DISCLOSURE BROCHURE (FORM ADV PART 2A)
Myra Wealth (CRD 311475), brochure dated October 6, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Item 1 – Cover Page
Disclosure Brochure
(Form ADV, Part 2A)
MYRA Advisors LLC
(805) 380-MYRA
October 1st, 2026
This Disclosure Brochure provides information about the qualifications and business practices of
MYRA Advisors LLC. If clients have any questions about the contents of this brochure, please
contact Compliance@MyraWealth.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.
MYRA Advisors LLC is a registered investment adviser. Registration as an investment adviser
does not imply any level of skill or training. Additional information about MYRA Advisors LLC is
available on SEC’s website at www.adviserinfo.sec.gov by conducting a Firm search using our
Firm CRD No. 311475.
Item 2 – Material Changes
Initially, during account opening, the Client acknowledges receipt of a copy of Advisor’s Form
ADV, Part 2A (“Disclosure Brochure”), Part 2B (“Brochure Supplement”), Part 3 (“Form CRS”),
and Privacy Policy. Advisor provides Client with either a Summary of Material Changes or an
updated Disclosure Brochure on an annual basis. Advisor provides Client with an updated
Brochure Supplement when material changes occur.
Since our Disclosure Brochure dated January 1st, 2026, we have some material changes:
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Item 5, INVEST Fees: The same tiered INVEST fee schedule now applies to all Clients,
regardless of whether their CONSULT subscription is FREE or PAID. INVEST fees are
calculated at the Household level using combined AUM across all Accounts managed by
Advisor within the Household. The fee tiers apply progressively to combined Household
AUM, and the resulting fee is allocated proportionately among Accounts. The $25
monthly minimum INVEST fee has been eliminated.
Item 5, Fees In-Advance: INVEST Services renew automatically on a monthly basis until
terminated and may be terminated at any time upon written notice. For a newly opened
Account, the initial month’s INVEST fee is billed in arrears following month-end, based
on the Account’s Month End Balance and the applicable Household effective annual fee
rate, and prorated for the calendar days the Account was under management, including
the opening date. Beginning with the second month, INVEST fees are billed monthly in
advance based on the prior Month End Balance and the applicable Household effective
annual fee rate. If an Account is terminated mid-month, the Client will receive a prorated
refund of the fee billed in advance for the calendar days after termination.
Advisor’s Form ADV, Part 2A and Part 3 are also currently available on www.adviserinfo.sec.gov
by conducting a Firm search using Advisor’s CRD Number.
Item 3 – Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Business
Item 5 – Fees and Compensation
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Client Transactions, Personal Trading
Item 12 – Brokerage Practices
Item 13 - Review of Accounts
Item 14 - Client Referrals and Other Compensation
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
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Item 4 – Advisory Business
MYRA Advisors LLC (dba MYRA Wealth) is a registered investment adviser (“RIA”) with the US
Securities and Exchange Commission (“SEC”). MYRA Advisors LLC is a Delaware limited
liability company formed in 2019, and is wholly-owned by MYRA, Inc.
As of December 31st, 2025, we had approx. $65M of discretionary assets under management.
MYRA Advisors LLC provides INVEST, PLAN and CONSULT services. These services are
offered via 2 plan types: (1) FREE (30-day trial), or (2) PAID subscriptions. There are 4 types of
PAID subscriptions: (1) Non-Accredited Individual, (2) Accredited Individual, (3) Non-Accredited
Household, and (4) Accredited Household.
Note: You are an Accredited Investor if: (1) your Net worth is over $1 million, excluding primary
residence (individually or with spouse or partner), OR (2) you earned an income of over
$200,000 (individually) or $300,000 (with a spouse or partner) in each of the prior two years,
and reasonably expect the same for the current year. Note: You are a Household if you have a
spouse or partner.
FREE (30-day trial) includes the Dashboard, and may include INVEST services for an additional
fee. FREE (30-day trial) does not include any consultations from a financial advisor. Clients may
avail CONSULT (One-Time) services for an additional fee when enrolled in the FREE (30-day
trial). PAID subscriptions include Dashboard, PLAN and CONSULT (ongoing) services, and may
include INVEST services for an additional fee.
Clients may access our services through an interactive website operated by our affiliate, MYRA
Technologies LLC (“Platform”). MYRA Technologies LLC is a wholly-owned subsidiary of MYRA,
Inc. This Platform is an interactive website in which computer software-based models and
applications provide advice to clients based on personal information provided by each client
through the website, and offers clients a variety of educational resources, account aggregation
tools, access to tax services offered by MYRA Tax LLC (an affiliate and wholly-owned subsidiary
of MYRA, Inc.), and access to other unaffiliated products and services providers.
PLAN enables a client to create a digital financial plan using online tools on the Platform. The
financial plan includes various topics, including a summary of income and assets, education
savings, insurance, investment planning, tax strategies, saving for retirement, estate planning,
employee benefits selection, and other related planning.
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CONSULT enables clients to schedule a consultation with an adviser, typically a CERTIFIED
FINANCIAL PLANNER® to discuss various topics including basic finances, education savings,
1 CERTIFIED FINANCIAL PLANNER® , CFP® and federally registered CFP (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by
Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary
insurance, tax strategies, saving for retirement, estate planning, employee benefits selection,
and other related planning.
INVEST enables a client to open taxable brokerage (e.g. individual brokerage, joint brokerage,
trust), retirement (e.g. IRA, Roth IRA, SEP IRA), education savings (e.g. 529 plan) and health
savings accounts (collectively referred to “Account”). The portfolio composition typically is made
up of cash and exchange-traded funds (ETFs). We do not offer a wrap-fee program (a program
that includes transaction costs in the advisory fee); however, we try to use zero commission fee
ETFs to minimize transaction costs. INVEST services will be provided on a discretionary basis,
which means that clients grant us the authority to make investment decisions and implement
transactions on client's behalf without obtaining client's prior consent and approval. Clients may
impose restrictions on investing in certain securities or types of securities in accordance with
client's values or beliefs as long as such restrictions allow us to reasonably manage client's
assets. Client's assets will be held with a qualified custodian. Please see Item 12 below for
further information on the custodians and brokerage practices.
To receive our services, clients will be asked to provide information through the Platform.
Because we rely on information clients provide to make our recommendations, it is important
that clients provide complete and accurate information. Clients should notify us immediately of
any changes in client's financial objectives, goals, and risk tolerance, as well as any other
material changes to client's personal financial circumstances (such as client's employment
status, marital status, or financial condition) by updating their Settings in the Platform. These
changes may affect our recommendations. In providing our services, we are not required to
verify any information we receive from clients or from other professionals acting on client's
behalf (e.g., attorney, accountant, payroll providers), and we are expressly authorized to rely on
the information clients provide directly or indirectly. When clients are enrolled as a household,
we may rely on the information provided by any one client on behalf of the other client (typically
a spouse or partner).
Clients receive our Disclosure Brochure, Form CRS, Privacy Policy and Terms of Use through
the Platform before being presented with an advisory agreement. If clients wish to engage our
services, clients will accept our disclosures and execute the advisory agreement electronically.
We will use our best judgment and good faith effort in providing services to our clients. As an
RIA, we act as a client's fiduciary, which means that we must act in the client's best interests.
We cannot guarantee the success of any recommendations we provide, or any particular level
certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It
is recognized in the United States and a number of other countries for its (1) high standard of professional
education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. To attain the right to use the CFP® marks, an individual
must satisfactorily fulfill the CFP Board requirements of education, examination, experience, and ethics.
of performance, or that an investment will be profitable over time. Past performance does not
guarantee future results. Investing involves risk, and investments may lose value over time.
Except as otherwise provided by law, we are not liable for any losses in an account if our
investment decisions and actions are made in good faith with the degree of care, skill, and
prudence that a person acting in a fiduciary capacity would use. In addition, we are not liable for
any losses arising as a result of following client's directives, or for any act or failure to act by a
service provider (e.g. custodian) maintaining an account.
IRA Rollover Considerations
As part of our CONSULT and INVEST services, we may provide you with education and
guidance concerning the options you may have with regard to your employer retirement plan or
other qualified retirement account. One option may include rolling over the assets over to an
individual retirement account (“IRA”) to be managed by our firm. If you elect to roll the assets to
an IRA under our management, we will charge you an asset-based fee as described in Item 5.
This practice presents a conflict of interest.
You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if
you do complete the rollover, you are under no obligation to have your IRA assets managed
under our program or a third party manager. You have the right to decide whether to complete
the rollover and the right to consult with other financial professionals. Some employers permit
former employees to keep their retirement assets in their company plan. Also, current
employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following
options are available, you should consider the costs and benefits of each. An employee will
typically have four options:
1. Leave the funds in your employer’s (former employer’s) plan,
2. Rollover the funds to a new employer’s retirement plan,
3. Cash out and take a taxable distribution from the plan, or
4. Roll the funds into an IRA rollover account.
Each of these options has advantages and disadvantages. Before making a change, we
encourage you to speak with an independent financial advisor, CPA and/or tax attorney. It is
important that you understand your options, their features, and their differences, and decide
whether a rollover is best for you. Before rolling over your retirement funds to an IRA for us to
manage or to a third party manager, carefully consider the following (This list is not exhaustive):
1. Determine whether the investment options in your employer’s retirement plan address
your needs or whether other types of investments are needed. Employer retirement
plans generally have a more limited investment menu than IRAs. Employer retirement
plans may have unique investment options not available to the public, such as employer
securities or previously closed funds.
2. Your current plan may have lower fees than our fee and/or the third party manager’s fee
combined. If you are interested in investing only in mutual funds, you should understand
the cost structure of the share classes available in your employer’s retirement plan and
how the costs of those share classes compare with those available in an IRA.
3. You should understand the various products and services available through an IRA
provider and their costs.
4. It is likely you will not be charged a management fee and will not receive ongoing asset
management services unless you elect to have such services. If your plan offers
management services, the fee associated with the service may be more or less than our
fee and/or the third party manager’s fee combined.
5. The third party manager’s or our management strategy may have higher risk than the
options provided to you in your plan.
6. Your current employer plan may offer financial advice, guidance, management and/or
portfolio options at no additional cost.
7. If you keep your assets titled in a 401(k) or retirement account, you could potentially
delay your required minimum distribution beyond the required minimum distribution age.
8. Your 401(k) may offer more liability protection than a rollover IRA; each state varies.
Generally, Federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies; however, there can
be exceptions. Consult an attorney if you are concerned about protecting from creditors.
9. You may be able to take out a loan on your 401(k), but not from an IRA.
10. IRA assets can be accessed any time; however, distributions are subject to ordinary
income tax and may also be subject to a 10% early distribution penalty unless they
qualify for an exception such as disability, higher education expenses or home purchase.
11. If you own company stock in your plan, you may be able to liquidate those shares at a
lower capital gains tax rate.
12. Your plan may allow you to hire us or another firm as the manager and keep the assets
titled in the plan name.
fiduciary
In addition to complying with applicable SEC rules, MYRA Wealth is subject to certain rules and
regulations adopted by the U.S. Department of Labor when we provide non discretionary
investment advice to retirement plan participants and IRA owners. When these DOL rules apply,
our advisors and MYRA Wealth are “fiduciaries,” for purposes of the Employee Retirement
Income Security Act of 1974 (“ERISA”), as amended, and the Internal Revenue Code of 1986
(“the Code”), as amended. Therefore, MYRA Wealth and our advisors may not receive
payments that create conflicts of interest when providing fiduciary investment advice to plan
sponsors, plan participants, and IRA owners, unless we comply with a prohibited transaction
exemption (“PTE”). As fiduciaries under ERISA and the Code, we render advice that is in plan
participants’ and IRA customers’ best interest. MYRA Wealth and our advisors’ status as an
ERISA/Code
is limited to ERISA/Code covered nondiscretionary advice and
recommendations regarding rolling over a retirement account and does not extend to all
situations.
Item 5 – Fees and Compensation
MYRA offers 2 types of subscriptions:
1. FREE subscription: $0 per month. 30-day trial.
2. PAID subscription(s): Starting at $3,000 per year. Auto renews.
Note: By default, all Clients are enrolled in the FREE subscription (30-day trial). Clients may
subscribe to the PAID subscription via the MYRA Portal (i.e., interactive website) within or after
the initial 30 days. If a client does not elect a PAID subscription, MYRA reserves the right to
disable or delete the client’s account, including deletion of any links to banks, documents added,
or other personal information provided by client.
Note: The FREE subscription includes access to the Dashboard and PLAN service. The FREE
subscription (30-day trial) does not include any consultations with a financial advisor. Clients
subscribed in the FREE subscription (30-day trial), may avail One-Time Consultations ranging
from $0 to $15,000 per consultation. A typical CONSULT (one-time) is $1,500 for a one-time
45-minute consultation by video or audio conference within 30 days. Clients subscribed in the
FREE plan may also elect to receive INVEST services for an additional fee (described below).
Clients may also elect to subscribe to PAID subscriptions, which includes access to the
Dashboard, PLAN, CONSULT, and INVEST services (for an additional fee). CONSULT includes
unlimited consultation for up to 12 months with a Certified Financial Planner® (CFP®) to discuss
your personal finances. INVEST services are available for an additional fee (described later).
There are 4 types of PAID subscriptions:
1. Non-Accredited, Individual = $3,000 per year
2. Accredited, Individual = $4,000 per year + $1,000 per year **
3. Non-Accredited, Household = $4,500 per year
4. Accredited, Household = $6,000 per year + $1,000 per year **
** for each additional $1 million of Net Worth over $1 million.
Example: For an Accredited Individual with earned income over $200,000 but Net Worth of
under $1 million, the annual fee is $4,000; but with a Net Worth of at least $1 million but under
$2 million, the annual fee would be $4,000 + $1,000 = $5,000 per year. For an Accredited
Household with earned income over $300,0000 but Net Worth under $1 million, the annual fee
is $6,000; but with a Net Worth of at least $4 million but less than $5 million would be $6,000 +
$4,000 = $10,000 per year.
Note: You are Accredited if: (1) your Net Worth is over $1 million, excluding primary residence
(individual or household), OR (2) you earned an income over $200,000 (individual) or $300,000
(household) in each of the prior two years, and reasonably expect the same for the current year.
During initial sign-up, the Client must subscribe via MYRA Portal to a PAID subscription that
best describes their financial status (Accredited vs. Non-Accredited) and personal situation (e.g.
Individual vs. Household). After initial sign-up, the Client or Advisor may update the PAID
subscription type based on the Client’s current financial status and personal situation. The
Advisor encourages the Client to notify the Advisor promptly if the Client's financial status or
personal situation changes. The Client should review your PAID subscription for accuracy, and
inform the Advisor immediately if there is a discrepancy. PAID subscriptions auto-renew until
canceled by the Client from the MYRA Portal, under Settings >> Billing.
The initial subscription term is 1 year (or 12 months) from the date of engagement. Upon the 1
year anniversary of the initial subscription, the PAID subscription will automatically renew for 12
months until cancelled, or on a prorated basis to the next June 30th at the sole discretion of
Advisor. If renewed until June 30th, the PAID subscription will then auto-renew on an annual
basis as of July 1st of each year, until cancelled. The Adviser has the discretion to modify this
renewal schedule at its discretion, and upon notice to the Client.
Example, if a Client initially subscribes to a PAID subscription on Jan 1st, 2026, the initial
subscription term is 12 months from the date of engagement, or until Dec 31st, 2026. Assuming
Advisor exercises discretion, the client contract is now renewed from Jan 1st, 2027 to June
30th, 2027 (for 6 months in this case); and then auto-renews from July 1st, 2027 to June 30th
2028 (for 12 months), and subsequently from July 1st to June 30th each year, until cancelled.
PAID subscriptions may be terminated at any time upon written notice. PAID subscriptions are
typically paid in full at the beginning of the engagement, and at the beginning of each renewal
term. Advisor performs services within the first 30 days of each subscription term, including
renewal terms. Services during the remainder of the term are generally limited to follow-ups,
answering questions, implementation assistance, and ongoing maintenance of the Client’s
relationship. Therefore, the fees are considered earned after the first month of any engagement
or renewal, and fees are non-refundable if the Client terminates the PAID subscription before
the end of the initial or renewal term. However, the Advisor may grant exceptions to this policy
at its sole discretion.
PAID subscription upgrades that result in a fee increase (e.g. Non-Accredited Individual to
Accredited Individual, or Non-Accredited Individual to Non-Accredited Household) take effect
immediately, and auto renew for a 12 month period from the date of subscription type change
(i.e., the new Effective Date), or until June 30th at the sole discretion of Advisor. The Client is
charged the full subscription fee for the new Subscription, and then issued a prorated refund for
the old Subscription fees, if applicable.
Example: If Client signed up as Non-Accredited Individual ($3,000 per year) on January 1st,
2026 and consequently got married on July 1st, 2026 and upgraded to Non-Accredited
Household ($4,500 per year), then on July 1st, 2026 the Client would be billed $4,500 for the
Non-Accredited Household (new) subscription effective from July 1st, 2026 to June 30, 2027
(with automatic annual renewal on July 1st, 2027), and would be refunded $3,000 x 6 months =
$1,500 for the Non-Accredited Individual (old) subscription.
PAID subscription type downgrades that result in a fee decrease (e.g. Accredited Individual to
Non-Accredited Individual, or Accredited Household to Accredited Household) only take effect at
the end of the 12 months from the Effective Date, when the Agreement is due for auto renewal.
In this case, there would be no refund.
Example: If Client signed up for Non-Accredited Household ($4,500 per year) on January 1st,
2026 and consequently got divorced on July 1st, 2026, then on January 1st, 2027 the Client
would be downgraded to Non-Accredited Individual (new) subscription, and auto renewed at
$3,000 per year. Since the subscription type change is at the end of the 12 month period, there
is no refund due to the Client.
Clients may engage an Advisor for PLAN Services. Fees range from $0 to $15,000 depending
on the scope and timeline of the engagement. The scope and timelines are mutually agreed
upon by the Advisor and Client. PLAN Services fees are non-refundable. Client is responsible
for payment of fees prior to termination.
Clients may avail INVEST Services for an additional fee with any CONSULT Services:
Our annual fee for INVEST services ranges from 1.50% (150 basis points) to 0.25% (25 basis
points) of assets under management (“AUM”). Specifically, the tiered fee structure is as follows:
● 1.50% = $0 to $1M AUM
● 1.25% = $1M to $2M AUM
● 1.00% = $2M to $3M AUM
● 0.75% = $3M to $4M AUM
● 0.50% = $4M to $5M AUM
● 0.25% = $5M+ AUM
Note: INVEST Services fees are applied at the Household level based on the combined AUM of
all Accounts managed by Advisor within the Household. The tiers apply progressively to the
corresponding portions of combined Household AUM. The resulting annual fee divided by
combined Household AUM determines the Household’s effective annual fee rate, which is
applied to each Account’s balance to allocate the fee proportionately among Accounts.
INVEST Services renew automatically on a monthly basis until terminated. For an existing
Account, the INVEST fee for each month is billed in advance based on the Account’s balance at
the end of the prior month. For a newly opened Account, the fee for the initial month is billed in
arrears following the end of that month, based on the Account’s balance at the end of the initial
month. If an Account opens or terminates during a month, the fee for that month is prorated
based on the number of calendar days the Account was under Advisor’s management, including
the opening or termination date. If a fee was billed in advance for a month in which the Account
terminates, Advisor will refund the portion attributable to the calendar days after termination.
Example: Client opens an Account on January 10. This is the Household’s only Account
managed by Advisor. The Account has a Month End Balance of $50,000 on January 31. On
February 1, Client will be billed $44.35 for January in arrears ($50,000 × 1.50% ÷ 12 × 22/31
calendar days) and $62.50 for February in advance ($50,000 × 1.50% ÷ 12), for a total of
$106.85 billed on February 1. Beginning March 1, each monthly INVEST fee will continue to be
billed in advance based on the prior Month End Balance. If the Account subsequently
terminates during a month that was billed in advance, Advisor will issue a prorated refund for
the days after the termination date.
Advisor’s full-month INVEST fee allocated to each Account is determined by multiplying the
applicable Household effective annual fee rate by the Account’s Month End Balance and
dividing by 12. For a partial month, the percentage-based fee is prorated based on the number
of calendar days the Account was under Advisor’s management during that month, including the
opening or termination date. For the initial month of a newly opened Account, “Month End
Balance” means the Account balance as of the last business day of that initial month. For each
subsequent month, it means the Account balance as of the last business day of the prior month.
The Household effective annual fee rate is determined using combined Household AUM as of
the same applicable month-end.
Example 1: Client A has a combined Household Month End balance of $100,000. The billed
Household fee is $125 per month (as 100,000 x 1.50% / 12 = 125).
Example 2: Client B has a combined Household Month End balance of $10,000. The billed
Household fee is $12.50 per month (as 10,000 x 1.50% / 12 = 12.50).
Example 3: Client C has a combined Household Month End balance of $25,000. The billed
Household fee is $31.25 per month (as 25,000 x 1.50% / 12 = 31.25).
Note: Fees are rounded up or down to 2 decimal places (i.e., $2.085 is rounded up to $2.09,
and $2.084 is rounded down to $2.08).
Upon signing the Client Agreement, the Client authorizes the Advisor to deduct all Service fees
(including, but not limited to CONSULT fees, INVEST fees, PLAN fees, and TAX fees) directly
from the Client’s Account managed by Advisor (“Account”) at qualified custodian. This fee
authorization is also approved by the Client in the brokerage account agreement with the
Custodian. If there is insufficient cash in Client’s Account to pay Advisor’s fees, securities in
Client’s Account may be sold to pay Advisor’s fee.
If a Client's Account does not have a sufficient balance of securities to pay the Advisor's fee, the
Advisor may deduct your fees from another Client Account in the same household. Example: if
Advisor’s fee is $100 on Client’s Account, but the Client’s Account does not have a $100 cash
(or security) balance available, then Advisor may deduct the $100 fees from Client’s Spouse’s
Account (if under the same household).
The Client’s fees for Services (including, but not limited to CONSULT fees, INVEST fees, PLAN
fees, and TAX fees) will typically be directly deducted from the Client’s Account. If the Client
does not have an active Client Account, fees may be paid by bank transfer (ACH or wire
transfer), credit card, or debit card, at Advisor’s discretion. An ~3% surcharge applies for fees
paid by credit card or debit card.
For CONSULT Services, especially for new Clients, who don’t have a Client Account (managed
by Advisor), the PAID subscription fees are paid via credit card or debit card upon signing the
CONSULT Client Agreement. At renewal, unless cancelled, if Client has a Client Account
(managed by Advisor), then the CONSULT fees will be directly deducted from the Client’s
Account (managed by Advisor). When CONSULT fees are deducted from Client’s Account, then
auto-renewal payments via credit card or debit card will be discontinued. If the Client does not
have an active Client Account (managed by Advisor), then auto-renewal payments for
CONSULT services will continue to be processed via credit card or debit card provided by the
Client, when initially signing the CONSULT Client Agreement. The Client may request to pay
CONSULT service fees via bank transfer (ACH or wire transfer) to avoid the ~3% credit card
surcharge, which may be approved at the sole discretion of the Advisor.
Our Services fees (including, but not limited to CONSULT fees, INVEST fees, PLAN fees, and
TAX fees) are generally not negotiable, although we do reserve the right to waive or reduce fees
in certain circumstances, or to offer promo or hardship discounts at sole discretion of Advisor.
Clients may also be charged an ACH transaction fee (both for a deposit into the Account or
withdrawal from the Account). Neither Advisor nor any affiliate retains or receives a share of the
ACH fee, which is retained solely by the ACH processor. In addition to our advisory fees, clients
may incur additional charges on Client’s Account(s), such as custodial fees, brokerage
commissions, internal fees and expenses charged by mutual funds and ETFs, account
maintenance and termination fees, and other fees and taxes on Accounts. Client is responsible
for payment of all other third party fees (e.g., custodial fees, mutual fund fees, 12b-1 fees,
transaction fees). Those fees are separate from Advisor’s Services fees.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not assess performance-based fees, and we do not engage in side-by-side management
of accounts.
Item 7 – Types of Clients
Our PLAN, CONSULT, INVEST services are appropriate for individuals (including high net worth
individuals), trusts and businesses. We do not impose an AUM minimum to receive services.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We primarily practice passive investment management. Passive investing involves building
portfolios that are composed of various distinct asset classes. The asset classes are weighted in
a manner to achieve a desired relationship between risk and return. Funds that passively
capture the returns of the desired asset classes are placed in the portfolio. The funds that are
used to build passive portfolios are typically exchange traded funds (“ETF”). Passive investment
management is characterized by low expense ratios (i.e. the funds inside the portfolio have low
internal costs), minimal trading costs (due to infrequent trading activity), and relative tax
efficiency (because the funds inside the portfolio are tax efficient and turnover inside the
portfolio is minimal). In contrast, active management involves a single manager or managers
who employ some method, strategy or technique to construct a portfolio that is intended to
generate returns that are greater than the broader market or a designated benchmark.
Academic research indicates most active managers underperform the market. A portfolio that
employs a passive, “efficient markets” approach (generally representative of index investing)
has the potential risk at times to generate lower-than-expected returns for the broader allocation
than might be the case for a more narrowly focused asset class, and the return on each type of
asset may deviate from the average return for the asset class. We believe this variance from the
expected return is generally low under normal market conditions when a portfolio is made up of
diverse, low-correlated or uncorrelated assets. Our investment portfolios are designed to
produce the appropriate potential return for the given level of risk; however, we cannot
guarantee that an investment objective or goal will be achieved. Clients must be able to bear the
risk of loss that is associated with their account, which may include the loss of some or all
principal invested.
Material Risks Involved: All investments involve risk and may result in a loss of client's original
investment which clients should be prepared to bear. Many of these risks apply equally to
stocks, bonds, commodities and any other investment or security. To the extent we provide
analysis or recommendations for the client's investment portfolio, clients should be aware of
some material risks that exist with investing, including the following:
●
● Company Risk: When investing in securities, there is always a certain level of company
or industry-specific risk that is inherent in each company or issuer. For example, there is
the risk that a company will perform poorly or have its value reduced based on factors
specific to the company or its industry. This is also referred to as unsystematic risk and
can be reduced or mitigated through diversification.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much
as a dollar next year because purchasing power is eroding at the rate of inflation.
● Management Risk: An investment with a firm varies with the success and failure of its
investment strategies, research, analysis and determination of its portfolio. If an
investment strategy were not to produce expected returns, the value of the investment
would decrease.
● Market Risk: When the stock market as a whole or an industry as a whole falls in value,
it can cause the prices of individual stock prices to fall indiscriminately. This is also called
systemic or systematic risk.
● Research Data: When research and analyses are based on commercially available
software, rating services, general market and financial information, or due diligence
reviews, a firm is relying on the accuracy and validity of the information or capabilities
provided by selected vendors, rating services, market data, and the issuers themselves.
Therefore, while we may make efforts to determine the accuracy of the information
received, we cannot predict the outcome of events or actions taken or not taken, or the
validity of all information researched or provided which may or may not affect the advice
regarding or investment management of an account.
● Security-Specific Risks: Our asset selection process seeks to identify ETFs which exhibit
high liquidity, low expenses, and low tracking error. Our selection process does not
guarantee the quality of a particular ETF or that it will (1) be profitable, (2) properly track
any comparable index, (3) trade in a liquid fashion, or (4) trade at or above its
publicly-posted net asset value. We reserve the right to change the selection of ETFs we
recommend at any time. Changes in the selection of ETFs that we use may result in the
sale of existing holdings and could be subject to additional tax liability.
● Small- and Mid-Cap Company Risk: A portion of most portfolios will include investments
in ETFs that invest in small and medium market capitalization companies. Securities of
companies with small and medium market capitalizations are often more volatile and
less liquid than investments in larger companies. Small and medium capitalization
companies may face a greater risk of business failure, which could increase the volatility
of the Client’s portfolio.
● Cash Drag Risk: The allocation of cash within a client's portfolio has an impact on
portfolio performance. As the allocation to cash increases, the volatility of the entire
portfolio is reduced. In times when invested assets are increasing in value, portfolios with
increased amounts of cash lead to returns which lag a fully invested portfolio.
Alternatively, when invested assets are declining in value, portfolios with an increased
amount of cash lead to a less significant decline in the portfolio.
● ETF Risks: The risk of owning ETFs reflect the risks of their underlying securities (e.g.,
alternative investments, stocks, bonds, etc.). ETFs also carry additional expenses based
on their share of operating expenses and certain brokerage fees, which may result in the
potential duplication of certain fees.
● Fixed Income Risks: Various forms of fixed income instruments, such as bonds, money
market or bond funds, or certain ETFs containing these holdings, may be affected by
various forms of risk, including: [1] Credit Risk – The potential risk that an issuer would
be unable to pay scheduled interest or repay principal at maturity, sometimes referred to
as “default risk.” Credit risk may also occur when an issuer’s ability to make payments of
principal and interest when due is interrupted. This may result in a negative impact on all
forms of debt instruments, as well as funds or ETF share values that hold these issues.
Bondholders are creditors of an issuer and have priority to assets before equity holders
(i.e., stockholders) when receiving a payment from liquidation or restructuring. When
defaults occur due to bankruptcy, the type of bond held will determine payment seniority.,
[2] Duration Risk – Duration is a measure of a bond’s volatility, expressed in years to be
repaid by its internal cash flow (interest payments). Bonds with longer durations carry
more risk and have higher price volatility than bonds with shorter durations., [3] Interest
Rate Risk – The risk that the value of the fixed income holding will decrease because of
an increase in interest rates., [4] Liquidity Risk – The inability to readily buy or sell an
investment for a price close to the true underlying value of the asset due to a lack of
buyers or sellers. While certain types of fixed income instruments are generally liquid
(i.e., bonds), there are risks which may occur such as when an issue trading in any given
period does not readily support buys and sells at an efficient price. Conversely, when
trading volume is high, there is also a risk of not being able to purchase a particular
issue at the desired price., and [5] Reinvestment Risk – With declining interest rates,
investors may have to reinvest interest income or principal at a lower rate.
Index Investing: Index investing may have the potential to be affected by “active risk” (or
“tracking error risk”), which might be defined as a deviation from a stated benchmark. If a
portfolio attempts to closely replicate a stated benchmark, the source of the tracking error or
deviation may come from a satellite portfolio or position, or from a “sample” or “optimized” index
fund or ETF that may not as closely align the stated benchmark. In these instances, a portfolio
manager may choose to reduce the weighting of a satellite holding, utilize very active satellites,
or use a “replicate index” position as part of its core holdings to minimize the effects of the
tracking error in relation to the overall portfolio.
Qualified Dividend Income (“QDI”) Ratios: While many ETFs and index mutual funds are known
for their potential tax-efficiency and higher QDI percentages, there are asset classes within
these investment vehicles or holding periods within that may not benefit. Shorter holding
periods, as well as commodities and currencies (that may be part of an ETF or mutual fund
portfolio), may be considered “non-qualified” under certain tax code provisions. A holding’s QDI
should be considered when tax-efficiency is an important aspect of the client’s portfolio.
Use of Algorithms: We use computer-based technology to make investment recommendations
and in the portfolio management processes. Accounts are continuously monitored by
rebalancing software to ensure the investments held correctly reflect the selected model
portfolio. Clients should be aware that this type of portfolio management is based on a pre-set
investment allocation that could rebalance the client's account and not take certain market
conditions into consideration. Such trading may occur on a more frequent basis than clients
might expect and may not address prolonged changes in market conditions. Understand that
changes to the algorithmic code could also have material effects on client's portfolio
recommendations and investment management. In the event of extraordinary market conditions,
we may halt trading or take other temporary measures meant to ensure client's financial
protection.
Alternative Investments: Strategies involving “alternative” investments generally include those
which do not fall into equity, fixed income or cash equivalents. Such investments would include
“real assets” such as real estate and commodities, and alternative strategies such as absolute
return strategies and various other hedge fund-type strategies: global macro, managed futures,
long/short equity, multi-strategy, event driven, private equity, etc. The goal of these alternative
strategies is to provide for diversification in order to lower portfolio volatility and enhance
long-term returns. The alternative investments we recommend are managed through ETFs; they
are not individual holdings. We do not directly invest in any alternative investments including
hedge funds, managed futures accounts, or private equity.
Catastrophic Events: Our investment strategies may be subject to the risk of loss arising from
direct or indirect exposure to a number of types of catastrophic events, such as global
pandemics, natural disasters, acts of terrorism, cyber-attacks, or network outages. The extent
and impact of any such event on investment strategies will depend on many factors, including
the duration and scope of the event, the extent of any governmental restrictions, the effect on
the supply chain, overall consumer confidence, and the extent of the disruption to global and
domestic markets.
Item 9 – Disciplinary Information
We have not been involved, and our management personnel have not been involved, in any
material criminal or civil action in a domestic, foreign or military jurisdiction, an administrative
enforcement action, or self-regulatory organization proceeding involving an investment-related
business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury,
forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses.
Item 10 – Other Financial Industry Activities and Affiliations
We are not registered, and do not have an application pending to register, as a broker-dealer, a
futures commission merchant, commodity pool operator, or a commodity trading advisor. No
members of our management or associated persons are registered or have applications
pending to register as a registered representative or associated person of the foregoing entities.
Non-advisory services are available to our clients through the Platform, including tax services
from our affiliate MYRA Tax LLC and access to other products and services from non-affiliated
providers. If clients choose to engage in these non-advisory services, our affiliates may receive
economic benefit.
Item 11 – Code of Ethics, Client Transactions, Personal Trading
We have adopted a Code of Ethics that establishes policies for ethical conduct for all personnel.
We require our personnel to comply with all applicable laws and regulations and to act in an
ethical and professionally responsible manner in all professional services and activities. Our
Code of Ethics includes prohibitions against insider trading, circulation of industry rumors, and
certain political contributions, among others. We periodically review our Code of Ethics and
update it as necessary to ensure it remains current. A copy of our Code of Ethics is available
upon request.
We do not buy securities from or sell securities to clients from our own accounts, except for
when executing block trades. We do not have any proprietary investments that we recommend
to our clients. We do not act as an investment adviser to any investment company that we
recommend to our clients.
Our firm and our associated persons may buy or sell securities the same as, similar to, or
different from, those we recommend to clients for the client's account. A recommendation made
to one client may be different in nature or in timing from a recommendation made to another
client. Clients often have different objectives and risk tolerances. At no time, however, will we or
any of our related persons receive preferential treatment over our clients.
In an effort to reduce or eliminate certain conflicts of interest for us or our associated persons,
our policy may require that we restrict or prohibit associated persons’ transactions in specific
securities transactions. Any exceptions or trading pre‐clearance must be approved by our Chief
Compliance Officer in advance of the transaction in an account, and we maintain the required
personal securities transaction records per regulation.
Item 12 – Brokerage Practices
For PLAN and CONSULT services we provide non-discretionary advice, clients are responsible
for implementing our recommendations, including the selection of custodian or broker-dealer.
We do not recommend custodians or broker-dealers. Furthermore, the Firm does not participate
in any formal soft-dollar arrangements but we do receive certain benefits from a broker-dealer
as described below.
For INVEST: We have established a relationship with Charles Schwab & Co., Inc. ("Schwab").
Schwab Advisor Services™ provides custody, trading, and the support services of Schwab,
member SIPC, to independent investment advisors (e.g. MYRA Wealth) and Charles Schwab
Investment Management, Inc. ("CSIM"). Independent investment advisors (including MYRA
Wealth) are not owned by, affiliated with or supervised by Schwab.
Client's assets must be maintained in an account with Schwab as the qualified custodian,
except for 529 plans which are maintained at state-specific 529 Plan providers or at my529.org
(Utah Educational Savings Plan®). For accounts opened through our Platform, and held at
Schwab, we provide discretionary advice.
We participate in the institutional adviser program offered by Schwab. There is no direct link
between our participation in the institutional customer service program and the investment
advice we give to our clients, although we receive economic benefits that are typically not
available to retail investors. These benefits are available to all investment advisers who
participate in the program, and include the following products and services (provided without
cost or at a discount): receipt of duplicate client statements and confirmations; research related
products and tools; consulting services; access to a trading desk; access to block trading (which
provides the ability to aggregate securities transactions for execution and then allocate the
appropriate shares to client accounts); the ability to have advisory fees deducted directly from
client accounts; access to an electronic communications network for client order entry and
account information; access to ETFs with no transaction fees; access to certain institutional
money managers; discounts on compliance, marketing, research, technology, practice
management products or services provided to us by third party managers.
Schwab may have also paid for business consulting and professional services received by us or
our associated persons. Some of the products or services made available by Schwab through
the institutional customer program may benefit us but may not benefit our client accounts. Other
services made available by Schwab are intended to help us manage and further develop our
business enterprise. The benefits received by us or associated persons through participation in
the institutional customer program do not depend on the amount of brokerage transactions
directed to Schwab. As part of our fiduciary duty to clients, we endeavor at all times to put the
interests of our clients first. Clients should be aware, however, that the receipt of economic
benefits by us or our associated persons in and of itself creates a potential conflict of interest
and may indirectly influence our choice of Schwab for custody and brokerage services.
We participate in an adviser program with my529.org (Utah Educational Savings Plan®) that
provides us with economic benefits. These benefits are available to all investment advisers who
participate in the program, and include the following products and services (provided without
cost or at a discount): receipt of duplicate client statements and confirmations; research related
products and tools; access to a trading desk; and access to an electronic communications
network for client order entry and account information.
Research and Other Soft Dollar Benefits
We do not participate in any formal soft dollar arrangements. The research products and
services that our firm might receive from Schwab (or other custodians or brokerage firms) may
include financial publications, information about particular companies and industries, and other
products or services that provide lawful and appropriate assistance to us in the performance of
our investment decision-making responsibilities. Such research products and services are
provided to all investment advisers who use Schwab, and not the result of a formal soft-dollar
arrangement even though they might be considered a soft dollar benefit to us and create a
conflict of interest as noted in the prior section. However, the commissions charged by a
particular broker for a particular transaction, or set of transactions, might be greater than the
amounts another broker who did not provide research services or products might charge. We do
not receive any referrals from a broker-dealer or third party in exchange for using that
broker-dealer or third party.
Aggregating (Block) Trading for Multiple Client Accounts
We place aggregated orders involving multiple client accounts trading in the same securities.
Each client that participates in an aggregated transaction will participate at the average share
price for transactions in the aggregated order.
Item 13 - Review of Accounts
PLAN: Clients may access information about the client's plan at any time through the Platform.
We do not provide any ongoing monitoring of the client's plan, and we do not provide periodic
statements or reports.
CONSULT: We do not provide any ongoing monitoring, and we do not provide periodic
statements or reports.
INVEST: Client's Account is periodically rebalanced using software-based model or application
to ensure portfolio is in alignment with client's investment objectives and risk tolerance.
Additionally, any reasonable restrictions clients impose will be reviewed to confirm they are
being followed. Events that may trigger a special review would be unusual performance,
addition or deletions of client-imposed restrictions, market volatility, changes in investment
strategies, or withdrawals from or deposits into the account. Clients receive trade confirmations
directly from the custodian for each transaction in their accounts as well as monthly account
statements and annual tax reporting statements from their custodian showing all activity in the
accounts. We encourage clients to review these statements carefully. Information regarding the
client's account may be available through the Platform.
Item 14 - Client Referrals and Other Compensation
Client Referrals: We do not directly (or indirectly) compensate any person (or entity) for client
referrals.
Other Compensation: As noted above, we receive economic benefits from Schwab in the form
of support products and services that Schwab makes available to us and other independent
advisers whose clients maintain accounts at Schwab. The availability of Schwab’s products and
services to us is based solely on our participation in the program and not on the provision of any
particular investment advice.
Item 15 – Custody
Except for the ability to deduct our fee from the client's investment account (which is deemed to
be a form of custody), we do not accept custody of the client's assets or funds. Clients should
receive monthly statements from the client's account custodian that shows disbursements from
the client's account, including our fee.
Item 16 – Investment Discretion
PLAN services are available on a non-discretionary basis. This means that clients are solely
responsible for deciding whether to accept or reject our recommendations, and clients are
responsible for implementing our recommendations as clients deem appropriate.
CONSULT services are available on a non-discretionary basis. This means that clients are
solely responsible for deciding whether to accept or reject our recommendations, and clients are
responsible for implementing our recommendations as clients deem appropriate.
INVEST services for accounts opened through our Platform, and held at Schwab, we provide
discretionary advice. This means that we have the authority to implement investment strategies
and transactions to meet stated objectives without requiring client's prior authorization. Clients
grant us this authority when clients accept our advisory agreement, as well as the custodian’s
account agreement. Clients retain the right to terminate our account discretion; however, this will
terminate our advisory agreement as well.
Clients may impose reasonable restrictions upon investments to be held in the client's portfolio.
We reserve the right to reject requests for restrictions that are inconsistent with our stated
investment strategy or methodology or that are inconsistent with the nature or operation of our
INVEST services. As a result, some requests for restrictions may not be considered reasonable
and therefore would not be accepted. Such restrictions could result in a strategy that differs from
our portfolio recommendation and may not meet client's financial goals, investment objectives,
time horizon, risk tolerance, and other metrics.
Item 17 – Voting Client Securities
For the convenience of the Client, by default, we receive proxies. Client hereby authorizes
Custodian to forward proxy soliciting materials, annual reports, and other related issuer
materials, normally sent to Client, to us and to allow us to vote Proxies on the Client’s behalf.
We are not required to vote any proxies or respond to any corporate actions or elective actions
with respect to securities held in the Client’s Account. In addition, we will not offer guidance
involving any claim in any bankruptcy or class action settlement, or other corporation actions
that involve the securities held in the client's account.
Item 18 – Financial Information
We do not require prepayment of fees six months or more in advance. Therefore, we are not
required to provide a balance sheet for our most recent fiscal year end. Furthermore, we do not
have any financial condition that is reasonably likely to impair our ability to meet our contractual
requirements to our clients. Finally, we have not been the subject of a bankruptcy petition.
MYRA Advisors LLC
+1 (805) 380-6972
Form ADV Part 2B – Brochure Supplement
Dated: October 1, 2026
For
Sahil Vakil - Individual CRD# 6122494
Chief Compliance Officer
This brochure provides information about Sahil Vakil that supplements the MYRA Advisors
LLC brochure. A copy of that brochure precedes this supplement. Please contact Sahil Vakil
if the brochure is not included with this supplement or if you have any questions about the
contents of this supplement. Additional info about Sahil Vakil is available on SEC’s website at
www.adviserinfo.sec.gov which can be found using the identification number 6122494.
Item 2: Educational Background and Business Experience
Sahil Vakil
Educational Background
• 2016 - MBA, The Wharton School, University of Pennsylvania
• 2008 - Master of Science (MS), University of Southern California
• 2006 - Bachelor of Engineering (BEng), University of Mumbai
Business Experience
• 01/2021 – Present, MYRA Advisors LLC, CCO
• 09/2022 – 12/2023, New York University (NYU), Adjunct Professor
• 05/2018 – 10/2023, MYRA Capital LLC, President and CCO
• 06/2016 – 04/2018, BNP Paribas, Vice President
• 04/2016 – 06/2016, Amazon, Manager
• 06/2011 – 03/2016, Deloitte Consulting, Consultant
• 04/2011 – 06/2011, PwC, Consultant
• 02/2008 – 04/2011, Ernst & Young, Consultant
Professional Designations, Licensing & Exams
Chartered Financial Analyst (CFA): The CFA Program is a graduate-level self-study program
that combines a broad-based curriculum of investment principles with professional conduct
requirements. It is designed to prepare charter holders for a wide range of investment
specialties that apply in every market all over the world. To earn a CFA charter, applicants study
for three exams (Levels I, II, III) using an assigned curriculum. Upon passing all three exams
and meeting the professional and ethical requirements, a charter is awarded.
CFP (Certified Financial Planner)®: The CERTIFIED FINANCIAL PLANNER®, CFP® and
federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are
professional certification marks granted in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires
financial planners to hold CFP® certification. It is recognized in the United States and a number
of other countries for its (1) high standard of professional education; (2) stringent code of
conduct and standards of practice; and (3) ethical requirements that govern professional
engagements with clients. To attain the right to use the CFP® marks, an individual must
satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial
planning subject areas that CFP Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services, and attain a
Bachelor’s Degree from a regionally accredited United States college or university (or its
equivalent from a foreign university). CFP Board’s financial planning subject areas
include insurance planning and risk management, employee benefits planning,
investment planning, income tax planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination
includes case studies and client scenarios designed to test one’s ability to correctly
diagnose financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
● Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct,
a set of documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every
two years, including two hours on the Code of Ethics and Standards of Conduct,
to maintain competence and keep up with developments in the financial planning
field; and
● Ethics – Renew an agreement to be bound by the Code of Ethics and Standards of
Conduct. The Standards prominently require that CFP® professionals provide financial
planning services at a fiduciary standard of care. This means CFP® professionals must
provide financial planning services in the best interests of their clients. CFP® professionals
who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of
their CFP® certification.
Item 3: Disciplinary Information
Sahil Vakil nas never been involved in an arbitration claim of any kind or been found liable in a
civil, self-regulatory organization, or administrative proceeding.
Item 4: Other Business Activities
Sahil Vakil does not have any operational other business activities at this time.
Item 5: Additional Compensation
Sahil Vakil, as Chief Compliance Officer of MYRA Advisors LLC, receives compensation from
MYRA Inc, the parent entity that wholly owns MYRA Advisors LLC.
Item 6: Supervision
Sahil Vakil, as Chief Compliance Officer of MYRA Advisors LLC, is responsible for supervision.