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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
October 2025
733 Marsh St., Suite #110
San Luis Obispo, CA 93401
www.CerroWealth.com
Firm Contact:
Timothy Reyna
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Cerro Pacific
Wealth Advisors, LLC. If clients have any questions about the contents of this brochure, please contact
us at 805-457-3300. 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. Additional
information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD #310825.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Cerro Pacific Wealth Advisors, LLC is required to notify clients of any information that has changed
since the last annual update of the Firm Brochure (“Brochure”) that may be important to them. Each
year, we will ensure that you receive a summary of any material changes to this and subsequent
brochures by April 30th. Clients can request a full copy of our Brochure or contact us with any
questions that they may have about the changes.
Since our firm’s registration with the SEC was initially approved on March 07, 2025, the following
changes have occurred:
• The firm removed Jennifer Lynn Chesini. (Item 4)
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Item 3: Table of Contents
Item 1: Cover Page ................................................................................................................................................. 1
Item 2: Material Changes ..................................................................................................................................... 2
Item 3: Table of Contents .................................................................................................................................... 3
Item 4: Advisory Business ................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................ 7
Item 6: Performance-Based Fees & Side-By-Side Management ............................................................. 9
Item 7: Types of Clients & Account Requirements ..................................................................................... 9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss...................................................... 9
Item 9: Disciplinary Information .................................................................................................................... 17
Item 10: Other Financial Industry Activities & Affiliations ................................................................... 17
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading17
Item 12: Brokerage Practices .......................................................................................................................... 18
Item 13: Review of Accounts or Financial Plans ........................................................................................ 21
Item 14: Client Referrals & Other Compensation ..................................................................................... 22
Item 15: Custody ................................................................................................................................................... 22
Item 16: Investment Discretion ...................................................................................................................... 23
Item 17: Voting Client Securities .................................................................................................................... 23
Item 18: Financial Information ....................................................................................................................... 23
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Item 4: Advisory Business
Our firm provides individuals and other types of clients with a wide array of investment advisory
services. Our firm is a limited liability company formed under the laws of the State of California in
2020 and has been in business as an investment adviser since that time. Our firm is owned by Daniel
Speirs, Lyle Meek.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Comprehensive Portfolio Management:
As part of our Comprehensive Portfolio Management service clients will be provided asset
management services for a single fee. Our firm conducts client meetings to understand their current
financial situation, existing resources, financial goals, and tolerance for risk. Based on what is learned,
an investment approach is presented to the client, which may consist of individual stocks, bonds,
ETFs, options, mutual funds and other public and private securities or investments. Once the
appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and
if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives.
Certain Clients may be reinsurance companies related to vehicle dealerships. These companies
receive premiums for insurance. These premiums are then invested according to an Investment
Policy Statement established by an administrator. Our firm will manage the assets according to the
Investment Policy Statement but will not be responsible for the administration of the account or
payment of claims.
Our firm utilizes the sub-advisory and separately managed account (“SMA”) services of third-party
investment advisory firms or individual advisors (collectively, the “Third-Party Managers”) to aid in
the implementation of an investment portfolio designed by our firm. Before selecting a firm or
individual, our firm will ensure that the chosen party is properly licensed or registered. Our firm will
not offer advice on any specific securities or other investments in connection with this service. We will
provide initial due diligence on Third-Party Managers and ongoing reviews of their management of
client accounts. In order to assist in the selection of a Third-Party Manager, our firm will gather client
information pertaining to financial situation, investment objectives, and reasonable restrictions to be
imposed upon the management of the account.
Our firm will periodically review Third-Party Manager reports provided to the client at least annually.
Our firm will contact clients from time to time to review their financial situation and
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Cerro Pacific Wealth Advisors, LLC
objectives; communicate information to Third-Party Managers as warranted; and assist the client in
understanding and evaluating the services provided by the Third-Party Manager. Clients will be
expected to notify our firm of any changes in their financial situation, investment objectives, or
account restrictions that could affect their financial standing.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
•
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
•
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and notify
the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
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Cerro Pacific Wealth Advisors, LLC
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the
provision of services described therein.
Participant Account Management (Discretionary)
We may use a third-party platform (Pontera or similar) to facilitate management of held away assets
such as defined contribution plan participant accounts, with discretion. The platform allows us to
avoid being considered to have custody of Client funds since we do not have direct access to Client
log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the Client allowing them
to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser
will review the current account allocations. When deemed necessary, the Adviser will rebalance the
account considering client investment goals and risk tolerance, and any change in allocations will
consider current economic and market trends. The goal is to improve account performance over time
and manage internal fees that harm account performance. Client account(s) will be reviewed at least
quarterly and allocation changes will be made as deemed necessary.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Portfolio Management
clients. General investment advice will be offered to our Financial Planning & Consulting and
Retirement Plan Consulting clients. Each Comprehensive Portfolio Management client may place
reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on
investments in certain securities or types of securities may not be possible due to the level of
difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2024, our firm manages $ 547,195,634 on a discretionary basis.
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Item 5: Fees & Compensation
Compensation for Our Advisory Services
Comprehensive Portfolio Management:
Assets Under Management
First
Next
Next
Over
$ 2,000,000
$ 1,500,000
$ 1,500,000
$ 5,000,000
Annual %
1.00%
0.85%
0.70%
0.50%
Fees to be assessed will be outlined in the advisory agreement to be signed by the Client. Annualized
fees are billed on a pro-rata basis quarterly in arrears based on the time-weighted daily average value
of the account(s) during the quarter. Fees are generally not negotiable; however, our firm may make
exceptions under certain circumstances at our sole discretion. Fees will be deducted from client
account(s). In rare cases, our firm will agree to directly invoice. Further, cash is frequently held within
model portfolios. We assess advisory fees on cash and cash equivalents when held within a managed
account and/or managed model. As part of this process, Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
The maximum annual fee charged to clients by Third-Party Managers (if applicable) will not exceed
1.00%. This fee shall be separate from and in addition to the advisory fee charged by our firm.
However, the maximum combined advisory fee charged to clients will not exceed 2.00%. Our firm
will debit fees for this service as disclosed in the executed advisory agreement between the client and
our firm. Third-Party Managers establish and maintain their own separate billing processes over
which we have no control, and which may differ from our firm’s billing process. In general, they will
directly bill you and describe how this works in their separate written disclosure documents. The
Third-Party Managers we recommend will not directly charge you a higher fee than they would have
charged without us introducing you to them.
Financial Planning & Consulting:
Our firm charges a flat fee for financial planning and consulting services. The maximum flat fee to be
charged will not exceed $3500. The total estimated fee, as well as the ultimate fee charged, is based
on the scope and complexity of our engagement with the client. The fee-paying arrangements will be
determined on a case-by-case basis and will be detailed in the signed consulting agreement. Our firm
will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months.
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Cerro Pacific Wealth Advisors, LLC
Retirement Plan Consulting:
The maximum annual fee charged for this service will not exceed 1.00%. The fee to be charged is
based on the scope and complexity of our engagement with the client. The fee-paying arrangements
will be determined on a case-by-case basis and will be detailed in the signed consulting agreement.
Other Types of Fees & Expenses
Clients will incur transaction fees for trades executed by their chosen custodian via individual
transaction charges. These transaction fees are separate from our firm’s advisory fees and will be
disclosed by the chosen custodian. Fidelity Brokerage Services (“Fidelity”) eliminated transaction
fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of
statements or maintain at least $1 million in assets at Fidelity. Clients who do not meet either criteria
will be subject to transaction fees charged by Fidelity for U.S. listed equities and exchange traded
funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees, distribution fees, surrender charges,
variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads
paid to market makers, fees for trades executed away from custodian, wire transfer fees and other
fees and taxes on brokerage accounts and securities transactions). Our firm does not receive a portion
of these fees.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for our Comprehensive
Portfolio Management service in writing at any time. Upon notice of termination, pro-rata advisory
fees for services rendered to the point of termination will be charged. If advisory fees cannot be
deducted, our firm will send an invoice for due advisory fees to the client.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated based on the number of hours work
versus the estimated number of hours needed to fully render services. Clients will receive a pro-rata
refund of unearned fees based on the time and effort expended by our firm.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the other party. Full refunds will only be made in cases where cancellation occurs
within 5 business days of signing an agreement. After 5 business days from initial signing, either party
must provide the other party 30 days written notice to terminate billing. Billing will terminate 30
days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into
account work completed by our firm on behalf of the client. Clients will incur charges for bona fide
advisory services rendered up to the point of termination (determined as 30 days from receipt of said
written notice) and such fees will be due and payable.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
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Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit-Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us. However, Clients who opt into electronic delivery of statements or maintain at least $1 million in
assets at Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded
funds. Our firm recommends that clients opt into electronic delivery of statements to avoid
transaction fees for U.S. listed equities and exchange traded funds, and as such, our firm will assist
clients wishing to opt into electronic delivery of statements.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Cyclical Analysis: Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis.
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
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reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable
information, such as management expertise, industry cycles, strength of research and development,
and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on
numbers that can be found on reports such as balance sheets. The two techniques, however, will often
be used together in order to examine a company's operations and evaluate its potential as an
investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to
the social and experiential realm rather than the mathematical one. This approach depends on the
kind of intelligence that machines (currently) lack, since things like positive associations with a
brand, management trustworthiness, customer satisfaction, competitive advantage and cultural
shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative
analysis is that subjective judgment may prove incorrect.
Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The
process usually consists of searching vast databases for patterns, such as correlations among liquid
assets or price-movement patterns (trend following or mean reversion). The resulting strategies may
involve high-frequency trading. The results of the analysis are taken into consideration in the
decision to buy or sell securities and in the management of portfolio characteristics. A risk in using
quantitative analysis is that the methods or models used may be based on assumptions that prove to
be incorrect.
Technical Analysis: A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Third-Party Money Manager Analysis: The analysis of the experience, investment philosophies,
and past performance of independent third-party investment managers in an attempt to determine
if that manager has demonstrated an ability to invest over a period of time and in different economic
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conditions. Analysis is completed by monitoring the manager’s underlying holdings, strategies,
concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of
the due-diligence process, the manager’s compliance and business enterprise risks are surveyed and
reviewed. A risk of investing with a third-party manager who has been successful in the past is that
they may not be able to replicate that success in the future. In addition, as our firm does not control
the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager
may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable
investment for our clients. Moreover, as our firm does not control the manager’s daily business and
compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent
business, regulatory or reputational deficiencies.
Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic,
foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-
term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these
three provides a starting point. Usually included are hybrid instruments such as convertible bonds
and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be
considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.;
Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps;
insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and
futures; foreign currency; venture capital; private equity; and/or distressed securities.
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames and diversification. The most common forms of asset allocation are: strategic, dynamic,
tactical, and core-satellite.
• Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset
mix that seeks to provide the optimal balance between expected risk and return for a long-
term investment horizon. Generally speaking, strategic asset allocation strategies are
agnostic to economic environments, i.e., they do not change their allocation postures relative
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to changing market or economic conditions.
• Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in
that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance
between expected risk and return for a long-term investment horizon. Like strategic
allocation strategies, dynamic strategies largely retain exposure to their original asset
classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust
their postures over time relative to changes in the economic environment.
• Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or individual
stocks that show the most potential for perceived gains. While an original asset mix is
formulated much like strategic and dynamic portfolio, tactical strategies are often traded
more actively and are free to move entirely in and out of their core asset classes
• Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core'
strategic element making up the most significant portion of the portfolio, while applying a
dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this
way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical
allocation strategies mentioned above.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk
associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
Leveraged Exchange Traded Funds: Leverage is the investment strategy of using borrowed money:
specifically, the use of various financial instruments or borrowed capital to increase the potential
return of an investment. Leverage can also refer to the amount of debt used to finance assets. When
one refers to something (a company, a property or an investment) as "highly leveraged," it means
that item has more debt than equity. Like other ETFs, leveraged ETFs are individual securities that
trade on an exchange and can be bought and sold in intraday trading. But leveraged ETFs differ from
their traditional cousins in that they typically invest in one or more derivatives, which will cause their
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prices to rise or fall exponentially farther than the underlying benchmark against which they trade.
For example, an ETF that is double leveraged against the S&P 500 Index would rise and fall twice as
much in price as the index itself. If the index rises 2% in a day, then this fund would rise by 4% in
value. These funds can be leveraged at different rates, with some moving twice as much as the
underlying market or index and others rising or falling three, four or more times as much as the
benchmark. There are also leveraged ETFs that move inversely to their benchmarks, where the fund
will fall in price by a given exponential rate when the benchmark rises and vice-versa. Those that
move with the markets are referred to as long or bullish funds and those that move inversely are
short or bearish. It is important to note that many leveraged ETFs are rebalanced daily. This
characteristic renders many of them inappropriate for use as long-term holdings in an investment
portfolio. They are more appropriately used by short-term traders who buy and sell them within a
matter of minutes or hours with protective stop-loss orders. These strategies are generally designed
for intra-day trading, however may be held for longer durations in cases we deem it prudent to do so.
Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm makes a decision to sell.
Margin Transactions: Our firm may purchase stocks, mutual funds, and/or other securities for your
portfolio with money borrowed from your brokerage account. This allows you to purchase more
stock than you would be able to with your available cash and allows us to purchase stock without
selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate
for every client. The potential risks associated with these transactions are (1) You can lose more
funds than are deposited into the margin account; (2) the forced sale of securities or other assets in
your account; (3) the sale of securities or other assets without contacting you; and (4) you may not
be entitled to choose which securities or other assets in your account(s) are liquidated or sold to
meet a margin call.
Options: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder, or option buyer). The contract offers the buyer the right,
but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the
strike price) during a certain period of time or on a specific date (exercise date). Options are
extremely versatile securities. Traders use options to speculate, which is a relatively risky practice,
while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option
buyers and writers have conflicting views regarding the outlook on the performance of a:
• Call Option: Call options give the option to buy at certain price, so the buyer would want the
stock to go up. Conversely, the option writer needs to provide the underlying shares in the
event that the stock's market price exceeds the strike due to the contractual obligation. An
option writer who sells a call option believes that the underlying stock's price will drop
relative to the option's strike price during the life of the option, as that is how he will reap
maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes
that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock
for a lower price and then sell it for a profit. However, if the underlying stock does not close
above the strike price on the expiration date, the option buyer would lose the premium paid
for the call option.
• Put Option: Put options give the option to sell at a certain price, so the buyer would want the
stock to go down. The opposite is true for put option writers. For example, a put option buyer
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Cerro Pacific Wealth Advisors, LLC
is bearish on the underlying stock and believes its market price will fall below the specified
strike price on or before a specified date. On the other hand, an option writer who sells a put
option believes the underlying stock's price will increase about a specified price on or before
the expiration date. If the underlying stock's price closes above the specified strike price on
the expiration date, the put option writer's maximum profit is achieved. Conversely, a put
option holder would only benefit from a fall in the underlying stock's price below the strike
price. If the underlying stock's price falls below the strike price, the put option writer is
obligated to purchase shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock
price to the option’s strike price, small movements in a stock can translate into big movements in the
underlying options.
Short Sales: A short sale is a transaction in which an investor sells borrowed securities in
anticipation of a price decline and is required to return an equal number of shares at some point in
the future. These transactions have a number of risks that make it highly unsuitable for the novice
investor. This strategy has a slanted payoff ratio in that the maximum gain is limited, but the
maximum loss is theoretically infinite. The following risks should be considered: (1) In addition to
trading commissions, other costs with short selling include that of borrowing the security to short it,
as well as interest payable on the margin account that holds the shorted security. (2) The short seller
is responsible for making dividend payments on the shorted stock to the entity from whom the stock
has been borrowed. (3) Stocks with very high short interest may occasionally surge in price. This
usually happens when there is a positive development in the stock, which forces short sellers to buy
the shares back to close their short positions. Heavily shorted stocks are also susceptible to “buy-ins,”
which occur when a broker closes out short positions in a difficult-to-borrow stock whose lenders
are demanding it back. (4) Regulators may impose bans on short sales in a specific sector or even in
the broad market to avoid panic and unwarranted selling pressure. Such actions can cause a spike in
stock prices, forcing the short seller to cover short positions at huge losses.
Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). Our firm does this in an
attempt to take advantage of conditions that our firm believes will soon result in a price swing in the
securities our firm purchase.
Structured Products: Structured products are designed to facilitate highly customized risk-return
objectives. While structured products come in many different forms, they typically consist of a debt
security that is structured to make interest and principal payments based upon various assets, rates
or formulas. Many structured products include an embedded derivative component. Structured
products may be structured in the form of a security, in which case these products may receive
benefits provided under federal securities law, or they may be cast as derivatives, in which case they
are offered in the over-the-counter market and are subject to no regulation.
Investing in structured products includes significant risks, including valuation, lack of liquidity, price,
credit and market risks. The relative lack of liquidity is due to the highly customized nature of the
investment and the fact that the full extent of returns from the complex performance features is often
not realized until maturity. Another risk with structured products is the credit quality of the issuer.
Although the cash flows are derived from other sources, the products themselves are legally
considered to be the issuing financial institution's liabilities. The vast majority of structured products
are from high-investment-grade issuers only. Also, there is a lack of pricing transparency. There is no
uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of
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Cerro Pacific Wealth Advisors, LLC
alternative structured product offerings than it is, for instance, to compare the net expense ratios of
different mutual funds or commissions among broker-dealers.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, and that their assets are appropriately diversified in
investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance.
Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
Cash and Cash Equivalent Risk: Cash and cash equivalents generally refer to either United States
dollars or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank
CD’s and commercial papers. Generally, these assets are considered nonproductive and will be
exposed to inflation risk and considerable opportunity cost risk. Investments in cash and cash
equivalents will generally return less than the advisory fee charged by our firm.
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations
and, volatile increases and decreases in value as market confidence in and perceptions of their issuers
change. If you held common stock, or common stock equivalents, of any given issuer, you would
generally be exposed to greater risk than if you held preferred stocks and debt obligations of the
issuer.
ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
Financial Risk: Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may
cause your account value to likewise decrease, and vice versa. How specific fixed income securities
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may react to changes in interest rates will depend on the specific characteristics of each security.
Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity
risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely
manner, or that negative perceptions of the issuer’s ability to make such payments will cause the
price of a bond to decline.
Higher Trading Costs: For any investment instrument or strategy that involves active or frequent
trading, you may experience larger than usual transaction-related costs. Higher transaction-related
costs can negatively affect overall investment performance.
Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of resources
and end-user products generally increase and thus, the same general goods and products today will
likely be more expensive in the future. The longer an investment is held, the greater the chance that
the proceeds from that investment will be worth less in the future than what they are today. Said
another way, a dollar tomorrow will likely get you less than what it can today.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Manager Risk: There is always the possibility that poor security selection will cause your
investments to underperform relative to benchmarks or other funds with a similar investment
objective.
Market Risk: The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes in
the market, and you could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade
in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in
general). For fixed-income securities, a period of rising interest rates could erode the value of a bond
since bond values generally fall as bond yields go up. Past performance is not a guarantee of future
returns.
Options Risk: Options on securities may be subject to greater fluctuations in value than an
investment in the underlying securities. Additionally, options have an expiration date, which makes
them “decay” in value over the amount of time they are held and can expire worthless. Purchasing
and writing put and call options are highly specialized activities and entail greater than ordinary
investment risks.
Past Performance: Charting and technical analysis are often used interchangeably. Technical
analysis generally attempts to forecast an investment’s future potential by analyzing its past
performance and other related statistics. In particular, technical analysis often times involves an
evaluation of historical pricing and volume of a particular security for the purpose of forecasting
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Cerro Pacific Wealth Advisors, LLC
where future price and volume figures may go. As with any investment analysis method, technical
analysis runs the risk of not knowing the future and thus, investors should realize that even the most
diligent and thorough technical analysis cannot predict or guarantee the future performance of any
particular investment instrument or issuer thereof.
Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under
all market conditions and each investor should evaluate his/her ability to maintain any investment
he/she is considering in light of his/her own investment time horizon. Investments are subject to
risk, including possible loss of principal.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our
Comprehensive Portfolio Management services, as applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Ms. Ferguson, one of our firm’s Representatives is a licensed Notary and is eligible to earn
compensation for acting in this capacity. This creates a conflict of interest as Ms. Ferguson is
incentivized to recommend said services to clients in order to increase her compensation. In order
to mitigate this conflict of interest, Ms. Ferguson will not charge a fee for this service when provided
to clients.
Ms. Collins, one of our firm’s Representatives is a licensed Notary and is eligible to earn compensation
for acting in this capacity. This creates a conflict of interest as Ms. Collins is incentivized to
recommend said services to clients in order to increase her compensation. In order to mitigate this
conflict of interest, Ms. Collins will not charge a fee for this service when provided to clients.
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal
Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
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Cerro Pacific Wealth Advisors, LLC
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
To prevent conflicts of interest, our firm has established procedures for transactions effected by our
representatives for their personal accounts1. To monitor compliance with our personal trading policy,
our firm has pre-clearance requirements and a quarterly securities transaction reporting system for all
of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client. Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. To minimize this conflict of interest, our related persons will place client
interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is
available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. To minimize this conflict of interest, our related
persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a
copy of which is available upon request. Further, our related persons will refrain from buying or selling
the same securities prior to buying or selling for our clients in the same day unless included in a block
trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
While our firm does not maintain physical custody of client assets, we are deemed to have custody of
certain client assets if given the authority to withdraw assets from client accounts (see Item 15
Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to
recommend a custodian who will hold client assets and execute transactions on terms that are overall
most advantageous when compared to other available providers and their services. The factors
considered, among others, are these:
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
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Cerro Pacific Wealth Advisors, LLC
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
Our firm has an arrangement with National Financial Services LLC and Fidelity Brokerage Services LLC
(collectively, and together with all affiliates, "Fidelity") through which Fidelity provides our firm with
"institutional platform services." Our firm is independently operated and owned and is not affiliated with
Fidelity. The institutional platform services include, among others, brokerage, custody, and other related
services. Fidelity's institutional platform services that assist us in managing and administering clients'
accounts include software and other technology that (i) provide access to client account data (such as
trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated
trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv)
facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
Fidelity may make certain research and brokerage services available at no additional cost to our firm.
Research products and services provided by Fidelity may include: research reports on
recommendations or other information about particular companies or industries; economic surveys,
data and analyses; financial publications; portfolio evaluation services; financial database software and
services; computerized news and pricing services; quotation equipment for use in running software
used in investment decision-making; and other products or services that provide lawful and appropriate
assistance by Fidelity to our firm in the performance of our investment decision-making responsibilities.
The aforementioned research and brokerage services qualify for the safe harbor exemption defined in
Section 28(e) of the Securities Exchange Act of 1934.
Fidelity does not make client brokerage commissions generated by client transactions available for
our firm’s use. The aforementioned research and brokerage services are used by our firm to manage
accounts for which our firm has investment discretion. Without this arrangement, our firm might be
compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of Fidelity as a custodial recommendation. Our firm examined this potential conflict of interest
when our firm chose to recommend Fidelity and have determined that the recommendation is in the
best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best
execution.
Our clients may pay a transaction fee or commission to Fidelity that is higher than another qualified
broker dealer might charge to effect the same transaction where our firm determines in good faith
that the commission is reasonable in relation to the value of the brokerage and research services
provided to the client as a whole.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
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Cerro Pacific Wealth Advisors, LLC
Additional custodians our firm currently utilizes, include but will not be limited to, UMB Financial
Services and both Altruist LLC and Altruist Financial LLC (collectively, and together with all affiliates,
"Altruist")
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children
or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client
accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in.
Transition Assistance Benefits
Fidelity has provided our firm and its related persons assistance with the transition of their
associated business to Fidelity’s platform. The proceeds of such transition assistance are intended for
a variety of purposes, including but not limited to: technology systems; legal services related to the
formation of the advisory firm; regulatory compliance support services; other professional consulting
services, etc. Our firm attempts to mitigate these conflicts of interest by evaluating and recommending
that clients use Fidelity’s services based on the benefits that such services provide, rather than the
transition assistance earned by our firm. We consider Fidelity’s suite of services when recommending
that clients maintain accounts with Fidelity. However, clients should be aware of this conflict and take it
into consideration in making a decision whether to custody their assets with Fidelity. Aside from this,
our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
Fidelity does not make client brokerage commissions generated by client transactions available for
our firm’s use.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
of securities are placed for execution, and the commission rates at which such securities transactions
are effected. Our firm routinely recommends that clients direct us to execute through a specified
broker-dealer. Our firm recommends the use of Fidelity. Each client will be required to establish their
account(s) with Fidelity if not already done. Please note that not all advisers have this requirement.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
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plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Client-Directed Brokerage
Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost
clients more money. For example, in a directed brokerage account, clients may pay higher brokerage
commissions because our firm may not be able to aggregate orders to reduce transaction costs, or
clients may receive less favorable prices.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes
that to do so will be in the best interest of the effected accounts. When such concurrent authorizations
occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, our firm attempts to allocate trade executions in the most equitable
manner possible, taking into consideration client objectives, current asset allocation and availability of
funds using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors review accounts on at least an annual basis for our
Comprehensive Portfolio Management clients. The nature of these reviews is to learn whether client
accounts are in line with their investment objectives, appropriately positioned based on market
conditions, and investment policies, if applicable. Our firm does not provide written reports to clients,
unless asked to do so. Verbal reports to clients take place on at least an annual basis when our clients
are contacted. Our firm may review client accounts more frequently than described above. Among
the factors which may trigger an off-cycle review are major market or economic events, the client’s
life events, requests by the client, etc.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to
discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients
do not receive written or verbal updated reports regarding their plans unless they choose to engage
our firm for ongoing services.
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Cerro Pacific Wealth Advisors, LLC
Item 14: Client Referrals & Other Compensation
Fidelity
Except for the arrangements outlined in Item 12 of Form ADV Part 2A, our firm has no additional
arrangements to disclose.
Product Sponsors
Our firm occasionally sponsors events in conjunction with our product providers to keep our clients
informed as to the services we offer and the various financial products we utilize. These events are
educational in nature and are not dependent upon the use of any specific product. While a conflict of
interest may exist because these events are at least partially funded by product sponsors, all funds
received from product sponsors are used for the education of our clients. We will always adhere to
our fiduciary duty in recommending appropriate investments for our clients.
Referral Fees
Our firm does not pay referral fees (non-commission based) to independent promoters (non-
registered representatives) for the referral of their clients to our firm at this time.
Item 15: Custody
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third
Party Money Movement.” All our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
statements will include a legend that recommends the client compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody.
As such, our firm has adopted the following safeguards in conjunction with our custodian:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
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• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Our firm manages accounts on a discretionary basis. After you sign an agreement with our firm, we’re
allowed to buy and sell investments in your account without asking you in advance. Any limitations
will be described in the signed advisory agreement. We will have discretion until the advisory
agreement is terminated by you or our firm.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. If proxies are sent to our firm,
our firm will forward them to the appropriate client and ask the party who sent them to mail them
directly to the client in the future. Clients may call, write, or email us to discuss questions they may
have about proxy votes or other solicitations.
Third Party Managers selected or recommended by our firm may vote proxies for clients. Therefore,
except in the event a Third Party Manager votes proxies, clients maintain exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the
client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers,
bankruptcy proceedings or other type events pertaining to the client’s investment assets. Therefore
(except for proxies that may be voted by a Third Party Manager), our firm and/or the client shall
instruct the qualified custodian to forward to copies of all proxies and shareholder communications
relating to the client’s investment assets.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• Our firm has never been the subject of a bankruptcy proceeding.
ADV Part 2A – Firm Brochure
Page 23
Cerro Pacific Wealth Advisors, LLC