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ITEM 1: COVER PAGE – BROCHURE – FORM ADV 2A
BURKE WEALTH MANAGEMENT, LLC
3355 W Alabama St Suite 910
Houston, TX 77098
Phone: 713-933-5402
www.burkewealthmanagement.com
April 22, 2026
This brochure provides information about the qualifications and business practices of Burke Wealth
Management, LLC. If you have any questions about the contents of this brochure, please contact us at 713-
933-5402 or kburke@burkewealthmanagement.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. Registration as an investment adviser does not imply a certain level of skill or training.
Additional information about Burke Wealth Management, LLC (CRD #: 305840). also is available on the SEC’s
website at www.adviserinfo.sec.gov.
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ITEM 2: MATERIAL CHANGES
Please note the following material changes to this Brochure since our last annual update filed on January 21,
2026:
• Burke Wealth Management, LLC has expanded its service offering to include acting as a sub-
advisor to an exchange-traded fund (“ETF”) and has amended various sections to describe
these services
• Burke Wealth Management, LLC has amended this Brochure to align with the instructions for
registration with the U.S. Securities and Exchange Commission (“SEC”).
The BWM Tactical Growth LP was terminated and liquidated on March 31, 2026.
•
ITEM 3: TABLE OF CONTENTS
ITEM 1: COVER PAGE – BROCHURE – FORM ADV 2A ............................................................................................................................. 1
ITEM 2: MATERIAL CHANGES ................................................................................................................................................................... 2
ITEM 3: TABLE OF CONTENTS .................................................................................................................................................................. 2
ITEM 4: ADVISORY BUSINESS................................................................................................................................................................... 4
BUSINESS AND OWNER .................................................................................................................................................................... 4
ADVISORY SERVICES OFFERED .......................................................................................................................................................... 4
CLIENT NEEDS AND RESTRICTIONS .................................................................................................................................................... 5
WRAP FEE PROGRAMS ..................................................................................................................................................................... 5
ASSETS UNDER MANAGEMENT .......................................................................................................................................................... 5
ITEM 5: FEES AND COMPENSATION......................................................................................................................................................... 5
FEE DESCRIPTION AND SCHEDULE ..................................................................................................................................................... 5
FEE DEDUCTION .............................................................................................................................................................................. 6
THIRD PARTY FEES AND EXPENSES .................................................................................................................................................... 6
ADVANCE PAYMENT OF FEES AND TERMINATION .................................................................................................................................. 6
COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTS ..................................................................................... 7
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................................................................ 7
ITEM 7: TYPES OF CLIENTS ...................................................................................................................................................................... 7
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................................................... 7
ANALYSIS AND INVESTMENT STRATEGY ............................................................................................................................................... 7
RISKS BASED ON ANALYSIS, STRATEGY, OR SECURITY TYPE .................................................................................................................. 8
ITEM 9: DISCIPLINARY INFORMATION................................................................................................................................................... 10
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS.............................................................................................. 10
RELATIONSHIP WITH A FIRM REGULATED BY FINRA ........................................................................................................................... 10
RELATIONSHIP WITH A FIRM REGULATED BY THE CFTC ....................................................................................................................... 10
OTHER RELATIONSHIP – CONFLICTS OF INTEREST ............................................................................................................................. 10
REFERRAL FEES FROM OTHER INVESTMENT ADVISERS ...................................................................................................................... 10
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ......................... 11
CODE OF ETHICS .......................................................................................................................................................................... 11
MATERIAL FINANCIAL INTEREST IN SECURITIES ................................................................................................................................. 11
SAME SECURITIES......................................................................................................................................................................... 11
CONCURRENT SECURITIES TRANSACTIONS ........................................................................................................................................ 11
ITEM 12: BROKERAGE PRACTICES ....................................................................................................................................................... 11
SELECTING AND RECOMMENDING BROKER-DEALERS ........................................................................................................................ 11
1. Research and Soft Dollar Benefits .............................................................................................................................. 12
2. Brokerage for Client Referrals ..................................................................................................................................... 12
3. Directed Brokerage ....................................................................................................................................................... 12
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AGGREGATING ORDERS ................................................................................................................................................................. 12
ITEM 13: REVIEW OF ACCOUNTS .......................................................................................................................................................... 13
PERIODIC ACCOUNT REVIEW ........................................................................................................................................................... 13
NON-PERIODIC ACCOUNT REVIEW ................................................................................................................................................... 13
REPORTING .................................................................................................................................................................................. 13
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION .............................................................................................................. 13
ECONOMIC BENEFIT ...................................................................................................................................................................... 13
REFERRALS ................................................................................................................................................................................. 13
ITEM 15: CUSTODY ................................................................................................................................................................................ 13
ITEM 16: INVESTMENT DISCRETION ..................................................................................................................................................... 14
ITEM 17: VOTING CLIENT SECURITIES .................................................................................................................................................. 14
ITEM 18: FINANCIAL INFORMATION ...................................................................................................................................................... 14
ITEM 1: COVER PAGE – BROCHURE SUPPLEMENT – FORM ADV 2B.................................................................................................. 15
ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ................................................................................................. 16
ITEM 3: DISCIPLINARY INFORMATION................................................................................................................................................... 16
ITEM 4: OTHER BUSINESS ACTIVITIES .................................................................................................................................................. 16
ITEM 5: ADDITIONAL COMPENSATION .................................................................................................................................................. 16
ITEM 6: SUPERVISION ............................................................................................................................................................................ 16
ITEM 1: COVER PAGE – BROCHURE SUPPLEMENT – FORM ADV 2B.................................................................................................. 17
ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ................................................................................................. 18
ITEM 3: DISCIPLINARY INFORMATION................................................................................................................................................... 18
ITEM 4: OTHER BUSINESS ACTIVITIES .................................................................................................................................................. 18
ITEM 5: ADDITIONAL COMPENSATION .................................................................................................................................................. 18
ITEM 6: SUPERVISION ............................................................................................................................................................................ 18
ITEM 1: COVER PAGE – BROCHURE SUPPLEMENT – FORM ADV 2B.................................................................................................. 19
ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ................................................................................................. 20
ITEM 3: DISCIPLINARY INFORMATION................................................................................................................................................... 20
ITEM 4: OTHER BUSINESS ACTIVITIES .................................................................................................................................................. 20
ITEM 5: ADDITIONAL COMPENSATION .................................................................................................................................................. 20
ITEM 6: SUPERVISION ............................................................................................................................................................................ 20
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ITEM 4: ADVISORY BUSINESS
BUSINESS AND OWNER
Burke Wealth Management, LLC (referred to as “BWM,” “we,” “us,” “our,” “firm” or “adviser”) is a Texas limited
liability company that was formed in August 2019 with its principal place of business in Houston, Texas. It
commenced operation as an investment adviser in October 2019. Kenneth Michael Burke Jr. is the sole
member of the firm.
ADVISORY SERVICES OFFERED
Burke Wealth Management, LLC provides portfolio management solutions to its clients through a variety of
offerings. Services are primarily offered on a discretionary basis. Please see Item 16 – Investment Discretion.
Separately Managed Accounts. BWM collaborates closely with each client to identify their goals, investment
liquidity needs, and financial situation. Generally, discretionary portfolio
objectives, risk tolerance,
management starts with the Focused Growth Strategy for a client’s equity exposure. The strategy owns high
quality companies in attractive industries that possess long-term growth opportunities greater than that of the
broader market. For clients with a shorter time horizon, the Balanced Growth strategy may be appropriate.
The Balanced Growth portfolio structure consists of our Focused Growth equity holdings alongside a diversified
portfolio of high-quality corporate bonds. The portfolio has a long term target weighting of 60/40 equity to
fixed income with the ability to adjust weightings in each asset class between 30% - 70% depending on market
conditions. For clients needing a balanced portfolio or a fixed income allocation, our fundamental equity
research can be leveraged to identify attractive high-quality corporate bonds.
Sub-Advisory Services.
Separately Managed Accounts. Our portfolio management services are offered to unaffiliated registered
investment advisers on a sub-advisory basis through separately managed accounts.
Exchange-Traded Fund. BWM acts as a discretionary sub-adviser to the BWM Quality Growth ETF (BWQG)
an actively-managed exchange-traded fund (“ETF”) that is an investment companies registered under
the Investment Company Act of 1940, as amended. BWM provides its investment advisory services in a
sub- advisory capacity to Empowered Funds, LLC dba EA Advisers, the primary adviser to the ETFs. The ETF
is a series of EA Series Trust (the “Trust”) and is subject to the general supervision of the Board of Trustees
of the Trust. The ETF is managed using the Focused Growth strategy described above in the Separately
Managed Account section, in accordance with the guidelines and restrictions set forth in the ETF’s
Prospectus and Statement of Additional Information and all respective regulatory guidelines or limitations.
Please refer to Item 8 for information specific to the investment strategies for the ETF.
Alpha Capture Program. BWM participates in an alpha capture program by submitting numerical ratings on
a regular basis for a predefined universe of holdings. The ratings generally align with our broader research
efforts. Ratings do not constitute market orders. We are one of many contributors to the program and are
unaware of how our submissions are ultimately utilized.
Non-Discretionary Accounts. Upon request from a client, BWM may assist in opening and administering non-
discretionary accounts. These accounts are provided as an accommodation for our clients. When we are
hired to provide non-discretionary services, BWM will make recommendations but the ultimate decision to buy
or sell a security will be made by the client.
Model Marketplaces. The Firm provides non-discretionary model portfolio recommendations to third-party
investment platforms and financial advisors utilizing the platforms (each, a "Model Marketplace"). Under these
arrangements, the Firm delivers a model portfolios to the Model Marketplace on a periodic basis. The Model
Marketplace retains full investment discretion over client accounts, including whether, when, and how to
implement the Firm's model portfolio recommendations. The Firm does not have an advisory relationship with,
discretion over, or trading authority for the underlying client accounts that invest pursuant to the Firm's models,
and the Firm does not consider the individual circumstances of those underlying clients.
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CLIENT NEEDS AND RESTRICTIONS
Separately Managed Accounts, Sub-Advisory Services and Non-Discretionary Accounts. Our investment
advice is tailored to each client, as described above. BWM allows clients to impose reasonable restrictions on
the management of the account. Reasonable restrictions, including special instructions and limitations,
regarding the investment management of the account must be provided in writing and must be specific.
Clients are responsible for notifying us of any updates regarding their financial situation, investment objectives,
or risk tolerance and whether they wish to impose or modify any existing investment restrictions.
WRAP FEE PROGRAMS
BWM does not participate in any wrap fee programs.
ASSETS UNDER MANAGEMENT
As of December 31, 2025, the firm managed $86,312,463 assets under management on a discretionary basis
and $8,927,979 on a non-discretionary basis.
ITEM 5: FEES AND COMPENSATION
FEE DESCRIPTION AND SCHEDULE
Separately Managed Accounts. Investment management fees are agreed upon in writing prior to an
engagement. Fees are billed quarterly in arrears. The fee will be equal to the agreed upon rate per annum
(as set-forth in the investment advisory agreement with each client), multiplied by the average daily market
value of the assets in the account(s) during the prior quarter. The market value of the assets is provided by the
account(s)’ custodian. The market value will not be adjusted by any margin debit.
Investment management fees may be negotiated and will vary due to certain factors, including but not
limited to the number, type, and size of the account(s); the range and frequency of additional services
provided to the client and account(s); the value of the assets under management for the client relationship;
and/or as otherwise agreed with specific clients.
Tiered Fee Schedule:
Assets under Management
$0 - $5,000,000
$5,000,000.01 - $10,000,000
$10,000,000.01 and higher
Annual Fee
1.00%
0.75%
0.50%
Please note, BWM may, in its sole and absolute discretion, waive or reduce the asset management fees for
employees, family members, and affiliates of BWM. As a result, BWM may offer certain clients lower fees than
other clients.
Sub-Advisory Services.
Separately Managed Accounts. The fee schedule for sub-advisory services through separately managed
accounts is agreed upon by the unaffiliated registered investment adviser and BWM. These agreements
will state the manner and amount that BWM will be compensated and is, generally, based upon the value
of the assets being managed by BWM.
Exchange-Traded Fund. BWM receives a management fee paid monthly in arrears calculated as a
percentage of assets under management for investment advisory services provided to the ETF. The ETF’s
management fee schedule is contained in the Prospectus and Statement of Additional Information. A
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copy of the ETF’s offering document may be obtained on the website, www.bwmqualitygrowth.com, or
upon request at ir@bwmqualitygrowth.com.
Non-Discretionary Accounts. These accounts are provided as an accommodation for our clients, and in the
sole and absolute discretion of BWM, are not charged a fee.
Model Marketplaces. For model portfolio delivery arrangements described in Item 4, the Firm is compensated
by the Model Marketplace at a negotiated rate, typically calculated as a percentage (in basis points) of the
assets managed by financial advisors and allocated to the Firm's model portfolio recommendations. Fees are
generally paid to the Firm by the Model Marketplace in arrears out of the fees the third party investment
platform or the financial advisor charges the underlying client; the Firm does not bill the underlying client
directly and does not receive any other compensation from the underlying client in connection with these
arrangements. Fee rates are individually negotiated with each Model Marketplace and may vary based on
asset level, the specific strategy delivered, and other factors. The Firm's model delivery fees are generally lower
than the fees the Firm charges for discretionary separate account management, reflecting the more limited
scope of services.
FEE DEDUCTION
Separately Managed Accounts and Sub-Advisory Services. Each client is expected to authorize BWM to
instruct the custodian to deduct the firm’s fees from the client’s assets. In the manner directed by the
custodian, BWM will submit its fees for deduction from each client’s account(s). The fees deducted are
reported on the account statements provided by the custodian. Each client is responsible for verifying fee
computations since custodians are not typically asked to perform this task. If you have questions about a
specific fee calculation, please contact us.
THIRD PARTY FEES AND EXPENSES
Clients will also incur certain charges imposed by third parties (custodians, broker-dealers, platforms, and
others) regarding investments made in the account(s). These commissions, fees and charges may include but
are not limited to the following: brokerage commissions; transaction, exchange, trade away and clearing
fees; account, wire, and electronic fund transfer fees; margin interest; custodial fees; administration and
termination fees; and other costs and expenses.
BWM may also invest client assets in mutual funds and traded funds. Clients bear the costs and expenses
charged by these fund(s) to their shareholders, such as management and administrative fees, in addition to
BWM’s advisory fees. These costs and expenses are set forth in the prospectuses for these investment funds.
These investment funds will be included in calculating the value of the account(s) for purposes of computing
BWM’s fees.
Sub-Advisory Services - Exchange-Traded Fund. Investors in the ETF pay expenses in addition to investment
management fees that generally include administration, organizational, research and investment expenses,
such as legal, director, accounting, audit and other professional fees and expenses. These expenses are
typically incorporated in the ETF’s share price or are allocated based on an investor’s pro-rata portion of the
investment vehicle. For additional details regarding these fees and expenses, please refer to the ETF’s the
Prospectus and Statement of Additional Information. For additional information regarding BWM’s brokerage
practices, please refer to Item 12 of this Brochure.
ADVANCE PAYMENT OF FEES AND TERMINATION
Separately Managed Accounts. Fees are billed in arrears. Fees will be calculated based on the number of
days the assets were in the account during the quarter.
If the investment advisory agreement is terminated, a pro rata portion of the Management Fee, based on the
number of days the assets were in the Account during the quarter, shall be due immediately to Adviser.
However, if the client terminates the engagement within five business days of signing the Client Agreement,
the client is entitled to a waiver of any pro-rated fees due to Adviser.
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Sub-Advisory Services. The fees for sub-advisory services through separately managed accounts are agreed
upon by the unaffiliated registered investment adviser and BWM. These agreements will state the manner and
amount that BWM will be compensated and is, generally, based upon the value of the assets being managed
by BWM.
COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTS
BWM and its officers, directors and employees do not receive compensation for the sale of securities or other
investment products.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
BWM does not charge performance fees.
ITEM 7: TYPES OF CLIENTS
Separately Managed Accounts. We offer investment management services to individuals and high net worth
clients, their trusts and estates, pension and profit-sharing plans, charitable organizations, other investment
advisers, corporations, and other types of entities.
A minimum account of $1,000,000 is required, although this is negotiable under certain circumstances. BWM
will group certain related client accounts for the purpose of achieving the minimum account size and fee
breakpoints.
Sub-Advisory Services. Additionally, our portfolio management services are offered to unaffiliated registered
investment advisers on a sub-advisory basis . These relationships are negotiated on a case-by-case basis.
Model Marketplaces. The Firm provides non-discretionary model portfolio recommendations to third-party
investment platforms and financial advisors utilizing the platforms.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
ANALYSIS AND INVESTMENT STRATEGY
Separately Managed Accounts. The Focused Growth strategy (U.S. Traded Equities, Long-Only) is designed to
be the core portion of a client’s equity exposure. Within the Focused Growth portfolio, we purchase high
quality companies in attractive industries that possess long-term growth opportunities greater than that of the
broader market. We want to own these businesses as long as these advantages persist, and long-term return
projections remain attractive. Each investment is made with a 3-5 year time horizon in mind so that the
favorable growth attributes of our portfolio companies are allowed to compound in a tax efficient manner. As
a general rule, the Focused Growth strategy seeks to invest in companies that are disrupting existing and
sometimes sluggish business models, businesses with network characteristics that are very difficult if not
impossible to replicate, and businesses with predictable and recurring revenue streams.
Stock selection and weightings are based on our internal estimates of risk-adjusted 3-year total return
projections. Our 3-5 year holding period allows us to look beyond day-to-day market noise and focus on the
long-term growth prospects of a company.
The Focused Growth strategy provides clients with diversified equity exposure across numerous geographies
and multiple sectors of the economy. The portfolio companies tend to be large-to-mega cap in size and
would generally be classified as growth rather than value. We view risk more in terms of permanent impairment
of capital and as such, the businesses we invest in tend to have strong balance sheets and typically generate
substantial free cash flow.
The Balanced Growth portfolio structure consists of our Focused Growth equity holdings alongside a diversified
portfolio of high-quality corporate bonds. The portfolio has a long term target weighting of 60/40 equity to
fixed income with the ability to adjust weightings in each asset class between 30% - 70% depending on market
conditions. Utilizing the same extensive research process that underpins our Focused Growth portfolio, fixed
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income holdings are sourced from the bond issuance of our existing Focused Growth portfolio as well as
companies on our watch-list. The duration of the fixed income portfolio will generally be 2-10 years.
Sub-Advisory Services.
Separately Managed Accounts. Our portfolio management services are offered to unaffiliated registered
investment advisers on a sub-advisory basis through separately managed accounts. These services will
be offered in accordance with an agreement with the primary investment adviser.
Exchange-Traded Fund. BWM acts as a discretionary sub-adviser to the BWM Quality Growth ETF (BWQG)
an actively-managed exchange-traded fund (“ETF”). The ETF is managed using the Focused Growth
strategy described above in the Separately Managed Account section, in accordance with the
guidelines and restrictions set forth in the ETF’s Prospectus and Statement of Additional Information and
all respective regulatory guidelines or limitations.
RISKS BASED ON ANALYSIS, STRATEGY, OR SECURITY TYPE
Some of the risks associated with BWM’s investment strategies, the securities and other assets utilized to
implement those strategies, include, but are not limited to, those listed below.
Investing in securities involves risk of loss that clients should be prepared to bear. BWM does not guarantee
the future performance of an account or any specific level of performance, the success of any investment
decision or strategy that BWM may use, or the success of BWM’s overall management. Clients understand that
investment decisions made for the client’s account by BWM are subject to various market, currency,
economic, political, and business risks, and that those investment decisions will not always be profitable.
Equities Risk. The value of a client’s account may be affected by changes in equity positions. Equities (and
stock markets generally) may experience significant short-term volatility and may fall or rise sharply at times.
Adverse events in any part of the equity or fixed-income markets may have unexpected negative effects on
other market segments. Different stock markets may behave differently from each other and U.S. stock
markets may move in the opposite direction from one or more foreign stock markets. The prices of individual
stocks generally do not all move in the same direction at the same time. However, individual stock prices tend
to go up and down more dramatically than those of certain other types of investments, such as bonds. A
variety of factors can negatively affect the price of a particular company’s stock. These factors may include,
but are not limited to: poor earnings reports, a loss of customers, litigation against the company, general
unfavorable performance of the company’s sector or industry, or changes in government regulations
affecting the company or its industry.
Concentration Risk. To the extent a client account concentrates its investments by investing a significant
portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse
impact on the client of adverse developments in the business of such issuer, such industry or such government
could be considerably greater than if they did not concentrate their investments to such an extent.
Margin Trading & Leverage Risk. Margin trading allows exposure to a given quantity of an underlying asset for
a fraction of the investment needed to purchase that quantity outright. Using borrowed money to finance the
purchase of securities involves greater risk than a purchase using cash resources only. The responsibility to
repay the loan as required by its terms remains the same even if the value of the segregated fund declines.
Using leverage will lead to larger profits and losses than if purchasing the security outright using cash.
Credit Risk. A client could lose money if the issuer or guarantor of a fixed income security is unable or unwilling
to meet its financial obligations.
Interest Rate Risk. Fixed income securities will decline in value because of an increase in interest rates; a bond
or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond
or bond fund with a shorter duration.
Investment Company Risk. To the extent a client account invests in ETFs, mutual funds or other investment
companies, its performance will be affected by the performance of those investment companies. These
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investments are subject to the risks of the investment companies' investments and expenses. The client
account may receive distributions of taxable gains from portfolio transactions by the investment company
and may recognize taxable gains from transactions in shares of that investment company, which would be
taxable when distributed.
Issuer-Specific Risk. The value of an individual security or particular type of security can be more volatile than
the market as a whole and can perform differently from the value of the market as a whole.
Market Risk. The value of securities owned by a client may go up or down, sometimes rapidly or unpredictably,
due to factors affecting securities markets generally or particular industries.
Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub-sectors
of the market, its performance will be especially sensitive to developments that significantly affect those
sectors, industries, or subsectors. An individual sector, industry, or sub-sector of the market may be more
volatile, and may perform differently, than the broader market. The several industries that constitute a sector
may all react in the same way to economic, political or regulatory events. A client account's performance
could be affected if the sectors, industries, or sub-sectors do not perform as expected. Alternatively, the lack
of exposure to one or more sectors or industries may adversely affect performance.
Reliance on Key Person. BWM will be substantially dependent on the services of Kenneth M. Burke,
(“Principal”). In the event of the death, disability, departure or insolvency of the Principal, or the complete
transfer of the Principal’s interest in BWM, the business of BWM could be adversely affected. The Principal will
devote such time and effort as he deems necessary for the management and administration of BWM’s
business.
Cybersecurity and Technology Risks. We rely on technology systems, including systems maintained by BWM
and third-party service providers, to conduct our business and provide services to clients. As a result, we are
subject to operational and information security risks. Cybersecurity incidents may include unauthorized access
to systems or data, ransomware attacks, denial-of-service attacks, business email compromise, data
corruption, or other events that disrupt normal operations. These incidents may occur at our firm or at third
parties with whom we conduct business, including custodians, third-party investment advisers, counterparties,
financial institutions, exchanges, regulators, and other service providers. A cybersecurity incident could result
in:
Temporary or extended disruption of our operations
•
Inability to access client accounts or complete transactions
•
Loss, theft, corruption, or unauthorized disclosure of confidential information
•
Financial losses
•
• Regulatory investigations, fines, or penalties
• Reputational harm
Increased compliance or remediation costs
•
Although we maintain policies, procedures, and controls designed to reduce cybersecurity risk and to detect
and respond to incidents, these measures may not be effective in all circumstances. Cybersecurity threats are
continually evolving, and there can be no assurance that we or our service providers will not experience future
incidents that could materially affect our operations or clients.
Data Management and Information Security Risks. Our services depend on the accurate, timely, and
complete processing of data. This includes the collection, transmission, storage, and protection of personal
and financial information. Failures in data management processes may occur due to human error, system
limitations, technical failures, process weaknesses, or control deficiencies. Inaccurate, incomplete, delayed,
or compromised data could adversely affect our ability to provide services, satisfy regulatory obligations, or
maintain effective internal controls. Such failures could result in operational losses, regulatory exposure, or
reputational damage.
Risks Related to the Use of Artificial Intelligence and Advanced Technologies. We use tools and systems that
incorporate artificial intelligence (AI), machine learning, predictive analytics, or other data science
technologies. Some of these tools may be developed or maintained by third parties.
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AI and similar technologies are complex and may produce inaccurate, incomplete, biased, or unreliable
outputs. These tools rely on underlying data and algorithms, which may contain errors or limitations. If the data
used by these systems is corrupted, incomplete, unavailable, or reformatted, the systems’ performance may
be adversely affected. We may have limited ability to independently verify the accuracy or completeness of
certain third-party AI tools.
The legal and regulatory framework governing the use of AI technologies is evolving and uncertain. Future
regulatory developments may require changes to our practices, increase compliance costs, or create
additional regulatory risk. In addition, the use of advanced technologies, including AI, may increase exposure
to cybersecurity risks. These technologies may be vulnerable to manipulation or attack and may also enable
more automated or targeted cyber threats.
Exchange Traded Funds’ (“ETFs”) Risks. ETFs are traded on stock exchanges or on the over-the-counter market.
An investment in an ETF generally presents the same primary risks as an investment in a conventional mutual
fund that has the same investment objectives, strategies, and policies. The price of an ETF can fluctuate up or
down, and a client account could lose money investing in an ETF if the prices of the securities owned by the
ETF go down. In addition, ETFs are subject to the following risks that do not apply to conventional mutual funds:
The market price of an ETFs shares may trade above or below their net asset value;
•
• An active trading market for an ETF’s shares may not develop or be maintained; or
•
Trading of ETFs shares may be halted if the listing exchange’s officials deem such action
appropriate, the shares are delisted from the exchange, or the activation of market-wide
“circuit breakers” (which are tied to large decreases in stock prices) halts stock trading
generally.
ITEM 9: DISCIPLINARY INFORMATION
Investment advisers are required to disclose all material facts regarding any legal or disciplinary events that are
material to a client’s evaluation of the adviser or the integrity of the adviser’s management. We have no
information to disclose.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
RELATIONSHIP WITH A FIRM REGULATED BY FINRA
BWM has no relationships to disclose.
RELATIONSHIP WITH A FIRM REGULATED BY THE CFTC
BWM has no relationships to disclose.
OTHER RELATIONSHIP – CONFLICTS OF INTEREST
BWM employees have personal investments in Focused Growth. While this operates to align, to some extent,
the interests of the employees with the firm’s investment strategies, it also creates a potential conflict of interest
to favor employees’ investments over clients or employees could have economic interests which compete
with their investments. To mitigate this conflict, all employees are bound by BWM’s Code of Ethics which is
discussed further in Item 11 below.
REFERRAL FEES FROM OTHER INVESTMENT ADVISERS
The firm does not receive referral fees.
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ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
CODE OF ETHICS
BWM’s Code of Ethics (“Code”) has been designed to comply with the requirements of Rule 204A-1 of the
Investment Advisers Act of 1940. Among other things, the Code (i) requires that all employees comply with
applicable federal and state securities laws, (ii) requires that access persons submit to BWM reports containing
their personal securities holdings and transactions in reportable securities, and that BWM review such reports,
(iii) requires access persons to obtain pre-approval of certain personal investments; and (iv) contains policies
and procedures designed to prevent the misuse of material, non-public information. All personnel of BWM
are required to certify their compliance with the Code of Ethics.
BWM will provide a copy of its Code of Ethics to a client or prospective client upon request.
MATERIAL FINANCIAL INTEREST IN SECURITIES
BWM has no material financial interest in securities.
SAME SECURITIES
Access persons are permitted to invest in their personal trading accounts, subject to certain restrictions, and
may invest in the same or in related securities as the clients of BWM, including doing so at or about the same
time as a BWM client transaction is entered.
BWM manages the conflicts of interest inherent in employee personal trading by enforcement of its Code of
Ethics, which contains pre-clearance and reporting guidelines. Specifically, BWM’s Code requires access
persons of BWM to obtain prior written approval from BWM’s Chief Compliance Officer before engaging in
certain transactions in their personal accounts. The Chief Compliance Officer may only approve the
transaction if he concludes that the transaction would comply with the provisions of the Code and is not likely
to have any adverse economic impact on clients.
The Chief Compliance Officer reviews each access person’s personal transaction reports to make sure each
access person is conducting his or her personal securities transactions in a manner that is consistent with the
Code.
CONCURRENT SECURITIES TRANSACTIONS
Please refer to Items 11.A, 11.B, and 11.C.
ITEM 12: BROKERAGE PRACTICES
SELECTING AND RECOMMENDING BROKER-DEALERS
We recommend that our clients use third party registered broker-dealers, members FINRA/SIPC, as qualified
custodians (“custodians”). BWM is independently owned and operated and is not affiliated with our
custodians. The custodians will hold client assets in a brokerage account. While we recommend that you use
certain firms as your custodian, you will decide whether to do so and will open your account with them by
entering into an account agreement directly with them. We do not open the account for you, although we
may assist you in doing so.
Generally, we will execute transactions through your custodian. However, in accordance with our duty of best
execution, we may use other brokers to execute trades for your account as described below.
We seek to recommend custodians/brokers that will hold your assets and execute transactions on terms that
are, overall, most advantageous when compared with other available providers and their services. We
consider a wide range of factors.
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For our clients’ accounts that the custodians maintain, the custodians are compensated by charging
commissions or other fees on trades that they execute or that settle into your custodial account.
In addition to commissions, the custodians may charge a flat dollar amount as a “prime broker” or “trade
away” fee for each trade that is executed by a different broker-dealer but where the securities bought or the
funds from the securities sold are deposited (settled) into your custodial account. These fees are in addition to
the commissions or other compensation you pay the executing broker-dealer.
1. RESEARCH AND SOFT DOLLAR BENEFITS
The term “soft dollars” refers generally to the practice by investment advisers of paying for research and
brokerage services using brokerage commissions generated by the execution of trades for their clients’
accounts. BWM has no formal soft dollar relationships with the custodians/brokers that we recommend.
However, we do receive research and other products or services from the custodians/brokers that we
recommend. Our custodians/brokers provide us with access to their institutional trading and custody
services, which are typically not available to retail investors. These services generally are available to
independent investment advisors at no charge to them so long as the independent investment advisors
maintain a minimum amount of assets with the custodian.
Services that we may receive include, but are not necessarily limited to: receipt of duplicate client
confirmations and bundled duplicate statements; access to a trading desk; access to block trading which
provides the ability to aggregate securities transactions and allocate the appropriate shares to client
accounts; the ability to have investment advisory fees deducted directly from client accounts; access to
an electronic communications network for client order entry and account information; and access to
mutual funds that generally require significantly higher minimum initial investments or are generally only
available to institutional investors.
Our custodians/brokers also make available to us other products and services that benefit our firm but
may not benefit clients' accounts. Some of these other products and services assist us in managing and
administering clients' accounts. These include software and other technology that provide access to
client account data (such as trade confirmation and account statements); provide research, pricing
information and other market data; facilitate payment of the firm’s fees from its clients' accounts; and
assist with back office functions; record keeping and client reporting. Many of these services generally
may be used to service all or a substantial number of our accounts, including accounts not maintained
at a recommended custodian. We also receive other services intended to help our firm manage and
further develop our business enterprise. These services may include consulting, publications and
conferences on practice management, information technology, business succession, regulatory
compliance, and marketing.
Our recommendation that you maintain your assets in accounts at our custodians/brokers may be based
in part on the benefit to us in the availability of some of the foregoing products and services and not solely
on the nature, cost or quality of custody and brokerage services provided. This creates a conflict of
interest.
2. BROKERAGE FOR CLIENT REFERRALS
BWM does not receive client referrals from broker-dealers.
3. DIRECTED BROKERAGE
BWM does not allow clients to direct execution of transactions through a specified broker dealer.
AGGREGATING ORDERS
To secure certain efficiencies and results with respect to execution, clearance, and settlement of orders, BWM
in its sole discretion may elect to combine or “bunch” (also known as a block trade) an order entered for
clients with orders entered for the same security for other clients of BWM. The average execution price at
BURKE WEALTH MANAGEMENT, LLC | Form ADV 2A |
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which a security is bought or sold may be assigned for the clients involved in a transaction when a bunched
order is executed in parts at different prices, or when two or more separate orders for the same security are
entered at approximately the same time and are executed at different prices. If a bunched order is not
executed in its entirety a client may buy or sell less of a security than if the order was not bunched. Similarly,
when price averaging is used some clients will get a better price and some clients will get a worse price than
they would have received if price averaging was not used. BWM will act in a manner it believes is equitable
for its clients as a group when bunching and price averaging. The overarching principle is that no client is
intentionally favored over another client that is similarly situated.
ITEM 13: REVIEW OF ACCOUNTS
PERIODIC ACCOUNT REVIEW
Accounts are reviewed ongoingly by our chief investment officer and/or chief compliance officer to ensure
that the holdings continue to align with the strategies’ investment philosophy and to make sure that the
accounts are consistent with the client’s financial profile and investment objectives.
NON-PERIODIC ACCOUNT REVIEW
Non-periodic account reviews can be triggered or intensified by unexpected performance, shifting market
conditions, in-flows/out-flows, or changing client preferences or circumstances.
REPORTING
Separately Managed Accounts and Non-Discretionary Accounts. In addition to the statements provided by
the custodians, on a quarterly basis, BWM provides clients with reports about their accounts. We urge clients
to compare the custodian’s account statements to these reports from BWM.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
ECONOMIC BENEFIT
See – Item 12: Brokerage Practices.
REFERRALS
BWM is required to disclose any direct or indirect compensation that it provides for client referrals. In the event
a client is introduced to BWM by an unaffiliated promoter, BWM will pay that promoter a referral fee in
accordance with the requirements of Rule 206(4)-1 of the Advisers Act and any corresponding state securities
law requirements. Generally, the promoter is paid a portion of the management fee due to this relationship.
The client’s fees are not increased by this arrangement. When the client is introduced to BWM by an
unaffiliated promoter, the promoter will provide the client with a copy of BWM’s written disclosure brochure
which meets the requirements of Rule 204-1 of the Advisers Act and a disclosure containing the terms and
conditions of the arrangement including the promoter’s compensation.
ITEM 15: CUSTODY
Separately Managed Accounts We are deemed to have custody of a client’s cash and securities to the extent
that we have the authority to deduct advisory fees directly from clients’ accounts. We do not intend to have
physical possession of the cash or securities in client accounts at any time. In general, all cash and securities
owned by clients will be held by one or more qualified custodians that are selected by such clients pursuant to
separate custody or other agreements.
Clients will receive account statements directly from the account’s custodian at least quarterly, but more likely
monthly. Statements will be sent to the email or postal mailing address that the client provided to the custodian.
Clients should review those statements promptly upon receipt. We also urge clients to compare the custodian’s
account statements to the periodic reports received from BWM.
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ITEM 16: INVESTMENT DISCRETION
Discretionary. BWM manages accounts on a discretionary basis. When discretion is given in writing we will have
authority over the types of financial instruments to be bought or sold, as well as the amount to be bought or sold
on behalf of our clients (without consulting them about the transaction) (subject to any restrictions and limitations
set forth in writing in the account documents). We will also have the authority to determine the broker-dealer or
other counterparty to be used for transactions and the negotiation of commission rates and other consideration
to be paid by clients. Discretion is to be exercised in a manner consistent with client’s financial profile and
investment objectives for the account.
Non-Discretionary Accounts. Upon request from a client, BWM may assist in opening and administering non-
discretionary accounts. These accounts are provided as an accommodation for clients. When we are hired to
provide non-discretionary services, BWM will make recommendations but the ultimate decision to buy or sell a
security will be made by the client.
ITEM 17: VOTING CLIENT SECURITIES
Clients retain the right and responsibility for voting proxies for all securities maintained in client accounts. As a
matter of firm policy and practice, BWM does not accept authority to and does not vote proxies on behalf of
advisory clients. Clients will receive their proxies or other solicitations directly from their custodian. Clients may
contact BWM with questions about a solicitation.
Clients agree that BWM will not advise or act for them in any legal proceedings, including bankruptcies or class
actions, involving securities held or previously held by the client.
ITEM 18: FINANCIAL INFORMATION
BWM does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. BWM
is not currently aware of any financial condition that is reasonably likely to impair its ability to meet its contractual
commitments to clients.
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ITEM 1: COVER PAGE – BROCHURE SUPPLEMENT – FORM ADV 2B
BURKE WEALTH MANAGEMENT, LLC
3355 W Alabama St Suite 910
Houston, TX 77098
Phone: 713-933-5402
www.burkewealthmanagement.com
April 22, 2026
Kenneth Burke Jr
CRD# 2923762
The brochure supplement provides information about Kenneth Michael Burke Jr. that supplements the Burke
Wealth Management, LLC (CRD #: 305840) brochure. You should have received a copy of that brochure. Please
contact Charles Ward if you did not receive Burke Wealth Management, LLC’s brochure or if you have any
questions about the contents of this supplement.
Additional information about Kenneth Michael Burke Jr. is available on the SEC’s website at
www.adviserinfo.sec.gov.
BURKE WEALTH MANAGEMENT, LLC | Form ADV 2B |
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ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Kenneth Michael Burke Jr. born 1974
Education:
Master of Business Administration 2001
The University of Texas
McCombs School of Business
Vanderbilt University
1997
Bachelor of Arts in Mathematics
and Economics
Business Background:
Burke Wealth Management, LLC – Managing Member
2019-Present
2018-2019
Doliver Advisors, L.P. – Chief Investment Officer Focused
Growth Strategy
Sarofim Fayez & Co. – Associate/Principal/Vice President
2001-2018
ITEM 3: DISCIPLINARY INFORMATION
Mr. Burke has nothing to disclose regarding any legal or disciplinary events material to a client’s evaluation of her
integrity.
ITEM 4: OTHER BUSINESS ACTIVITIES
Mr. Burke has nothing to disclose regarding other business activities.
ITEM 5: ADDITIONAL COMPENSATION
Except as otherwise described in Item 12 of the brochure, Mr. Burke does not expect to receive any economic
benefit from any non-advisory client for providing investment advice or other advisory services to our clients.
ITEM 6: SUPERVISION
information
Mr. Burke is the managing member for BWM. His activities are supervised by the Chief Compliance Officer, Charles
is
in accordance with our policies and procedures. Mr. Ward’s contact
Keithley Ward,
cward@burkewealthmanagement.com and 713-385-1441.
BURKE WEALTH MANAGEMENT, LLC | Form ADV 2B |
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ITEM 1: COVER PAGE – BROCHURE SUPPLEMENT – FORM ADV 2B
BURKE WEALTH MANAGEMENT, LLC
3355 W Alabama St Suite 910
Houston, TX 77098
Phone: 713-385-1441
www.burkewealthmanagement.com
April 22, 2026
Charles Ward
CRD# 4632946
The brochure supplement provides information about Charles Ward that supplements the Burke Wealth
Management, LLC (CRD #: 305840) brochure. You should have received a copy of that brochure. Please contact
Charles Ward if you did not receive Burke Wealth Management, LLC’s brochure or if you have any questions about
the contents of this supplement.
Additional information about Charles Ward is available on the SEC’s website at
www.adviserinfo.sec.gov.
BURKE WEALTH MANAGEMENT, LLC | Form ADV 2B |
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ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Charles Keithley Ward born 1978
Education:
B.A. Economics
2002
The University of Texas at
Austin
Business Background:
Burke Wealth Management, LLC – CCO/COO
2019-Present
Doliver Advisors, LP – CCO/COO
2016-2020
ITEM 3: DISCIPLINARY INFORMATION
Mr. Ward has nothing to disclose regarding any legal or disciplinary events material to a client’s evaluation of her
integrity.
ITEM 4: OTHER BUSINESS ACTIVITIES
Mr. Ward has nothing to disclose regarding other business activities.
ITEM 5: ADDITIONAL COMPENSATION
Except as otherwise described in Item 12 of the brochure, Mr. Ward does not expect to receive any economic
benefit from any non-advisory client for providing investment advice or other advisory services to our clients.
ITEM 6: SUPERVISION
Mr. Ward is the Chief Compliance Officer and Chief Operating Officer for BWM. His activities are supervised by
Kenneth Burke Jr., the managing member, in accordance with our policies and procedures. Mr. Burke’s contact
information is kburke@burkewealthmanagement.com and 713-933-5402.
BURKE WEALTH MANAGEMENT, LLC | Form ADV 2B |
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ITEM 1: COVER PAGE – BROCHURE SUPPLEMENT – FORM ADV 2B
BURKE WEALTH MANAGEMENT, LLC
3355 W Alabama St Suite 910
Houston, TX 77098
Phone: 713-385-1441
www.burkewealthmanagement.com
April 22, 2026
Christopher Winters
CRD# 6611671
The brochure supplement provides information about Christopher Winters that supplements the Burke Wealth
Management, LLC (CRD #: 305840) brochure. You should have received a copy of that brochure. Please contact
Charles Ward if you did not receive Burke Wealth Management, LLC’s brochure or if you have any questions about
the contents of this supplement.
Additional information about Christopher Winters is available on the SEC’s website at
www.adviserinfo.sec.gov.
BURKE WEALTH MANAGEMENT, LLC | Form ADV 2B |
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ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Christopher Winters born 1991
Education:
Wake Forest University
B.A. Economics
2014
Business Background:
Burke Wealth Management
2024-Present
J.P. Morgan Private Bank
2019-2024
ITEM 3: DISCIPLINARY INFORMATION
Mr. Winters has nothing to disclose regarding any legal or disciplinary events material to a client’s evaluation of her
integrity.
ITEM 4: OTHER BUSINESS ACTIVITIES
Mr. Winters has nothing to disclose regarding other business activities.
ITEM 5: ADDITIONAL COMPENSATION
Except as otherwise described in Item 12 of the brochure, Mr. Winters does not expect to receive any economic
benefit from any non-advisory client for providing investment advice or other advisory services to our clients.
ITEM 6: SUPERVISION
Mr. Winters is the Vice President for BWM. His activities are supervised by Charles Keithley Ward, the Chief
Compliance Officer, in accordance with our policies and procedures. Mr. Ward’s contact information is
cward@burkewealthmanagement.com and 713-385-1441.
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