partners
manages. LeClair Wealth Partners addresses this conflict of interest by this disclosure and working
and working to ensure that any recommendation to a client regarding the use of margin is suitable
for the client.
Additional Fees and Expenses
In addition to the LeClair Wealth Partners Wrap Fee Program Fee, clients will be responsible for
transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees and any
charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan
account fees (where applicable), electronic fund and wire fees. Furthermore, LeClair Wealth
Partners fees do not cover transaction fees or “trade away” fees imposed for trades placed away
from RJA. In addition, for External Managers, clients should review each manager’s Form ADV
2A disclosure brochure and any contract they sign with the External Manager (in a dual contract
relationship). The client is responsible for all such fees and expenses, as well as trading and custody
costs of a broker-dealer/custodian other than RJA if utilized by that External Manager.
Fee Schedule
In providing investment management services pursuant to the LeClair Wealth Partners Wrap Fee
Program, LeClair Wealth Partners charges an annual investment management services fee that is
agreed upon with each client and set forth in an agreement executed by LeClair Wealth Partners
and the client. The LeClair Wealth Partners Wrap Fee Program investment management fee is
based on a percentage of the value of assets under management, or a flat fee, and is generally paid
quarterly in advance. When a client’s account is opened, the LeClair Wealth Partners Wrap Fee
Program investment management services fee is billed for the remainder of the current quarterly
billing period and is based on the client’s initial contribution to the client account. Subsequent
quarterly LeClair Wealth Fee Partners Wrap Fee Program investment management services fees
will be based on the client’s account value as of the last business day of the previous calendar
quarter. If cash or securities, or a combination thereof, amounting to at least $100,000 are deposited
to or withdrawn from a LeClair Wealth Partners Wrap Fee Program client’s account on an
individual business day in the first two months of the quarter, LeClair Wealth Partners will (i)
assess investment management services fees to the deposited assets based on the value of the assets
on the date of deposit for the pro rata number of days remaining in the quarter, or (ii) refund prepaid
LeClair Wealth Partners Wrap Fee Program investment management services fees based on the
value of the assets on the date of withdrawal for the pro rata number of days remaining in the
quarter. No additional LeClair Wealth Partners Wrap Fee Program investment management
services fees or adjustments to previously assessed LeClair Wealth Partners Wrap Fee Program
investment management services fees will be made in connection with deposits or withdrawals that
occur during the last month of the quarter.
For purposes of LeClair Wealth Partners Wrap Fee Program investment management services fee
calculation, LeClair Wealth Partners utilizes third party sources, such as pricing services,
custodians, fund administrators, and client-provided sources. For purposes of fee calculation, the
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asset value of LeClair Wealth Partner Wrap Fee Program client accounts include cash and cash
equivalents, as well as margined securities. LeClair Wealth Partners does not reduce LeClair
Wealth Partners Wrap Fee Program investment management fees for margin borrowing, regardless
of whether the assets are in cash or other securities. LeClair Wealth Partners has a financial
incentive to recommend that clients borrow money for the purchase of additional securities for the
client’s LeClair Wealth Partners Wrap Fee Program account managed by LeClair Wealth Partners
or otherwise not liquidate some or all the assets LeClair Wealth Partners manages. LeClair Wealth
Partners addresses this conflict of interest by this disclosure and working to ensure that any
recommendation to a client regarding the use of margin is suitable for the client.
Following is the LeClair Wealth Partners Wrap Fee Program asset based fee:
FEE SCHEDULE
Market Value of Assets
Rate
Up to $1,999,999
1.50%
$2,000,000 to $4,999,999
1.25%
$5,000,000 to $9,999,999
1.00%
$10,000,000 to $24,999,999
0.75%
$25,000,000 to $49,999,999
0.50%
$50,000,000 to $99,999,999
0.35%
$100,000,000 and above
0.25%
The percentage for the highest range of Managed Asset value achieved
applies to all Managed Assets, not just Managed Assets within that
range.
There are clients of LeClair Wealth Partners who were clients of an unaffiliated investment
adviser at which current LeClair Wealth Partners personnel served as investment adviser
representatives that pay a higher fee for investment management services. LeClair Wealth
Partners also began offering flat fee investment management which is detailed in an individual’s
contract.
LeClair Wealth Partners’s policy is to include all related client accounts, specifically the accounts
of direct family members sharing the same residence address, for purposes of determining a
client’s market value of assets.
Compensation for Recommending the LeClair Wealth Partners Wrap Fee Program
C.
LeClair Wealth Partners does not have any arrangements where it receives an economic benefit from a third
party for recommending the LeClair Wealth Partners Wrap Fee Program.
Item 5 – Account Requirements and Types of Clients
Investment management services through the LeClair Wealth Partners Wrap Fee Program are provided to
individuals, including high net worth individuals, families, family offices, trusts, businesses, charitable
foundations, and retirement/profit-sharing plans. LeClair Wealth Partners does not impose a minimum
portfolio size or a minimum initial investment to open a LeClair Wealth Partners Wrap Fee Program
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account. However, LeClair Wealth Partners does reserve the right to accept or decline a potential client for
any reason in its sole discretion.
Item 6 – Portfolio Manager Selection and Evaluation
The LeClair Wealth Partners Wrap Fee Program utilize advisers, the External Managers, in addition to
LeClair Wealth Partners. RJA provides access to External Managers that have been subject to initial and
ongoing due diligence and reviews by RJA. In making External Managers available RJA evaluates External
Managers’ investment philosophy and policies, records as an investment adviser, and the investment
disciplines or strategies the External Manager is able to offer. In addition, in determining whether to
continue to make an External Manager available RJA conducts ongoing reviews of performance
calculations, peer comparisons, and examination of portfolio characteristics and holdings. This RJA
External Manager information is made available to, and reviewed by, LeClair Wealth Partners.
Performance information provided by External Managers is compared by RJA to publicly available
resources for reasonableness. External Manager provided performance information is not independently
verified by RJA nor LeClair Wealth Partners.
Advisory Services Offered by LeClair Wealth Partners
A.
See Item 4 of this Wrap Fee LeClair Wealth Partners Wrap Fee Program Brochure for a full description of
the LeClair Wealth Partners Wrap Fee Program. In addition to the LeClair Wealth Partners Wrap Fee
Program, LeClair Wealth Partners provides investment management on a non-wrap fee basis to certain
clients, retirement plan clients and financial planning and consulting services.
Investment Management Services to Retirement Plans
LeClair Wealth Partners offers discretionary and non-discretionary advisory services to qualified
plans, including 401k plans. These services include, depending upon the needs of the plan client,
recommending, or for discretionary clients selecting, investment options for plans to offer to
participants, ongoing monitoring of a plan’s investment options, assisting plan fiduciaries in
creating and/or updating the plan’s written investment policy statements, working with plan service
providers, and providing general investment education to plan participants.
Financial Planning Services and Consulting Services
LeClair Wealth Partners offers personal comprehensive financial planning services to set forth
goals, objectives and implementation strategies for the client over the long-term. Depending upon
individual client requirements, the comprehensive financial plan will include recommendations for
retirement planning, educational planning, estate planning, cash flow planning, long term health
care planning, tax planning and insurance needs and analysis. LeClair Wealth Partners prepares and
provides the financial planning client with a written comprehensive financial plan and performs
periodic reviews of the plan with the client, as agreed upon with the client. In addition, LeClair
Wealth Partners provides financial planning services that are completed upon the delivery of the
financial plan to the client. Clients should notify us promptly anytime there is a change in their
financial situation, goals, objectives, or needs and/or if there is any change to the financial
information initially provided to us.
B.
Client Tailored Advisory Services
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Clients may impose reasonable restrictions on the management of their accounts if LeClair Wealth Partners
determines, in its sole discretion, that the conditions would not materially impact the performance of a
management strategy or prove overly burdensome for LeClair Wealth Partners’s management efforts.
The LeClair Wealth Partners Wrap Fee Program
C.
As described above, LeClair Wealth Partners is one of the portfolio managers of the LeClair Wealth
Partners Wrap Fee Program. See Item 4 above for a description of the LeClair Wealth Partners Wrap Fee
Program and the other advisory services offered by LeClair Wealth Partners. Clients may impose
reasonable restrictions on the management of their accounts if LeClair Wealth Partners determines, in its
sole discretion, that the conditions would not materially impact the performance of a management strategy
or prove overly burdensome for LeClair Wealth Partners’s management efforts. As a portfolio manager,
LeClair Wealth Partners receives the LeClair Wealth Partners Wrap Fee Program Fee after the payment of
the brokerage, execution and custodian fees and expenses.
Performance-Based Fees and Side-By-Side Management
D.
LeClair Wealth Partners does not charge performance-based fees or participate in side-by-side
management. Performance-based fees are fees that are based on a share of capital gains or capital
appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts
that are charged performance-based fees while at the same time managing accounts that are not charged
performance-based fees. LeClair Wealth Partners’s fees are calculated as described in Item 5 above.
E.
Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
A primary step in LeClair Wealth Partners’s investment strategy is getting to know the clients –
to understand their financial condition, risk profile, investment goals, tax situation, liquidity
constraints – and assemble a complete picture of their financial situation. To aid in this
understanding, LeClair Wealth Partners offers clients financial planning that is highly customized
and tailored. This comprehensive approach is integral to the way that LeClair Wealth Partners
does business. Once LeClair Wealth Partners has a true understanding of its clients’ needs and
goals, the investment process can begin, and the Firm can recommend strategies and investments
that it believes are aligned with the client’s goals and risk profile.
LeClair Wealth Partners primarily employs fundamental analysis methods in developing
investment strategies for its clients. Research and analysis from LeClair Wealth Partners is based
on numerous sources, including third-party research materials and publicly-available materials,
such as company annual reports, prospectuses, and press releases.
LeClair Wealth Partners generally employs a long-term investment strategy for its clients, as
consistent with their financial goals. At times, the Firm may also buy and sell positions that are
more short-term in nature, depending on the goals of the client and/or the fundamentals of the
security, sector or asset class.
Client portfolios with similar investment objectives and asset allocation goals may own different
securities and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income
needs, long-term wealth transfer objectives, time horizon and choice of custodian are all factors
that influence LeClair Wealth Partners’s investment recommendations.
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Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her
investment. A client should be willing to bear such a loss. Some investments are intended only for
sophisticated investors and can involve a high degree of risk.
Material Risks Involved
Investing in securities involves a significant risk of loss which clients should be prepared to bear.
LeClair Wealth Partners’s investment recommendations are subject to various market, currency,
economic, political and business risks, and such investment decisions will not always be profitable.
Clients should be aware that there may be a loss or depreciation to the value of the client’s account.
There can be no assurance that the client’s investment objectives will be obtained and no inference
to the contrary should be made.
Generally, the market value of equity stocks will fluctuate with market conditions, and small-stock
prices generally will fluctuate more than large-stock prices. The market value of fixed income
securities will generally fluctuate inversely with interest rates and other market conditions prior to
maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or
interest on future dates, and include, among other securities: bonds, notes and debentures issued by
corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or
instrumentalities, or by a non-U.S. government or one of its agencies or instrumentalities; municipal
securities; and mortgage-backed and asset-backed securities. These securities may pay fixed,
variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked
fixed income securities. The value of longer duration fixed income securities will generally
fluctuate more than shorter duration fixed income securities. Investments in overseas markets also
pose special risks, including currency fluctuation and political risks, and it may be more volatile
than that of a U.S. only investment. Such risks are generally intensified for investments in emerging
markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investment
objective. Past performance of investments is no guarantee of future results.
Additional risks involved in the securities recommended by LeClair Wealth Partners include,
among others:
• Stock market risk, which is the chance that stock prices overall will decline. The market
value of equity securities will generally fluctuate with market conditions. Stock markets
tend to move in cycles, with periods of rising prices and periods of falling prices. Prices
of equity securities tend to fluctuate over the short term as a result of factors affecting
the individual companies, industries or the securities market as a whole. Equity securities
generally have greater price volatility than fixed income securities.
•
• Sector risk, which is the chance that significant problems will affect a particular sector,
or that returns from that sector will trail returns from the overall stock market. Daily
fluctuations in specific market sectors are often more extreme than fluctuations in the
overall market.
Issuer risk, which is the risk that the value of a security will decline for reasons directly
related to the issuer, such as management performance, financial leverage, and reduced
demand for the issuer's goods or services.
• Non-diversification risk, which is the risk of focusing investments in a small number of
issuers, industries or foreign currencies, including being more susceptible to risks
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associated with a single economic, political or regulatory occurrence than a more
diversified portfolio might be.
• Value investing risk, which is the risk that value stocks not increase in price, not issue the
anticipated stock dividends, or decline in price, either because the market fails to
recognize the stock’s intrinsic value, or because the expected value was misgauged. If the
market does not recognize that the securities are undervalued, the prices of those
securities might not appreciate as anticipated. They also may decline in price even though
in theory they are already undervalued. Value stocks are typically less volatile than
growth stocks, but may lag behind growth stocks in an up market.
• Smaller company risk, which is the risk that the value of securities issued by a smaller
company will go up or down, sometimes rapidly and unpredictably as compared to more
widely held securities. Investments in smaller companies are subject to greater levels
of credit, market and issuer risk.
•
• Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities
result in the portfolio experiencing more rapid and extreme changes in value than a
portfolio that invests exclusively in securities of U.S. companies. Risks associated with
investing in foreign securities include fluctuations in the exchange rates of foreign
currencies that may affect the U.S. dollar value of a security, the possibility of
substantial price volatility as a result of political and economic instability in the foreign
country, less public information about issuers of securities, different securities
regulation, different accounting, auditing and financial reporting standards and less
liquidity than in the U.S. markets.
Interest rate risk, which is the chance that prices of fixed income securities decline
because of rising interest rates. Similarly, the income from fixed income securities may
decline because of falling interest rates.
• Credit risk, which is the chance that an issuer of a fixed income security will fail to pay
interest and principal in a timely manner, or that negative perceptions of the issuer’s
ability to make such payments will cause the price of that fixed income security to
decline.
• Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF,
including the possible loss of principal. ETFs typically trade on a securities exchange
and the prices of their shares fluctuate throughout the day based on supply and
demand, which may not correlate to their net asset values. Although ETF shares will
be listed on an exchange, there can be no guarantee that an active trading market will
develop or continue. Owning an ETF generally reflects the risks of owning the
underlying securities it is designed to track. ETFs are also subject to secondary market
trading risks. In addition, an ETF may not replicate exactly the performance of the
index it seeks to track for a number of reasons, including transaction costs incurred
by the ETF, the temporary unavailability of certain securities in the secondary market,
or discrepancies between the ETF and the index with respect to weighting of
securities or number of securities held.
Derivatives Risk, entails the use of derivative instruments for a variety of purposes,
including hedging, risk management, portfolio management or to earn income. A
derivative is a financial instrument whose value is based, in part, on the value of an
underlying asset, interest rate, index or financial instrument (“reference instrument”
or “underlying asset”). In this context, derivatives include but are not limited to
futures, forwards, options, participatory notes, warrants, swaps and other similar
instruments that are normally valued based upon another or related asset. The use of
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derivatives can lead to losses because of adverse movements in the price or value of
the reference instrument, failure of the counterparty or tax or regulatory constraints.
Prevailing interest rates and volatility levels, among other things, also affect the value
of derivative instruments. A derivative instrument often has risks similar to its
underlying asset and can have additional risks, including imperfect correlation
between the value of the derivative and the underlying asset, risks of default by the
counterparty to certain transactions, magnification of losses incurred due to changes
in the market value of the securities, instruments, indices or interest rates to which
the derivative instrument relates, risks that the transactions might not be liquid and
risks arising from margin requirements. The use of derivatives involves risks that are
different from, and possibly greater than, the risks associated with other portfolio
investments. Derivatives can involve the use of highly specialized instruments that
require investment techniques and risk analyses different from those associated with
other portfolio investments. Certain derivative transactions give rise to a form of
leverage, which magnifies the portfolio’s exposure to the underlying asset. Leverage
associated with derivative transactions could cause an account to liquidate portfolio
positions when it might not be advantageous to do so to satisfy its obligations or to
meet earmarking or segregation requirements, including with respect to certain funds
to comply with applicable SEC rules and regulations, or could cause an account’s
value to be more volatile than might have been the case absent such leverage.
Derivatives risk could be more significant when derivatives are used to enhance
return or as a substitute for a position or security, rather than solely to hedge the risk
of a position or security held by a client portfolio. Derivatives for hedging purposes
might not reduce risk if they are not sufficiently correlated to the position being
hedged. A decision as to whether, when and how to use derivatives involves the
exercise of specialized skill and judgment, and a transaction could be unsuccessful in
whole or in part because of market behavior or unexpected events. Derivative
instruments can be difficult to value, can be illiquid, and can be subject to wide swings
in valuation caused by changes in the value of the underlying instrument. If a
derivative counterparty is unable to honor its commitments, the value of a client
portfolio could decline and/or the portfolio could experience delays in the return of
collateral or other assets held by the counterparty. The loss on derivative transactions
can substantially exceed the initial investment. Certain strategies use derivatives
extensively. Derivative investments also involve the risks relating to the reference
instrument. Although certain strategies seek to use derivatives to further a client’s
investment objectives, there is no assurance that the use of derivatives will achieve
this result.
Hedging Strategy risks, entails engaging in transactions designed to reduce the risk
or to protect the value of investments, including securities and currency hedging
transactions. These hedging strategies could involve a variety of derivative
transactions, including transactions in forward, swap and option contracts or other
financial instruments with similar characteristics, including, without limitation,
forward foreign currency exchange contracts, currency and interest rate swaps,
options and short sales (collectively “Hedging Instruments”). Certain risks associated
with Hedging Instruments are further detailed under “Derivative Risks.” Hedging
against a decline in the value of a portfolio position does not eliminate fluctuations in
the values of portfolio positions or prevent losses if the values of those positions
decline, but establishes other positions designed to gain from those same
developments, thus offsetting the decline in the portfolio positions’ value. While these
transactions can reduce the risks associated with an investment, the transactions
themselves entail risks that are different from and possibly greater than, the risks
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associated with other portfolio investments. The use of Hedging Instruments could
require investment techniques and risks analyses different from those associated with
other portfolio investments. The risks posed by these transactions include, but are not
limited to, interest rate risk, market risk, the risk that these complex instruments and
techniques will not be successfully evaluated, monitored or priced, the risk that
counterparties will default on their obligations, liquidity risk and leverage risk.
Changes in liquidity can result in significant, rapid and unpredictable changes in the
prices for derivatives. Thus, while the accounts might benefit from the use of Hedging
Instruments, unanticipated changes in interest rates, securities prices or currency
exchange rates could result in a poorer overall performance for the accounts than if
they had not used such Hedging Instruments.
Artificial Intelligence risk. Artificial Intelligence is a branch of computer science
focused on creating systems capable of performing taks that typically require human
intelligence; this includes, among other things, methods for analyzing, modeling and
understanding language as well as developing algorithms that can learn to perform
various tasks. Such usage is subject to the limitations of design of the application and
the sourcing of data. The use of artificial intelligence has inherent risks such as the
reliance on accurate imputs, sourcing and interpretation of data, and human
interpretation of results. Artificial intelligence continues to develop rapidly and it’s
impossible to predict future risk that may arise from such development.
• Management risk, which is the risk that the investment techniques and risk analyses
applied by LeClair Wealth Partners may not produce the desired results and that
legislative, regulatory, or tax developments, affect the investment techniques available
to LeClair Wealth Partners. There is no guarantee that a client’s investment objectives
will be achieved.
•
• Real Estate risk, which is the risk that an investor’s investments in Real Estate Investment
Trusts (“REITs”) or real estate-linked derivative instruments will subject the investor to
risks similar to those associated with direct ownership of real estate, including losses from
casualty or condemnation, and changes in local and general economic conditions, supply
and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and
operating expenses. An investment in REITs or real estate-linked derivative instruments
subject the investor to management and tax risks.
Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual funds,
the investor will bear additional expenses based on his/her pro rata share of the mutual
fund’s operating expenses, including the management fees. The risk of owning a mutual
fund generally reflects the risks of owning the underlying investments the mutual fund
holds.
• Cybersecurity risk, which is the risk related to unauthorized access to the systems and
networks of LeClair Wealth Partners and its service providers. The computer systems,
networks and devices used by LeClair Wealth Partners and service providers to us and our
clients to carry out routine business operations employ a variety of protections designed
to prevent damage or interruption from computer viruses, network failures, computer and
telecommunication failures, infiltration by unauthorized persons and security breaches.
Despite the various protections utilized, systems, networks or devices potentially can be
breached. A client could be negatively impacted as a result of a cybersecurity breach.
Cybersecurity breaches can include unauthorized access to systems, networks or devices;
infection from computer viruses or other malicious software code; and attacks that shut
down, disable, slow or otherwise disrupt operations, business processes or website access
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or functionality. Cybersecurity breaches cause disruptions and impact business
operations, potentially resulting in financial losses to a client; impediments to trading; the
inability by us and other service providers to transact business; violations of applicable
privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement
or other compensation costs, or other compliance costs; as well as the inadvertent release
of confidential information. Similar adverse consequences could result from cybersecurity
breaches affecting issues of securities in which a client invests; governmental and other
regulatory authorities; exchange and other financial market operators, banks, brokers,
dealers and other financial institutions; and other parties. In addition, substantial costs
may be incurred by those entities in order to prevent any cybersecurity breaches in the
future.
Alternative Investments / Private Funds risk, investing in alternative investments is
speculative, not suitable for all clients, and intended for experienced and sophisticated
investors who are willing to bear the high economic risks of the investment, which can
include:
loss of all or a substantial portion of the investment due to leveraging, short-selling
or other speculative investment practices;
lack of liquidity in that there may be no secondary market for the investment
and none expected to develop;
volatility of returns;
restrictions on transferring interests in the investment;
potential lack of diversification and resulting higher risk due to concentration of
trading authority when a single adviser is utilized;
absence of information regarding valuations and pricing;
delays in tax reporting;
less regulation and higher fees than mutual funds;
risks associated with the operations, personnel, and processes of the manager of the
funds investing in alternative investments.
• Closed-End Funds risk, Closed-end funds typically use a high degree of leverage. They
•
may be diversified or non-diversified. Risks associated with closed-end fund investments
include liquidity risk, credit risk, volatility and the risk of magnified losses resulting from
the use of leverage. Additionally, closed-end funds may trade below their net asset value.
Structured Notes risk -
• Complexity. Structured notes are complex financial instruments. Clients should
understand the reference asset(s) or index(es) and determine how the note’s
payoff structure incorporates such reference asset(s) or index(es) in calculating
the note’s performance. This payoff calculation may include leverage multiplied
on the performance of the reference asset or index, protection from losses should
the reference asset or index produce negative returns, and fees. Structured notes
may have complicated payoff structures that can make it difficult for clients to
accurately assess their value, risk and potential for growth through the term of the
structured note. Determining the performance of each note can be complex and
this calculation can vary significantly from note to note depending on the
structure. Notes can be structured in a wide variety of ways. Payoff structures
can be leveraged, inverse, or inverse-leveraged, which may result in larger
returns or losses. Clients should carefully read the prospectus for a structured
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note to fully understand how the payoff on a note will be calculated and discuss
these issues with LeClair Wealth Partners.
•
• Market risk. Some structured notes provide for the repayment of principal at
maturity, which is often referred to as “principal protection.” This principal
protection is subject to the credit risk of the issuing financial institution. Many
structured notes do not offer this feature. For structured notes that do not offer
principal protection, the performance of the linked asset or index may cause
clients to lose some, or all, of their principal. Depending on the nature of the
linked asset or index, the market risk of the structured note may include changes
in equity or commodity prices, changes in interest rates or foreign exchange
rates, and/or market volatility.
Issuance price and note value. The price of a structured note at issuance will
likely be higher than the fair value of the structured note on the date of issuance.
Issuers now generally disclose an estimated value of the structured note on the
cover page of the offering prospectus, allowing investors to gauge the difference
between the issuer’s estimated value of the note and the issuance price. The
estimated value of the notes is likely lower than the issuance price of the note to
investors because issuers include the costs for selling, structuring and/or hedging
the exposure on the note in the initial price of their notes. After issuance,
structured notes may not be re-sold on a daily basis and thus may be difficult to
value given their complexity.
• Liquidity. The ability to trade or sell structured notes in a secondary market is
often very limited, as structured notes (other than exchange-traded notes known
as ETNs) are not listed for trading on securities exchanges. As a result, the only
potential buyer for a structured note may be the issuing financial institution’s
broker-dealer affiliate or the broker-dealer distributor of the structured note. In
addition, issuers often specifically disclaim their intention to repurchase or make
markets in the notes they issue. Clients should, therefore, be prepared to hold a
structured note to its maturity date, or risk selling the note at a discount to its
value at the time of sale.
• Credit risk. Structured notes are unsecured debt obligations of the issuer,
meaning that the issuer is obligated to make payments on the notes as promised.
These promises, including any principal protection, are only as good as the
financial health of the structured note issuer. If the structured note issuer defaults
on these obligations, investors may lose some, or all, of the principal amount they
invested in the structured notes as well as any other payments that may be due on
the structured notes.
There also are risks surrounding various insurance products that are recommended to LeClair Wealth
Partners clients from time to time. Such risks include, but are not limited to loss of premiums. Prior to
purchasing any insurance product, clients should carefully read the policy and applicable disclosure
documents.
Clients are advised that they should only commit assets for management that can be invested for the long
term, that volatility from investing can occur, and that all investing is subject to risk. LeClair Wealth
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Partners does not guarantee the future performance of a client’s portfolio, as investing in securities involves
the risk of loss that clients should be prepared to bear.
Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss.
Voting Client Securities
F.
LeClair Wealth Partners does not accept the authority to and does not vote proxies on behalf of clients.
Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in
client LeClair Wealth Partners Wrap Fee Program portfolios.
Item 7 – Client Information Provided to Portfolio Managers
Any utilized External Managers for a client are selected by LeClair Wealth Partners. External Managers
are not provided client information since LeClair Wealth Partners has the responsibility to determine
whether the utilization of an External Manager is suitable for a client. External Managers have access to
client portfolio information in their execution of advisory services for a client.
Item 8 – Client Contact with Portfolio Managers
Clients may contact LeClair Wealth Partners personnel during regular business hours to discuss the
LeClair Wealth Partners Wrap Fee Program and their LeClair Wealth Partners Wrap Fee Program
accounts. Therefore, no restrictions are placed on a client’s ability to contact or consult with LeClair
Wealth Partners. Clients are not permitted access to contact or consult with any utilized External
Managers.
Item 9 – Additional Information
Disciplinary Information
A.
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s
management. LeClair Wealth Partners has no information applicable to this Item.
B.
Other Financial Industry Activities and Affiliations
Insurance Agent Activities
Advisory persons of LeClair Wealth Partners are licensed as insurance professionals. Such
persons earn commission-based compensation for selling insurance products to clients. Insurance
commissions earned by advisory persons who are insurance professionals are separate from and
in addition to LeClair Wealth Partners’s advisory fee. This practice presents a conflict of interest
as an advisory person who is an insurance professional has an incentive to recommend insurance
products for the purpose of generating commissions rather than solely based on client
needs. LeClair Wealth Partners addresses this conflict through disclosure and strives to make
recommendations which are in the best interests of its clients. Clients are under no obligation to
purchase insurance products through any person affiliated with LeClair Wealth Partners. LeClair
Wealth Partners clients should understand that lower fees and/or commissions for comparable
services may be available from other insurance providers.
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Broker Dealer Activities
Certain advisory persons of LeClair Wealth Partners are licensed as broker dealer
representatives. Such persons earn commission-based compensation for broker dealer
transactions. Commissions earned by advisory persons are separate from and in addition to
LeClair Wealth Partners’s advisory fee. These individuals are licensed through their affiliate,
LeClair Capital Partners, whos primary business is investment banking. This practice presents a
conflict of interest as an advisory person who participates in investment banking have an
incentive to recommend LeClair Wealth Partners for asset management services. LeClair Wealth
Partners addresses this conflict through disclosure and strives to make recommendations which
are in the best interests of its clients. Clients are under no obligation to purchase any products
through any person affiliated with LeClair Wealth Partners. LeClair Wealth Partners clients
should understand that lower fees and/or commissions for comparable services may be available
from other providers.
C.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
LeClair Wealth Partners has a Code of Ethics (the “Code”) which requires LeClair Wealth Partners’s
employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties
owed to the Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related
to conflicts of interest, outside business activities, gifts and entertainment, compliance with insider trading
laws and policies and procedures governing personal securities trading by supervised persons.
Personal securities transactions of supervised persons present potential conflicts of interest with the price
obtained in client securities transactions or the investment opportunity available to clients. The Code
addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a
client and requiring, with certain exceptions, supervised persons to report their personal securities holdings
and transactions to LeClair Wealth Partners for review by the Firm’s Chief Compliance Officer. The Code
also requires supervised persons to obtain pre-approval of certain investments, including initial public
offerings and limited offerings.
LeClair Wealth Partners will provide a copy of the Code of Ethics to any client or prospective client upon
request.
Review of Accounts
D.
While LeClair Wealth Partners Wrap Fee Program accounts are monitored on an ongoing basis, LeClair
Wealth Partners’s investment adviser representatives seek to have at least one annual meeting with each
client to conduct a formal review of the clients’ accounts. For smaller asset size client accounts and/or
clients with less complicated financial sitations annual reviews may be done through various electronic or
other means. Accounts are reviewed for consistency with the investment strategy and other parameters
set forth for the account and to determine if any adjustments need to be made.
Other Reviews and Triggering Factors
In addition to the periodic reviews described above, reviews may be triggered by changes in an
account holder’s personal, tax or financial status. Other events that may trigger a review of an
account are material changes in market conditions as well as macroeconomic and company- specific
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events. Clients are encouraged to notify LeClair Wealth Partners of any changes in his/her personal
financial situation that might affect his/her investment needs, objectives, or time horizon.
Regular Reports
Written brokerage statements are generated no less than quarterly and are sent directly from the
qualified custodian. These reports list the account positions, activity in the account over the covered
period, and other related information. Clients are also sent confirmations following each brokerage
account transaction unless confirmations have been waived.
LeClair Wealth Partners may also determine to provide account statements and other reporting to
clients on a periodic basis. Clients are urged to carefully review all custodial account statements
and compare them to any statements and reports provided by LeClair Wealth Partners. LeClair
Wealth Partners statements and reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
E.
Client Referrals and Other Compensation
Client Referrals
LeClair Wealth Partners does not receive benefits from third parties for providing investment
advice to clients. In addition, LeClair Wealth Partners does not enter into agreements with
individuals or organizations for the referral of clients to them. LeClair Wealth Partners enters into
agreements with individuals and organizations, some of whom may be affiliated or unaffiliated
with LeClair Wealth Parnter for the referral of clients to us. All such agreements will be in writing
and comply with the applicable state and federal regulations.
Other Compensation
As described above, LeClair Wealth Partners requires that LeClair Wealth Partners Wrap Fee
Program clients utilize RJA as the custodian for their LeClair Wealth Partners Wrap Fee Program
account(s). While there is no direct link between the investment advice LeClair Wealth Partners
provides and participation in the RJA program, LeClair Wealth Partners management receives
certain economic benefits from the RJA program. These benefits may include software and other
technology that provides access to client account data (such as trade confirmations and account
statements), facilitates trade execution (and allocation of aggregated orders for multiple client
accounts), provides research, pricing information and other market data, facilitates the payment of
LeClair Wealth Partners’s fees from its clients’ accounts, and assists with back-office functions,
recordkeeping and client reporting. Many of these services may be used to service all or a
substantial number of LeClair Wealth Partners’s accounts, including accounts not held at RJA.
RJA may also make available to LeClair Wealth Partners other services intended to help LeClair
Wealth Partners manage and further develop its business. These services may include consulting,
publications and conferences on practice management, information technology, business
succession, and marketing. In addition, RJA may make available, arrange and/or pay for these
types of services to be rendered to LeClair Wealth Partners by independent third parties. RJA
may discount or waive fees it would otherwise charge for some of these services, pay all or a part
of the fees of a third-party providing these services to LeClair Wealth Partners, and/or RJA may
pay for travel expenses relating to participation in such training. Finally, participation in the RJA
program provides LeClair Wealth Partners with access to mutual funds which normally require
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significantly higher minimum initial investments or are normally available only to institutional
investors.
The benefits received through participation in the RJA program do not necessarily depend upon
the proportion of transactions directed to RJA. The benefits are received by LeClair Wealth
Partners, in part because of commission revenue generated for RJA by LeClair Wealth Partners’s
clients. This means that the investment activity in client accounts is beneficial to LeClair Wealth
Partners, because RJA does not assess a fee to LeClair Wealth Partners for these services. This
creates an incentive for LeClair Wealth Partners to continue to recommend RJA to its clients.
While it may be possible to obtain similar custodial, execution and other services elsewhere at a
lower cost, LeClair Wealth Partners believes that RJA provides an excellent combination of these
services. These services are not soft dollar arrangements, but are part of the institutional platform
offered by RJA.
Financial Information
F.
LeClair Wealth Partners is not required to disclose any financial information pursuant to this item due to
the following:
a) LeClair Wealth Partners does not require or solicit the prepayment of more than $1,200 in
fees six months or more in advance of rendering services;
b) LeClair Wealth Partners is unaware of any financial condition that is reasonably likely to
impair its ability to meet its contractual commitments relating to its discretionary authority
over certain client accounts; and
c) LeClair Wealth Partners has never been the subject of a bankruptcy petition.
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