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Cove Wealth Management
a Registered Investment Adviser
710 N. Post Oak Rd., Suite 420
Houston, TX 77024
713-821-2343
www.covewm.com
March 12, 2026
This brochure provides information about the qualifications and business practices of Cove Wealth
Management, a dba of Valued Retirements, Inc.
If you have any questions about the contents of this brochure, please contact us at 713-821-3243 and/or
cco@covewm.com. The information in this brochure has not been approved or verified by the Securities and
Exchange Commission or by any state securities authority.
Additional information about Cove Wealth Management also is available on the SEC’s website at
www.adviserinfo.sec.gov.
Disclosure Brochure
Item 2. Material Changes
Since our update filed in March 2025, there have been the following material changes.
• Sarah Mizell was engaged as the Chief Compliance Officer in February of 2026.
We will provide you with a new Brochure as necessary based on material changes, new or updated information,
or upon request at any time, at no cost to you.
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Disclosure Brochure
Item 3. Table of Contents
Contents
Item 2. Material Changes .................................................................................................................................................................................................................. 2
Item 3. Table of Contents .................................................................................................................................................................................................................. 3
Item 4. Advisory Business ................................................................................................................................................................................................................... 4
Item 5. Fees and Compensation ...................................................................................................................................................................................................... 6
Item 6. Performance-Based Fees and Side-by-Side Management ...................................................................................................................... 9
Item 7. Types of Clients ........................................................................................................................................................................................................................ 9
Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss ............................................................................................................. 9
Item 9. Disciplinary Information ................................................................................................................................................................................................ 11
Item 10. Other Financial Industry Activities and Affiliations ................................................................................................................................ 11
Item 11. Code of Ethics ........................................................................................................................................................................................................................ 11
Item 12. Brokerage Practices ........................................................................................................................................................................................................ 12
Item 13. Review of Accounts ......................................................................................................................................................................................................... 14
Item 14. Client Referrals and Other Compensation .................................................................................................................................................. 15
Item 15. Custody .................................................................................................................................................................................................................................... 15
Item 16. Investment Discretion .................................................................................................................................................................................................. 16
Item 17. Voting Client Securities ................................................................................................................................................................................................ 16
Item 18. Financial Information ...................................................................................................................................................................................................... 16
Page 3 of 16
Disclosure Brochure
Item 4. Advisory Business
Cove Wealth Management offers a variety of advisory services, which include investment management
supported by financial planning, and wealth coordination services with a proprietary process designed to
mitigate information overload and create clarity. Prior to CWM providing any advisory service, clients must
complete written contracts with CWM setting forth an advisory relationship (“Advisory Agreement”).
CWM is owned by Cory & Sarah Mizell and Malcolm Morris. As of December 31, 2025, CWM had
$190,117,019 in total assets under management, all on a discretionary basis.
All assets under management are managed on a discretionary basis pursuant to written client agreements.
CWM does not manage any non-discretionary assets.
While this brochure generally describes the business of Cove Wealth Management, certain sections also discuss
the activities of its Supervised Persons, which refer to CWM’s officers, partners, directors (or other persons
occupying a similar status or performing similar functions), employees or other persons who provide investment
advice on the Advisor’s behalf and are subject to CWM’s supervision or control.
CWM provides fee-only investment management supported by financial planning, and advice characterized by
excellence for the purpose of creating a meaningful impact for our clients and the communities in which we
operate. We measure impact by meeting the goal that every family we serve will be able to articulate their
driving values, priority relationships, and one part of life for which they are grateful. As fiduciaries, we are
obligated to act in the best interests of our clients.
The foregoing statements reflect our investment philosophy and service approach and should not be interpreted
as guarantees of investment performance or client outcomes.
Financial Planning and Investment Management Services
CWM offers clients fee-only investment management services which include any or all of the following:
Portfolio Review and Rebalance
Trust and Estate Planning
•
•
Tax Strategy and Planning
• Overview of Client’s Financial Situation
•
Long-Term Financial Projections and Scenarios
•
Business Continuity Planning
•
Retirement Planning
•
Generational Transfer/ Family Education
•
Charitable Giving Strategy and Execution
•
Risk Management
•
Endowment or Restricted Fund Management
•
Insurance Review and Planning
•
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Disclosure Brochure
We tailor each financial plan, our investment management recommendations, and our Wealth Coordination
services to you. You can customize which services we provide. Clients are advised that a conflict of interest exists
for CWM to recommend that clients engage CWM or its affiliates to provide (or continue to provide) additional
services for compensation, including investment management services. Clients are under no obligation to act
upon any of the recommendations made by CWM under a financial planning or consulting engagement. Clients
are advised that it remains their responsibility to promptly notify CWM of any change in their financial situation
or investment objectives for the purpose of reviewing, evaluating, or revising Advisors’ recommendations and/or
services.
We tailor our advisory services to the unique needs of our clients by initially gathering client details and priorities.
We gather data, including risk tolerance, and create a customized Investment Policy Statement (IPS). The IPS sets
investment parameters that guide us as we make decisions about each client’s portfolio. As Investment
Managers, CWM primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”),
individual debt and equity securities (stocks and bonds), and additional outside independent investment
managers as needed in accordance with stated investment objectives. CWM consults with clients on an initial
and ongoing basis to assess their specific risk tolerance, time horizon, cash constraints and other related factors
relevant to the management of their portfolios.
Clients can engage CWM to advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored
retirement plans, and qualified tuition plans (i.e., 529 plans). In these situations, CWM directs or recommends the
allocation of client assets among the various investment options available with the product. These assets are
generally maintained at the underwriting insurance company or the custodian designated by the product’s
provider.
Wealth Coordination Services
In addition to financial planning and investment management, we provide individualized consultations on
selective financial matters. CWM provides clients with Wealth Coordination Services (WCS) which include
complex synchronization services to engage ultra-high net worth families through intentional and structured
collaboration with other professional service providers (accountants/ CPAs, bookkeepers, attorneys, other
investment professionals, etc.). We collaborate with outside professionals in a range of industries to support
families with a net worth between $20 million and $500 million. Professional collaborations are a key
component of Wealth Coordination Services. Our role is not to supplant these services, but to coordinate and
support them. CWM’s Wealth Coordination services help you execute a plan that brings everything together
under one cohesive umbrella.
By focusing on the big picture, we assist you in making the fundamental decisions that seek to put you on a path
to achieving your goals. This unique approach surrounds you with a dedicated team of skilled professionals that
can integrate all of your financial professionals and decisions.
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Disclosure Brochure
Use of Independent Managers
CWM selects certain Independent Managers to actively manage a portion of its clients’ assets when that
manager is deemed appropriate for a portion of a client’s portfolio. There is a separate written agreement with
the designated Independent Manager. That agreement can be between CWM and the Independent Manager
(often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account
manager). In addition to this brochure, clients will typically also receive the written disclosure documents of any
Independent Managers engaged to manage their assets.
CWM continues to provide services relative to the discretionary or non-discretionary selection of the Independent
Managers. On an ongoing basis, CWM monitors the performance of those accounts being managed by
Independent Managers.
When Independent Managers are utilized, clients typically pay fees directly to the Independent Manager in
addition to the advisory fee paid to CWM. As a result, the total advisory fees paid by clients may be higher than
if CWM managed the assets exclusively. CWM does not receive any portion of the fees paid to Independent
Managers. The use of Independent Managers presents a conflict of interest because CWM has discretion to
recommend and select Independent Managers, including those with higher fees.
Item 5. Fees and Compensation
CWM is a fee-only firm and receives no compensation for the sale of any product.
Financial Planning & Consulting Fees
CWM charges a fixed fee for providing financial planning and consulting services under a stand-alone, separate
contract. The fees, terms and conditions of financial planning services are set forth in the Advisory Agreement
and range from $5,000 to $10,000. Financial Planning fees are separate from other CWM services and are
negotiable depending upon the scope and complexity of the services and the professional rendering the financial
planning and/or the consulting services. The fee can be for a defined project, such as a comprehensive financial
plan, or for ongoing services. CWM reserves the right to waive all or part of the Financial Planning and Consulting
fees at its sole discretion. You may pay an initial Financial Planning fee in addition to the ongoing investment
management fee if you also engage us for Investment Management Services, or you may pay for a stand-alone
financial plan. CWM is under no obligation to offer a stand-alone financial plan prior to an investment
management engagement.
For project-based services, CWM requires one-half of the fee (estimated hourly or fixed) payable upon execution
of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan or completion of
the agreed-upon services.
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Disclosure Brochure
Investment Management Fees
The terms and conditions of Investment Management services are set forth in the Advisory Agreement with
CWM and will be customized per the individual Agreement with the client and calculated based on a percentage
of the value of assets under management. Investment Management services are charged separate from other
CWM services or per the signed Advisory Agreement. The standard CWM minimum annual Investment
Management fee is $5,000.
Investment Assets Under Management
The first $5 million
The next $5 million
The next $10 million
More than $20 million
Annual Rate
1.0%
0.80%
0.60%
Negotiated
This is a blended fee schedule, meaning different asset levels are assessed different fees, as shown above. Your
assets will be assessed a fee at each level, then those fees are combined for your overall fee. The annual fee is
prorated and charged quarterly, in arrears, based upon the market value of the assets as of the last business day
of the preceding calendar quarter. Fees are deducted from the accounts unless the clients have requested
separate billing. For the initial period of an engagement, the fee is prorated.
In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the
effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to
the client, as appropriate.
The annual fee can be negotiable based upon certain criteria (e.g., historical relationship, type of assets,
anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed,
related accounts, account composition, negotiations with Clients, etc.). The amount and method by which fees
are charged is established in each client’s written Agreement with CWM. While CWM’s planning and advisory
fees are negotiable, fee differences among clients are based on objective factors such as asset size, account
complexity, related household relationships, and the scope of services provided. Fee arrangements are
memorialized in each client’s written Advisory Agreement.
For asset management or advisory services that CWM provides with respect to certain client holdings (e.g., held-
away assets, accommodation accounts, alternative investments, etc.), CWM can negotiate a fee rate that differs
from the range set forth above. Clients are advised that a conflict of interest exists for CWM to recommend that
clients engage CWM for additional services for compensation, including rolling over retirement accounts or
moving other assets to CWM’s management.
CWM has a financial incentive to recommend that clients roll over retirement assets or move assets held away
to accounts managed by CWM because CWM earns advisory fees on assets under management. Clients are
under no obligation to roll over or transfer assets and may leave assets with their current custodian or adviser.
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Disclosure Brochure
Clients retain absolute discretion over the planning and financial decisions when engaging CWM and are under
no obligation to act upon any of the recommendations.
A portion of the revenue earned by CWM is intentionally used by partners and the team to create a positive
impact in our communities. We support many organizations with a particular focus on orphans and the
disadvantaged. We invite clients to join in generosity by recommending favorite charitable organizations.
Wealth Coordination Fees
Wealth Coordination fees are structured as a monthly flat fee charged in addition to investment management or
financial planning fees. The fees for Wealth Coordination range from $1,000 to $25,000 monthly based on
complexity/client needs, and they are typically billed quarterly or monthly, in arrears.
Clients engage and pay third-party professional collaborators directly for services rendered. We are only paid by
the client and do not ever pay or receive “referral payments” or other compensation from the collaborative
partners.
Additional Fees and Expenses
In addition to the advisory fees paid to CWM, clients also incur certain charges imposed by other third parties,
such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial
Institutions”). These additional charges include commissions, transaction fees, custodial fees, fees charged by the
Independent Managers, margin and other borrowing costs, charges imposed directly by a mutual fund or ETF
such as an expense ratio or marketing fee, as disclosed in the fund’s prospectus (e.g., fund management fees and
other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions. CWM’s brokerage
practices are described at length in Item 12, below.
Direct Fee Debit
Clients provide CWM and/or certain Independent Managers with authority to directly debit their accounts for
payment of the investment advisory fees. The Financial Institutions that act as qualified custodian(s) for client
accounts, from which CWM retains the authority to directly deduct fees, are obligated to send statements to
clients not less than quarterly detailing all account transactions, including any amounts paid to Cove Wealth
Management.
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Disclosure Brochure
Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time subject to cash availability.
Additions can be in cash or securities. CWM and/or the custodian reserves the right to liquidate any transferred
securities or decline to accept particular securities into a client’s account. Clients can withdraw account assets
on notice to Cove Wealth Management, subject to the usual and customary securities settlement procedures.
However, CWM designs its portfolios as long-term investments, and the withdrawal of assets may impair the
achievement of a client’s investment objectives.
Item 6. Performance-Based Fees and Side-by-Side Management
CWM does not provide any services for a performance-based fee (i.e., an additional fee based on an increase in
capital gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
CWM offers services to individuals, trusts, estates, charitable organizations, businesses, pension and profit-
sharing plans. Clients are often successful professionals and/or business owners who work to be financially
stable and strategic while making a positive impact on their families and communities.
Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss
Methods of Analysis and Investment Strategies
Investing differs from saving in one main way. Money designated as “savings” generally is held so that the balance
is fully protected, with some small amount of interest earned each year. Investing carries with it the potential for
greater rewards, but also the potential for loss of principal (principal refers to the amount invested). To repeat:
investing involves the risk of loss of principal. Clients need to realize this, and to be aware that this risk is theirs to
bear. Investing is for the long term. Before anyone invests, there are other issues that it is wise to address such as
a savings cushion, current levels of debt and spending, and emotional tolerance for investing and market
movement.
As an investment advisory firm, we use methods of analysis such as charting the movements of the markets or
securities within those markets; fundamental strengths of companies; technical price movements based on the
market or responses to outside events; cyclical movements of stocks within their industries; and momentum
issues with respect to securities (short-term performance that is stronger relative to comparable assets).
Occasionally, our research into the US and world economies may lead us to hold a significant cash allocation
temporarily. Because the initial and internal costs of any security can significantly affect its performance, we try
to be aware of those expenses as a part of the process of maximizing returns.
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Disclosure Brochure
We do not consider our investment strategies to be under the “frequent trading” classification, which to us means
holding securities for days or weeks only. However, we are not enamored of “buy and hold” either, except when
it comes to fixed income securities. Accordingly, in taxable accounts there may be taxable gains on a yearly basis
because securities were sold for a gain. Obviously, there can also be losses, which may also affect a client’s tax
situation.
Investment Philosophy:
CWM recognizes its fiduciary responsibility and willingly assumes the role of a steward on behalf of CWM’s
clients. CWM designs portfolios for client objectives using a diversified mix of publicly traded investments as the
portfolio core with focused investments or private placements as additional diversifiers.
Client Families:
Analysis of Client Family Desires - CWM asks clients about their hopes, dreams, and priorities. One process used
to explore this topic is Life Planning. Client responses to these topics help CWM better understand the desires of
their hearts and how CWM may or may not be able to help meet those desires.
Balance Sheet Analysis - CWM analyzes a client’s existing assets, liabilities and the details of their current
allocation of risk and resources in order to provide appropriate recommendations.
Cash Flow Analysis - CWM analyzes a client’s expected income and expenses in order to understand their true
investing time horizon and need for cash movement into or out of their investment portfolio.
Risk Tolerance Analysis - CWM asks clients questions to understand their comfort level with risk and how they
might respond to different investment experiences. This helps CWM understand their likely behavior and build an
appropriate investment portfolio to match their comfort level.
Investments:
CWM uses fundamental, technical, and valuation analysis. CWM primarily uses publicly traded low-cost
exchange traded funds, mutual funds, and Independent Managers that use individual equities and bonds. Given
CWM’s view that markets are generally efficient, CWM expects to hold most of its investments long-term. Most
accounts will hold a combination of cash, equities and fixed income in varying percentages according to the
appropriate level of risk.
Risk of Loss
All investing involves risk, and we discuss specific risks such as credit, market, cash management, inflation,
volatility, headline, social media, interest-rate and systemic and macroeconomic risk with our clients during an
initial appointment. We also discuss how non-correlated assets can reduce risk to a portfolio.
All investment strategies involve risk of loss, including the potential loss of principal. The degree of risk associated
with a client’s portfolio depends on factors such as asset allocation, market conditions, and the specific
investments selected.
Specific risks applicable to client portfolios may include, but are not limited to: market risk, interest rate risk,
inflation risk, credit risk, liquidity risk, manager risk, ETF and mutual fund risk, and the risk that diversification does
not eliminate the risk of loss. Investments in Independent Managers or alternative strategies may involve
additional risks, including limited liquidity, reduced transparency, and higher fees.
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Disclosure Brochure
Item 9. Disciplinary Information
CWM has not been involved in any legal or disciplinary events.
Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations. CWM does
not have any other professional financial industry activities or affiliations that need to be disclosed. Our advisors
serve in local community organizations where they provide periodic pro bono financial education.
These community activities are uncompensated and do not involve discretionary investment authority or
financial decision-making on behalf of clients.
Item 11. Code of Ethics
We have adopted a Code of Ethics which describes the general standards of conduct that we expect of all Firm
personnel (collectively referred to as “employees”). This code of ethics focuses on three specific areas where
employee conduct has the potential to adversely affect you:
• misuse of confidential information
• personal securities trading and
• outside business activities
Failure to uphold the Code of Ethics will result in disciplinary sanctions, including possible termination of
employment with us. All employees are required to review and acknowledge the Code of Ethics on an annual
basis. You may request a copy of the Firm’s Code of Ethics which will be provided to you at no cost.
The following basic principles guide all aspects of our business and represent the minimum requirements to
which we expect employees to adhere. Your interests come before the employees’ personal interests and before
the firm’s. We must fully disclose all material facts about conflicts between our interests, our employees’
interests, and your interests. Employees must operate on our behalf and on their own behalf consistently with
our disclosures and to manage the impacts of any conflicts of interest. We must not take inappropriate
advantage of our position of trust or responsibility to you. We must always comply with all applicable securities
laws.
Misuse of Non-Public Information:
The Code of Ethics contains a policy against the use of non-public information in the conduct of our business.
Employees may not convey non-public information nor use it in placing personal securities trades or any trades
for our clients.
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Disclosure Brochure
Personal Securities Trading:
Our personnel may buy, sell, or hold in their personal accounts the same securities we buy, sell, or hold for you.
Employees must obtain pre-approval from the Chief Compliance Officer before purchasing any IPO or investing
in a private partnership fund for any personal account.
To mitigate conflicts of interest, we have established the following policies to ensure our fiduciary responsibilities
and to place your interests first:
• An officer, director or employee shall not buy or sell securities for a personal portfolio when the decision
to purchase is substantially derived, in whole or in part, by reason of employment with us unless the
information is also available to the investing public on reasonable inquiry.
•
• Compliance reviews all personal trades considering our code of ethics and client trades on at least a
quarterly basis. Reports of personal securities holdings are filed with the Compliance Team (which is led
by the CCO) by all personnel and are reviewed at least annually.
Infractions of our personal trading policies will be grounds for disciplinary action, including possible
termination.
Outside Business Activities:
Employees are required to report on any outside business activities. If any such activities are deemed to conflict
with clients, such conflicts will be fully disclosed, or the employee will be required to cease such activity.
CWM’s Code of Ethics is designed to comply with Rule 204A-1 of the Advisers Act and is administered in a manner
consistent with the firm’s compliance policies and procedures.
Item 12. Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
CWM recommends that clients utilize the custody, brokerage and clearing services of Charles Schwab & Co, Inc.
through its Schwab Advisor Services division (“Schwab”) for investment management accounts. Our process for
selecting brokerages relies more on their capabilities as CUSTODIANS than as BROKERS. Since 2018, there has
been increased consolidation in available custodians which limits our choices as well. If a client has a preference,
this is always taken into consideration first.
We also examine:
• whether the client is best served by having all accounts with one custodian
(very often, this is a result of a client’s desire to “simplify,” “track fewer accounts,” etc.);
• whether there is a custodian that is more suitable for the client based on unique circumstance; and
• what provides the lowest transaction costs across the client’s portfolio.
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Disclosure Brochure
We generally choose discount brokerages due to the lower cost of transactions. In recent years, ease of website
use has also been a factor. For additional information, we would be happy to copy the applicable
pages from our compliance manual. Incidental benefits from any custodian, such as a discounted rate on
partner/vendor software, do not affect our choice of custodian. We will use the resources available to make
intelligent choices, but it has no bearing on our custodian of choice.
its policies and procedures regarding
The final decision to custody assets with Custodians is at the discretion of the client, including those accounts
under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA
accountholder. CWM is independently owned and operated and not affiliated with Custodians. Custodians
provide CWM with access to institutional trading and custody services, which are typically not available to retail
investors. CWM periodically and systematically reviews
its
recommendation of Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
CWM may receive the following benefits from Custodians through its registered investment adviser division:
receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that
exclusively services its Registered Investment Adviser participants; access to block trading which provides the
ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and
access to an electronic communication network for client order entry and account information. CWM also has
the ability to deduct advisory fees directly from client accounts; access to an electronic communications network
for client order entry and account information; access to mutual funds with no transaction fees and to certain
institutional money managers; and discounts on compliance, marketing, research, technology, and practice
management products or services provided to CWM by third party vendors. Custodians may fund business
consulting and professional services received by Advisors’ related persons.
Custodians’ services include brokerage services that are related to the execution of securities transactions,
custody, research, including that in the form of advice, analysis and reports, and access to mutual funds and other
investments that are otherwise generally available only to institutional investors or would require a significantly
higher minimum initial investment.
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Disclosure Brochure
Trade Aggregation
Transactions for each client will be affected independently, unless CWM decides to purchase or sell the same
securities for several clients at approximately the same time. CWM may (but is not obligated to) combine or
“batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate
equitably among CWM’s clients differences in prices and commissions or other transaction costs that might not
have been obtained had such orders been placed independently. Under this procedure, transactions will be
averaged as to price and allocated among Cove Wealth Management’ clients pro rata to the purchase and sale
orders placed for each client on any given day. To the extent that CWM aggregates client orders for the purchase
or sale of securities, including securities in which Cove Wealth Management’ Supervised Persons may invest,
CWM does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance
provided by the staff of the U.S. Securities and Exchange Commission. CWM does not receive any additional
compensation or remuneration as a result of the aggregation.
In the event that CWM determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small
percentage of the order is executed, shares may be allocated to the account with the smallest order or the
smallest position or to an account that is out of line with respect to security or sector weightings relative to other
portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations
in its investment guidelines which prohibit it from purchasing other securities which are expected to produce
similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment
guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be
due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations,
allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution
would result in a de minimis allocation in one or more accounts, CWM may exclude the account(s) from the
allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases
where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts
on a random basis.
Item 13. Review of Accounts
Account Reviews
CWM monitors client portfolios on a continuous and ongoing basis. Regular account reviews are conducted
annually at a minimum by CWM personnel. All investment advisory clients are encouraged to discuss their needs,
goals and objectives with CWM and to keep CWM informed of any changes.
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Disclosure Brochure
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements directly
from the Custodians. Clients may also receive quarterly written or electronic reports from CWM and/or an
outside service provider, which contain certain account and/or market-related information, such as an inventory
of account holdings or account performance. Clients should compare the account statements they receive from
their custodian with any documents or reports they receive from CWM or an outside service provider.
Item 14. Client Referrals and Other Compensation
CWM does not provide compensation to any third-party solicitors for client referrals. In the event a client is
introduced to CWM by either an unaffiliated or an affiliated solicitor, CWM will not pay nor accept a referral fee.
Item 15. Custody
Custody is the ability to take possession of or gain access to your money. CWM is deemed to have custody of
client funds and securities only to the extent the client grants CWM authority to direct the custodian to debit
client accounts for payment of CWM’s fees. As such, client funds and securities are maintained at one or more
Financial Institutions that serve as the qualified custodian with respect to such assets. Such qualified custodians
will send account statements to clients at least once per calendar quarter that typically detail any transactions
in such account for the relevant period.
In addition, as discussed in Item 13, CWM will also send, or otherwise make available, periodic supplemental
reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and
compare them to those received from Cove Wealth Management. Any other custody disclosures can be found in
CWM’s Form ADV Part 1.
Standing Letters of Authorization
In special circumstances, CWM has custody due to clients giving CWM a standing letter of authorization (“SLOA”)
to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, CWM
will consider the “SEC’s NO ACTION LETTER DATED FEBRUARY 21, 2017.” The steps in the SEC’s no-action letter
include (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize CWM
to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the
instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have
the ability to terminate or change the instruction; v) CWM will have no authority or ability to designate or change
the identity or any information about the third party; vi) CWM will keep records showing that the third party is
not a related party of CWM or located at the same address as CWM; and vii) the custodian will send the client an
initial and annual notice confirming the SLOA instructions. A standing letter of authorization permits CWM to
direct the custodian to transfer funds to a third party at the client’s instruction. CWM does not have authority to
change the recipient, amount, or timing of such transfers without client authorization.
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Disclosure Brochure
Item 16. Investment Discretion
CWM has discretion over its client’s accounts. This means that CWM does not seek a client’s consent first when
buying or selling securities. The client gives CWM this authority through a limited power-of- attorney included in
the agreement between CWM and the client included in initial account paperwork. Clients may request a
limitation on this authority (such as certain securities not to be bought or sold). CWM has discretion over the
following:
The securities to be purchased or sold;
The amount of securities to be purchased or sold;
The Independent Managers to be hired or fired.
•
•
• When transactions are made; and
•
Item 17. Voting Client Securities
Proxy Voting Authority
CWM will not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients will receive their
proxies or other solicitations directly from their custodian or a transfer agent (by email or US mail) for actions by
the client. Clients may contact CWM with questions about a particular solicitation, but we do not suggest that
much time be spent by the client on this activity, unless they desire an active role.
Item 18. Financial Information
Cove Wealth Management is not required to disclose any financial information listed in the instructions to Item
18 because:
•
CWM does not require prepayment of advisory fees in excess of $1,200 more than six months in
advance, and advisory fees are generally billed in arrears.
•
CWM does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
CWM has not been the subject of a bankruptcy petition at any time during the past ten years.
•
This brochure is current as of March 2026 and supersedes all prior versions.
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