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ITEM 1 - COVER PAGE
ADV PART 2A
BROCHURE
50 E. Loucks, Suite 125
Sheridan, WY 82801
307-461-5550
ELEVATEASSET.COM
February 23, 2026
This brochure provides information about the qualifications and business practices of Elevate Wealth Management, LLC (“Elevate”). If you
have any questions about this brochure's contents, please contact us at 307.461.5550. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (“SEC”) or any state securities authority. Elevate is a
Registered Investment Adviser (“RIA”). Registration as an Investment Adviser with the SEC or any state securities authority does not imply a
certain level of skill or training.
Additional information about Elevate is available on the SEC's website at http://www.adviserinfo.sec.gov/. You can search this site by a
unique identifying number called an IARD number. The IARD number for Elevate is 336710.
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FEBRUARY 2026 | PAGE 1 OF 39
ITEM 2 - MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
Under federal and state law, fiduciaries must make full disclosure to Clients of all material facts relating to the
advisory relationship. This brochure provides clients or prospective clients with information and conflicts of
interest about Elevate Wealth Management that should be considered before or when obtaining our investment
advisory services. We are required to update this item to describe the material changes made to this brochure
on an annual basis and deliver to you, within 120 days of the end of the fiscal year, a free updated brochure that
includes or is accompanied by a summary of material changes; or a summary of material changes and an offer
to provide an updated brochure and how to obtain it. We will also provide interim disclosures regarding material
changes, as necessary.
Since our initial filing on June 5, 2025, there have been the following material changes to report:
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Item 5 has been updated to reflect our current Assets Under Management.
This brochure may be updated periodically for non-material changes to clarify and provide additional
information.
QUESTIONS & CONCERNS
We encourage you to read this document in its entirety. Our Chief Compliance Officer, James D. Shellenberger,
CFA, CFP®, remains available to address any questions or concerns regarding this Part 2A Brochure, including
any material change disclosure or information described below.
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FEBRUARY 2026 | PAGE 2 OF 39
ITEM 3 - TABLE OF CONTENTS
ITEM 1 - COVER PAGE ___________________________________________________________________________ 1
ITEM 2 - MATERIAL CHANGES ____________________________________________________________________ 2
SUMMARY OF MATERIAL CHANGES ___________________________________________________________ 2
QUESTIONS & CONCERNS ___________________________________________________________________ 2
ITEM 3 - TABLE OF CONTENTS ___________________________________________________________________ 3
ITEM 4 - ADVISORY BUSINESS ____________________________________________________________________ 7
ABOUT OUR FIRM ____________________________________________________________________________ 7
ADVISORY SERVICES WE OFFER _______________________________________________________________ 7
INITIAL PUBLIC OFFERINGS _________________________________________________________________________ 8
LEGACY MANAGEMENT SERVICES __________________________________________________________________ 8
FINANCIAL PLANNING SERVICES ____________________________________________________________________ 8
TAX PLANNING SERVICES __________________________________________________________________________ 9
CONSULTING SERVICES & ASSETS UNDER ADVISEMENT ______________________________________________ 9
INDEPENDENT THIRD-PARTY MANAGER SERVICES ____________________________________________________ 9
RETIREMENT PLAN SERVICES ______________________________________________________________________ 10
ROLLOVER RECOMMENDATION DISCLOSURE _______________________________________________________ 10
CASH MANAGEMENT SERVICES ____________________________________________________________________ 11
SEMINARS & WORKSHOPS _________________________________________________________________________ 11
CLIENT OBJECTIVES & RESTRICTIONS ________________________________________________________ 11
WRAP FEE PROGRAM _______________________________________________________________________ 11
REGULATORY ASSETS UNDER MANAGEMENT _________________________________________________ 11
ITEM 5 - FEES AND COMPENSATION _____________________________________________________________ 12
INVESTMENT MANAGEMENT FEE ____________________________________________________________ 12
LEGACY MANAGEMENT FEE _______________________________________________________________________ 12
FINANCIAL PLANNING FEE ________________________________________________________________________ 12
CONSULTING SERVICES & ASSETS UNDER ADVISEMENT FEE _________________________________________ 13
INDEPENDENT SUB-ADVISORY & THIRD-PARTY MANAGER SERVICE FEES ______________________________ 13
RETIREMENT PLAN SERVICE FEE ___________________________________________________________________ 14
CASH MANAGEMENT SERVICES FEE ________________________________________________________________ 14
SEMINARS & WORKSHOPS FEE _____________________________________________________________________ 14
ADMINISTRATIVE SERVICES PROVIDED BY ADVYZON TECHNOLOGIES __________________________ 15
ADDITIONAL FEES & EXPENSES ______________________________________________________________ 15
ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT ______________________________ 16
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ITEM 7 - TYPES OF CLIENTS _____________________________________________________________________ 16
ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS ___________________________________ 16
METHODS OF ANALYSIS ____________________________________________________________________ 16
FUNDAMENTAL ___________________________________________________________________________________ 16
MODEL MANAGER ________________________________________________________________________________ 16
MUTUAL FUND OR ETF ____________________________________________________________________________ 17
QUANTITATIVE ___________________________________________________________________________________ 17
RISKS FOR ALL FORMS OF ANALYSIS _______________________________________________________________ 17
INVESTMENT STRATEGIES ___________________________________________________________________ 17
LONG-TERM HOLDING ____________________________________________________________________________ 17
STRATEGIC ASSET ALLOCATION ___________________________________________________________________ 17
TACTICAL ASSET ALLOCATION ____________________________________________________________________ 18
VALUE INVESTING ________________________________________________________________________________ 18
USE OF ALTERNATIVE INVESTMENTS _______________________________________________________________ 18
DESCRIPTION OF MATERIAL, SIGNIFICANT OR UNUSUAL RISKS _______________________________________ 18
RISK OF LOSS ______________________________________________________________________________ 19
ACTIVE MANAGEMENT RISK _______________________________________________________________________ 19
ALLOCATION RISK ________________________________________________________________________________ 19
ALTERNATIVE RISK ________________________________________________________________________________ 19
CAPITALIZATION RISK _____________________________________________________________________________ 19
CALL RISK ________________________________________________________________________________________ 20
COMPANY RISK ___________________________________________________________________________________ 20
CONCENTRATION RISK ____________________________________________________________________________ 20
CREDIT RISK ______________________________________________________________________________________ 20
CURRENCY RISK ___________________________________________________________________________________ 20
CYBERSECURITY RISK ______________________________________________________________________________ 20
EQUITY RISK ______________________________________________________________________________________ 21
EVENT RISK _______________________________________________________________________________________ 21
ETF & ETN RISK ___________________________________________________________________________________ 21
FIXED INCOME & DEBT RISK _______________________________________________________________________ 21
FREQUENT TRADING RISK _________________________________________________________________________ 22
INDUSTRY OR SECTOR RISK ________________________________________________________________________ 22
INTEREST RATE RISK ______________________________________________________________________________ 22
ISSUER RISK ______________________________________________________________________________________ 22
LEGACY HOLDING RISK ___________________________________________________________________________ 22
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FEBRUARY 2026 | PAGE 4 OF 39
LIQUIDITY RISK ____________________________________________________________________________________ 22
MANAGEMENT RISK ______________________________________________________________________________ 23
MARKET RISK _____________________________________________________________________________________ 23
MUNICIPAL BOND RISK ____________________________________________________________________________ 23
MUTUAL FUND OR ETF RISK _______________________________________________________________________ 23
NON-LIQUID ALTERNATIVE INVESTMENT RISK ______________________________________________________ 23
OPTIONS RISK ____________________________________________________________________________________ 24
PERFORMANCE OF UNDERLYING MANAGER RISK ___________________________________________________ 24
PREPAYMENT RISK ________________________________________________________________________________ 24
REAL ESTATE SECURITIES AND RELATED DERIVATIVES RISK __________________________________________ 24
REINVESTMENT RISK ______________________________________________________________________________ 25
SECTOR RISK _____________________________________________________________________________________ 25
SECURITIES LENDING RISK _________________________________________________________________________ 25
SHORT SALE RISK _________________________________________________________________________________ 25
SOCIALLY RESPONSIBLE INVESTING & ESG RISK _____________________________________________________ 25
TIMING RISK ______________________________________________________________________________________ 26
VALUE INVESTING RISK ____________________________________________________________________________ 26
ITEM 9 - DISCIPLINARY INFORMATION ___________________________________________________________ 26
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS ________________________________ 26
INDUSTRY ACTIVITIES _______________________________________________________________________ 26
INSURANCE COMPANIES ____________________________________________________________________ 27
PERSONAL RELATIONSHIPS __________________________________________________________________ 27
SEMINARS & WORKSHOPS __________________________________________________________________ 27
OTHER FINANCIAL AFFILIATIONS ____________________________________________________________ 27
OTHER FINANCIAL INDUSTRY ACTIVITIES _____________________________________________________ 28
ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT TRANSACTIONS, & PERSONAL
TRADING ______________________________________________________________________________________ 28
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING ______________________ 28
ITEM 12 - BROKERAGE PRACTICES _______________________________________________________________ 29
INVESTMENT MANAGEMENT SERVICES ______________________________________________________ 29
FIDELITY INSTITUTIONAL,CHARLES SCHWAB & CO. INC. & ALTRUIST ____________________________ 29
CLIENT BROKERAGE AND CUSTODY COSTS ________________________________________________________ 30
PRODUCTS AND SERVICES AVAILABLE TO US _______________________________________________________ 30
SERVICES THAT BENEFIT OUR CLIENTS _____________________________________________________________ 30
SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS __________________________________________ 31
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SERVICES THAT GENERALLY BENEFIT ONLY US ______________________________________________________ 31
OUR INTEREST IN OUR CUSTODIAN’S SERVICES _____________________________________________________ 31
BROKERAGE FOR CLIENT REFERRALS _______________________________________________________________ 32
AGGREGATION AND ALLOCATION OF TRANSACTIONS ______________________________________________ 32
TRADE ERRORS ___________________________________________________________________________________ 33
DIRECTED BROKERAGE ____________________________________________________________________________ 33
ITEM 13 - REVIEW OF ACCOUNTS ________________________________________________________________ 34
CLIENT REVIEWS ____________________________________________________________________________ 34
ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION __________________________________________ 34
BROKERAGE PRACTICES ____________________________________________________________________ 34
LEAD GENERATION & REFERRALS ____________________________________________________________ 35
PROMOTERS ______________________________________________________________________________________ 35
OTHER PROFESSIONALS ___________________________________________________________________________ 35
ITEM 15 - CUSTODY ____________________________________________________________________________ 35
FEE DEDUCTION ___________________________________________________________________________ 35
STANDING LETTERS OF AUTHORIZATION (“SLOA”) ____________________________________________ 36
ITEM 16 - INVESTMENT DISCRETION _____________________________________________________________ 36
DISCRETIONARY AUTHORITY ________________________________________________________________ 36
ITEM 17 - VOTING CLIENT SECURITIES ___________________________________________________________ 36
PROXY VOTING _____________________________________________________________________________ 36
CLASS ACTION LAWSUITS ___________________________________________________________________ 37
ITEM 18 - FINANCIAL INFORMATION _____________________________________________________________ 37
FINANCIAL CONDITION ____________________________________________________________________ 37
ADDITIONAL INFORMATION ____________________________________________________________________ 37
PRIVACY POLICY ____________________________________________________________________________ 37
OPTING OUT _____________________________________________________________________________________ 37
BUSINESS CONTINUITY PLAN ________________________________________________________________ 37
CONTACTING US ___________________________________________________________________________ 38
VARYING DISRUPTIONS _____________________________________________________________________ 38
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ITEM 4 - ADVISORY BUSINESS
ABOUT OUR FIRM
Elevate Wealth Management is an investment advisory firm offering comprehensive financial planning and
investment management designed to support clients at every level of net worth. Elevate Wealth Management
is currently registered with the Securities and Exchange Commission ("SEC") as an investment adviser, with its
principal place of business located in Wyoming. Elevate Wealth Management has been in business since 2025,
and its principal owner is the Gary and Susan Miller Revocable Trust. Our Firm was registered with the SEC as
an investment adviser in 2025. Registration as an Investment Adviser with the United States SEC or any state
securities authority does not imply a certain level of skill or training. Our Firm currently has offices located at 50
East Loucks Street, Suite 125, Sheridan, WY. 82801.
This brochure is designed to provide detailed and precise information about each item noted in the table of
contents. Certain disclosures are repeated in one or more items, and other disclosures are referred throughout
to be as comprehensive as possible on the broad subject matters discussed.
Within this brochure, specific terms in either are used as follows:
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•
•
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“Elevate” refers to Elevate Wealth Management.
“Firm,” “we,” “us,” and “our” refer to Elevate Wealth Management.
“Advisor,” “Investment Advisor Representative,” and “IAR” refers to our professional representatives
who provide investment recommendations or advice on behalf of Elevate Wealth Management.
“You,” “yours,” and “Client” refers to Clients of Elevate Wealth Management and its advisors.
“Code” refers to our Firm’s Code of Ethics.
“CCO” refers to our Chief Compliance Officer.
ADVISORY SERVICES WE OFFER
Our Firm offers a variety of advisory services, which include discretionary investment management, financial
planning, consulting services and assets under advisement, independent third-party money management, and
retirement services. Before rendering any preceding advisory services, Clients must enter into one or more
written Investment Advisory Agreements (“Agreements”), setting forth the relevant terms and conditions of the
advisory relationship.
We do not provide tax or legal advice. Clients should consult with an expert on tax or legal issues.
Our Firm manages portfolios for individuals, high-net-worth individuals and families, trusts, retirement plans,
corporations, charitable foundations and pension plans. We provide investment management and advisory
services to multi-generational families using separately managed accounts under a custodial relationship with
an independent brokerage firm.
With our discretionary relationship, we will change the portfolio as appropriate to help meet your financial
objectives. We trade Client portfolios based on our Firm’s market views and the Client’s financial goals.
We primarily invest in equities, corporate debt securities, certificates of deposit, municipal securities, mutual
funds, and exchange-traded funds, and US Government Securities. A portion of the account may be held in
cash, cash equivalents, or money market funds as part of the overall investment strategy. Cash balances may
have a higher concentration and represent a sizable portion of your overall portfolio, depending on the current
investment outlook or strategy.
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FEBRUARY 2026 | PAGE 7 OF 39
Clients may impose reasonable restrictions on investing in certain securities by notifying us through written
notification. Elevate reserves the right to decline such restrictions at its discretion.
Where deemed appropriate, we may recommend that our Clients invest in alternative assets, including hedge
funds, private equity funds, real estate funds, and other alternative funds. Although the Investment Advisory
Agreement with our Clients gives us broad investment authority, we do not anticipate investing in other security
types. However, from time to time, we will consider incorporating socially responsible investing (Sustainable
Investing Strategies (“SIS”) or Environment, Social, and Governance Strategies (“ESG”) for those Clients who
wish to align their portfolios with their personal preferences for Impact Investing. This may include investing in
both public and private markets. A Client’s investment allocation and our strategy will depend on the Client's
responses in review meetings, written questionnaires, stated goals, risk tolerance, objectives, and personal
preference for Impact Investing.
Clients are advised to promptly notify us if there are changes in their financial situation or if they wish to place
any limitations on managing their portfolios.
Elevate Wealth Management can recommend that certain clients utilize margin in the client’s investment
portfolio or other borrowing. Elevate Wealth Management only recommend such borrowing for non-investment
needs, such as bridge loans and other financing needs. The Firm’s fees are determined based on the value of
the assets being managed gross of any margin or borrowing.
Our Firm typically requires a minimum account size of $100,000 for advisory accounts. However, sometimes, at
our sole discretion, we may accept smaller accounts based on various criteria, such as anticipated future assets,
related accounts, and other individual Client circumstances.
INITIAL PUBLIC OFFERINGS
When offered through the account Custodian, we may have the ability to request shares of initial public offerings
(“IPOs”) and secondary offerings for our Clients. These are short-term, speculative investments.
At this time, we will only request shares of an IPO (Initial Public Offerings) for a Client that has specifically
requested those shares.
If several Clients request the shares of an IPO, and we receive fewer shares than were requested, we must
allocate those shares among the participating Clients. The allocations are typically equal or proportionate to the
number of shares requested. Investing in securities involves the risk of loss that Clients should be prepared to
bear. See Item 8 for more detail on the risk associated with investing.
LEGACY MANAGEMENT SERVICES
Our Firm may advise a Client about legacy positions or other investments in Client portfolios. Clients can limit
or restrict our trading and/ or billing in these positions.
FINANCIAL PLANNING SERVICES
Our Firm offers financial planning services, which involve preparing a written financial plan covering specific or
multiple topics. We provide full written financial plans, which may address one or several topics: Investment
Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios, and Allocation
Review.
Unless otherwise agreed to in writing, the Client is solely responsible for determining whether to implement our
financial planning recommendations. Our financial planning services do not involve implementing transactions
on your behalf nor include active and ongoing monitoring or management of your investments or accounts.
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The Client must execute a separate written agreement if the Client elects to implement any of our investment
recommendations through our Firm or retain our Firm to monitor and manage investments actively.
TAX PLANNING SERVICES
HOLISTIPLAN – TAX PLANNING SERVICES
Holistiplan is a tax planning software that may uncover potential tax strategies designed to help mitigate tax
burden in retirement and beyond.
CONSULTING SERVICES & ASSETS UNDER ADVISEMENT
Our investment consulting and advisement services are designed to meet our Client’s financial goals, needs,
and objectives involving analysis of a Client’s investments, such as variable life insurance and annuity contracts
and assets held in employer-sponsored retirement plans, and qualified tuition plans (i.e., 529 plans) held
externally from our Firm. In these situations, our Firm may direct or recommend allocating assets among the
various investment options available within the product.
INDEPENDENT THIRD-PARTY MANAGER SERVICES
If deemed appropriate, our Firm will utilize the services of an Independent Third-Party Manager (“ITPM” or
“Manager”) to manage your accounts. Investment recommendations and securities trading will only be offered
by or through the chosen Manager or ITPM. Our Firm will not advise on any specific securities concerning this
service.
Before referring you, our Firm will provide initial due diligence on Manager and ITPMs and ongoing reviews of
their management of your accounts. To assist in selecting an Manager or ITPM, our Firm will gather information
about the Client’s financial situation, investment objectives, and reasonable restrictions to be imposed upon the
account management.
Our Firm will periodically review the Manager reports provided to the Client. We will periodically contact the
Client to review their financial situation and objectives, communicate information to the Manager as warranted,
and assist you in understanding and evaluating the services provided. The Client 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.
By executing an Investment Advisory Agreement with our Firm, the Client gives our Firm the discretionary
authority to hire or fire the Manager and to allocate assets among Managers without obtaining consent.
The services provided by the Manager and ITPM include:
Implementation of an asset allocation
• Assessment of your investment needs and objectives
•
• Delivery of suitable style allocations (e.g., Income, Large Cap, Small Cap, Growth, Value, etc.)
• Facilitation of portfolio transactions
• Ongoing monitoring of investment vehicles’ performance
• Review of accounts for adherence to policy guidelines and asset allocation
• Reporting of your portfolio activity.
Each Manager has minimum account requirements that will vary between Managers. Account minimums are
typically higher for fixed-income accounts than for equity-based accounts. A complete description of the
Manager’s services, fee schedules, and account minimums will be disclosed in the Manager’s disclosure
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brochure, which will be provided to you before or when an agreement for services is executed, and the account
is established.
RETIREMENT PLAN SERVICES
When providing any non-discretionary investment advisory services, we will solely be making investment
recommendations to the Sponsor, and the Sponsor retains full discretionary authority or control over assets of
the retirement plan. We agree to perform any non-discretionary investment advisory services to the retirement
plan as a fiduciary, as defined in ERISA Section 3(21)(A)(ii). We will act in good faith and with the degree of
diligence, care, and skill that a prudent person rendering similar services would exercise under similar
circumstances.
When providing administrative services, we may support the Sponsor with plan governance and committee
education; vendor management and service provider selection and review; investment education; or plan
participant non-fiduciary education services. We agree to perform any administrative services solely in a capacity
that would not be considered a fiduciary under ERISA or any other applicable law.
When offering investment models to plan sponsors, under certain circumstances, we will act as a “fiduciary” as
defined under Section 3(21) of ERISA and Section 4975I (3) of the Internal Revenue Code of 1986, as amended
(the “Code”).
When applicable, our Firm accepts its appointment as an “Investment Manager” within the meaning of Section
3(38) of ERISA (but only concerning those plan assets constituting the portfolio models). We will not have any
authority or responsibility in the administration of the Plan (including the selection of portfolio models for the
Plan) or interpretation of any Plan document. Our Firm agrees it will act in a manner consistent with the
requirements of a fiduciary under ERISA and the Code. We further agree that all investment management
powers, duties, and responsibilities relating to the portfolio shall be exercised exclusively by our Firm per the
Plan.
ROLLOVER RECOMMENDATION DISCLOSURE
Our Firm is considered a fiduciary under the Investment Advisers Act of 1940. When we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries
within the meaning of Title I of the Employee Retirement Income Security Act and the Internal Revenue Code,
as applicable, which are laws governing retirement accounts. We must act in your best interest and not put our
interests ahead of yours. At the same time, how we make money conflicts with Client interests.
A Client leaving an employer typically has four options regarding an existing retirement plan (and may engage
in a combination of these options):
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leave the money in the former employer’s plan, if permitted,
roll over the assets to the new employer’s plan, if one is available and rollovers are permitted,
rollover to an Individual Retirement Account (“IRA”), or
cash out the account value (which depending upon the Client’s age, could result in adverse tax
consequences).
Our Firm may recommend a Client rollover plan assets to an IRA for which our Firm provides investment advisory
services. As a result, our Firm and its advisors may earn an asset-based fee on the rolled assets. In contrast, a
recommendation that a Client leave their plan assets with their previous employer or rollover the assets to a plan
sponsored by a new employer will result in no compensation to our Firm. Therefore, our Firm has an economic
ELEVATE WEALTH MANAGEMENT
FEBRUARY 2026 | PAGE 10 OF 39
incentive to encourage a Client to roll plan assets into an IRA that our Firm will manage, which presents a conflict
of interest. To mitigate the conflict of interest, there are numerous factors that our Firm will consider before
recommending a rollover, including but not limited to:
the investment options available in the plan versus the investment options available in an IRA,
fees and expenses in the plan versus the fees and expenses in an IRA,
the services and responsiveness of the plan’s investment professionals versus those of our Firm,
required minimum distributions and age considerations, and
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• protection of assets from creditors and legal judgments,
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• employer stock tax consequences, if any.
The Chief Compliance Officer remains available to address client questions regarding the supervision and
oversight of rollover and transfer assets.
CASH MANAGEMENT SERVICES
FLOURISH CASH
As part of our comprehensive wealth management services, we offer clients the option to utilize Flourish Cash,
a cash management solution provided by Flourish Financial LLC, a FINRA-registered broker-dealer and SIPC
member, and its affiliated entities.
Flourish Cash is designed to provide enhanced yield on cash balances through a program that allocates funds
across multiple FDIC-member banks. Clients who elect to participate in Flourish Cash authorize Elevate to
facilitate the connection to the platform and monitor balances as part of their overall financial plan.
Clients are under no obligation to use Flourish Cash and may access comparable services through other
providers.
SEMINARS & WORKSHOPS
Our Firm occasionally provides financial, retirement, estate, and college planning seminars. Seminars are always
offered on an impersonal basis and do not focus on the individual needs of participants.
CLIENT OBJECTIVES & RESTRICTIONS
Our Firm tailors our investment management and advisory services continuously to meet the needs of our
Clients. We seek to ensure Client portfolios are managed consistently with those needs and objectives in mind.
We meet with Clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity
constraints, and other related factors relevant to managing their portfolios. Clients may impose reasonable
restrictions on managing the accounts if the conditions do not impact the performance of a management
strategy.
WRAP FEE PROGRAM
Our Firm does not sponsor or participate in a Wrap Program.
REGULATORY ASSETS UNDER MANAGEMENT
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As of December 31, 2025, our Firm has $320,171,504 in discretionary assets under management and $101,214
in non-discretionary assets under management for a total of $320,272,718.
ITEM 5 - FEES AND COMPENSATION
In addition to the information provided in Item 4 – Advisory Business, this section details our Firm’s services and
each service’s fees and compensation arrangements. The Client and Elevate Wealth Management’s Investment
Advisory Agreement will outline and agree upon the exact costs and other terms related to the Client’s Accounts.
INVESTMENT MANAGEMENT FEE
Our Firm offers investment management services for an annual fee based on the amount of assets under
management. Our maximum annual fee is 2%, and we have a minimum account size of $100,000. We retain the
right to waive the minimum account size at our discretion.
Our annual fee is reasonable in relation to (1) the services provided and (2) the fees charged by other investment
advisers offering similar services/programs.
Our annual fee is prorated and charged quarterly in advance based on the value of the Client’s assets under
management as of the close of business on the last business day of the previous quarter. Cash and cash
equivalents, including money market funds, are subject to the agreed-upon advisory fee. Clients should
understand that the advisory fees charged on these balances may exceed the returns provided by cash, cash
equivalents, or money market funds, especially in low-interest rate environments.
Our Firm retains complete discretion to negotiate fees and may waive or impose different fees on any Client.
The investment advisory fees will be deducted from your account and paid directly to our Firm by the qualified
Custodian(s) of your account. The Client will authorize your account's qualified Custodian(s) to deduct fees from
the account and pay such fees directly to our Firm. All account assets, transactions, and advisory fees will be
shown on the monthly or quarterly statements provided by the Custodian. You should review your account
statements received from the qualified Custodian(s) and verify that appropriate investment advisory fees are
being deducted. The qualified Custodian(s) will not verify the accuracy of the investment advisory fees deducted.
We may aggregate related Client accounts to calculate the advisory fee applicable to the Client. The investment
management agreement will outline the fee charged to a Client and any breakpoints based on the level of assets
managed. The fees are subject to change with prior written notice to the Client.
Our annual investment advisory fee may be higher than that of other investment advisers that offer similar
services and programs. In addition to our compensation, you may incur charges imposed at the mutual fund
level (e.g., advisory fees and other fund expenses).
Accounts initiated or terminated during a calendar quarter will be charged a prorated fee based on the days the
Client account was open during that quarter. Any prepaid, unearned fees will be refunded upon termination of
any account.
LEGACY MANAGEMENT FEE
Managed legacy positions are included within our Firm’s standard investment management fee and are outlined
in the executed investment management agreement.
FINANCIAL PLANNING FEE
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Our Firm provides financial planning services under a fixed fee or hourly arrangement. This arrangement charges
a mutually agreed-upon fee for financial planning services. Fixed fee typically range from $2,500 - $10,000 and
the maximum hourly fee is $500 per hour.
Fees charged for our financial planning services are negotiable based upon the type of Client, the services
requested, the investment adviser representative providing advice, the complexity of the Client's situation, the
composition of the Client's account, other advisory services provided, and the relationship of the Client and the
investment adviser representative.
The amount of the fee for your engagement is specified in your financial planning agreement with us. At our
sole discretion, the Client may be required to pay the fee at the time the agreement is executed with our Firm;
however, our Firm does not require or solicit prepayment of more than $1,200 in fees per Client, six months or
more in advance. The fee is considered earned upon delivery of the financial plan, and any unpaid amount is
immediately due.
The Client may pay the fees owed for the financial planning services by submitting payment directly via check,
or by deducting the fee from an existing investment account. If the Client elects to pay by automatic deduction
from an existing investment account, they will provide written authorization to our Firm for such a charge.
If the Client terminates the financial planning services after entering into an agreement with our Firm, the Client
will be invoiced and responsible for immediate payment of any hourly financial planning services performed by
us before receiving notice of termination. For financial planning services, our Firm performs under a fixed or
hourly fee arrangement, the Client will be responsible for paying a pro-rated fixed fee equivalent to the
percentage of work that our Firm completed. If there is a remaining balance of any fees paid in advance after
deducting fees from the final invoice, those remaining proceeds will be refunded to the Client.
CONSULTING SERVICES & ASSETS UNDER ADVISEMENT FEE
Our Firm provides consulting services based on an hourly fee arrangement, generally $250 per hour. This
arrangement charges a mutually agreed-upon fee for financial planning services.
Fees charged for consulting services are negotiable based on the type of Client, the services requested, the
investment adviser representative providing advice, the complexity of the Client's situation, the composition of
the Client's account, other advisory services provided, and the relationship of the Client and the investment
adviser representative.
INDEPENDENT SUB-ADVISORY & THIRD-PARTY MANAGER SERVICE FEES
If deemed appropriate, our Firm will utilize the services of a Sub-Advisor (“SMA” or “Manager”) or Independent
Third-Party Manager (“ITPM” or “Manager”) to manage your accounts. Investment recommendations and
securities trading will only be offered by or through the chosen SMA or ITPM. Our Firm will not advise on any
specific securities concerning this service.
A complete description of the SMA and ITPM’s services, fee schedules, and account minimums will be disclosed
in Manager's disclosure brochure, which will be provided to you before or when an agreement for services is
executed, and the account is established. Each third-party investment adviser is required under federal securities
laws to provide their clients, including SMA and ITPM Clients, with a Form ADV Part 2A (“Adviser Brochure” or
“this Brochure”) that includes disclosures, and among other things, the fees charged to their clients.
The actual fee charged to the Client will vary depending on SMA or ITPM. All fees are calculated and collected
by the Manager, who will be responsible for delivering our Firm’s portion of the fee paid by the Client. With
SMA and ITPMs, you may incur additional charges, including mutual fund sales loads, 12b-1 fees and surrender
charges, and IRA and qualified retirement plan fees.
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There is a potential conflict of interest in using independent managers if they pay us a portion of their advisory
fee and have met the conditions of our Firm’s due diligence review. Our Firm is committed to always working in
the Client's best interest. There may be other Managers not affiliated with our Firm that may be suitable for a
Client or may be more or less costly. As with any Advisor, no guarantees can be made that the SMA or ITPM will
achieve your financial goals or objectives. Further, no guarantees of performance can be offered.
Clients should review the SMA or ITPM’s Brochure in its entirety, along with this Brochure, to fully understand
the services, fees, agreements, and risks surrounding these arrangements and fully understand that these types
of arrangements have layers of fees that may or may not be apparent without reading the SMA or ITPM’s
Brochure and this Brochure, along with the offering document/prospectus for underlining investments.
If Elevate engages an ITPM for alternative investments, the client may incur an additional fee outside of Elevate’s
advisory fee from the ITPM for the management of the assets invested in the alternative product.
RETIREMENT PLAN SERVICE FEE
For Retirement Plan Advisory Services compensation, we charge an advisory fee as negotiated with the Plan
Sponsor and as disclosed in the Employer-Sponsored Retirement Plans Consulting Agreement (“Plan Sponsor
Agreement”).
Typically, the billing period for these fees is paid quarterly. This fee is negotiable, but the terms and the advisory
fee are agreed upon in advance and acknowledged by the Plan Sponsor Agreement or Plan Provider’s account
agreement. Fee billing methods vary depending on the Plan Provider.
Our Firm or the Plan Sponsor may terminate the Agreement upon 30 days written notice to the other party. The
Plan Sponsor is responsible for paying for the services rendered until the termination of the Agreement.
CASH MANAGEMENT SERVICES FEE
FLOURISH CASH
The Firm receives a fee up to 10 basis points (0.10%) annually on assets held in Flourish Cash accounts when
clients are introduced to the service by Elevate and enroll through the provided referral link or advisor interface.
This fee is paid to the Firm by Flourish Financial LLC and is not deducted from client assets. The fee does not
impact the interest rate or yield the client receives. However, clients should be aware that this fee arrangement
presents a conflict of interest, as the Firm has a financial incentive to recommend Flourish Cash.
The Firm mitigates this conflict by:
• Disclosing the compensation arrangement to clients in writing;
• Ensuring that clients are free to use any cash management provider they choose;
• Recommending Flourish Cash only when it is in the client’s best interest based on overall financial
needs.
Clients do not pay any advisory fee directly to Elevate for use of Flourish Cash, though the Firm does include
cash assets in Flourish Cash when reporting on total client balances under management or advisement where
appropriate.
SEMINARS & WORKSHOPS FEE
Our Firm does not charge for attending one of our seminars.
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ADMINISTRATIVE SERVICES PROVIDED BY ADVYZON TECHNOLOGIES
Our Firm has contracted with Advyzon Technologies to utilize its technology platforms to support data
reconciliation, performance reporting, fee calculation, client relationship maintenance, quarterly performance
evaluations, and other functions related to managing Client accounts' administrative tasks. Due to this
arrangement, Advyzon will have access to client accounts, but Advyzon will not serve as an investment advisor
to our clients or bill the accounts. Advyzon charges our firm an annual fee for each account administered by its
software. Please note that our Firm’s annual fee to Advyzon will not increase the Client's fee. Our firm will pay
the annual fee from the portion of the management fee retained by Our Firm. Our Firm and Advyzon are non-
affiliated companies.
ADDITIONAL FEES & EXPENSES
In addition to the advisory fees paid to our Firm, Clients also incur certain charges imposed by other third parties,
such as broker-dealers, Custodians, trust companies, banks, and other financial institutions. These additional
charges include securities, transaction fees, custodial fees, fees charged by the SMA, ITPM, and Manager
charges imposed by a mutual fund or ETF (Exchange Traded Funds) in a Client’s account, 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. Our brokerage practices are described at length in Item 12 below. Neither
our Firm nor its supervised persons accept commission compensation for selling securities or other investment
products. Further, we do not share any additional fees and expenses outlined above.
Our Firm’s investment strategies may include mutual and exchange-traded funds (“ETFs”). Our policy is to
purchase institutional share classes of those mutual funds selected for the Client’s portfolio. The institutional
share class generally has the lowest expense ratio. The expense ratio is the annual fee that all mutual funds or
ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for funds
expenses, including 12b-1 fees, management fees, administrative fees, operating costs, and all other asset-
based costs incurred by the fund. Some fund families offer different classes of the same fund, and one share
class may have a lower expense ratio than another. Mutual fund expense ratios are in addition to our fees; we
do not receive any portion of these charges. If an institutional share class is not available for the mutual fund
selected, the adviser will purchase the least expensive share class available for the mutual fund. As share classes
with lower expense ratios become available, we may use them in the Client’s portfolio or convert the existing
mutual fund position to the lower-cost share class. Clients who transfer mutual funds into their accounts with our
Firm would bear the expense of any contingent or deferred sales loads incurred upon selling the product. If a
mutual fund has a frequent trading policy, the policy can limit a Client’s transactions in fund shares (e.g., for
rebalancing, liquidations, deposits, or tax harvesting). All mutual fund expenses and fees are disclosed in the
respective mutual fund prospectus.
When selecting investments for our Clients’ portfolios, we might choose mutual funds on your account
Custodian’s Non-Transaction Fee (NTF) list. This means that your account Custodian will not charge a transaction
fee or commission associated with the purchase or sale of the mutual fund.
The mutual fund companies that choose to participate in the Client’s Custodial NTF fund program pay a fee to
the Custodian to be included in the NTF program. The mutual fund owners bear the fee that a company pays to
participate in the program, as captured in the fund’s expense ratio. When choosing a fund from the Client’s
Custodial NTF list, our Firm considers the expected holding period, position size, and expense ratio versus
alternative funds. Depending on our Firm’s analysis and future events, NTF funds might not always be in the
Client’s best interest.
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ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
Performance-based fees are based on a share of capital gains on or appreciation of the assets in a Client’s
account.
Our Firm does not accept performance-based or other fees based on a share of capital gains or appreciation of
a Client's assets.
ITEM 7 - TYPES OF CLIENTS
Our Firm provides investment management, investment advice, financial planning, consulting and advisement,
and third-party portfolio management to individuals, high-net-worth individuals, families, trusts, retirement
plans, corporations, charitable foundations, and pension plans.
For fee calculation purposes, unless instructed otherwise, we will automatically aggregate related client
accounts, a practice commonly known as "householding" portfolios. Householding may result in lower fees than
if each account were billed separately, as the combined value is used to determine the account size and the
corresponding annualized fee.
Our approach to householding considers the overall family dynamic and relationship. Additionally, if applicable,
and as noted in Appendix B of the Investment Management Agreement, legacy positions may be excluded from
the fee calculation.
Clients must execute a written agreement with our Firm specifying the advisory services to establish a Client
arrangement with us.
ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS
METHODS OF ANALYSIS
Our Investment Advisory Representatives will generally use the following analysis methods to formulate our
investment advice and manage Client assets. However, each IAR can manage its Client’s account as necessary,
and their specific analysis method may vary from below. Clients should acknowledge that investing in securities
involves the risk of loss, regardless of the strategies, that Clients should be prepared to bear.
FUNDAMENTAL
Fundamental analysis attempts to identify stocks offering sturdy growth potential at a competitive price by
examining the underlying company's business and conditions within its industry or the broader economy.
Investors have traditionally used fundamental analysis for longer-term trades, relying on metrics such as earnings
per share, price-to-earnings ratio, price-to-earnings growth, and dividend yield.
MODEL MANAGER
Our Firm examines the Manager's experience, expertise, investment philosophies, and past performance to
determine if that Manager has demonstrated an ability to invest over time and in different economic conditions.
Our Firm monitors the Manager’s underlying holdings, strategies, concentrations, and leverage as part of our
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Firm’s periodic risk assessment. Additionally, as part of our due diligence process, our Firm surveys the
Manager’s compliance and business enterprise risks.
MUTUAL FUND OR ETF
Our Firm examines the experience and track record of the Manager of the mutual fund or ETF to determine if
that Manager has demonstrated an ability to invest over a period of time and in different economic conditions.
Our Firm also looks at the underlying assets in a mutual fund or ETF to determine if there is a significant overlap
in the underlying investments held in other funds in the Client’s portfolio. Our Firm also monitors the funds or
ETFs to determine if they continue to follow their stated investment strategy.
QUANTITATIVE
Our Firm uses a proprietary optimization model that takes historical price performance, quantitative risk metrics,
and several other data points as inputs and attempts to recommend securities that will enhance the overall risk-
reward characteristic of the whole portfolio.
RISKS FOR ALL FORMS OF ANALYSIS
Our Firm’s securities analysis method relies on the assumption that the companies whose securities we purchase
and sell, the rating agencies that review these securities, and other publicly available sources of information
about these securities, are providing accurate and unbiased data. While we are alert to indications that data
may be incorrect, there is always a risk that the analysis may be compromised by inaccurate or misleading
information.
INVESTMENT STRATEGIES
Our Firm may use any of the following investment strategies when managing Client assets and providing
investment advice:
LONG-TERM HOLDING
Our Firm purchases securities with the intent to hold them in the Client's account long-term (longer than one
year). In extreme circumstances, we may be forced to sell a fund completely within a year of buying it. An
example would be a fund Manager resigns, and we do not have confidence in the new management. Also, fund
positions may be trimmed occasionally to rebalance the portfolio.
A risk in a long-term purchase strategy is that holding the security for this length of time may decline in value
before we decide to sell. We do not guarantee the future performance of the account or any specific level of
performance, the success of any investment decision or strategy we may use, or the success of the overall
management of the account. The Client understands that the investment decisions our Firm makes for the
Client’s account are subject to various market, currency, economic, political, and business risks and that those
investment decisions will not always be profitable. Clients are reminded that investing in any security entails the
risk of loss, which they should be willing to bear.
STRATEGIC ASSET ALLOCATION
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The primary investment strategy used by our Firm is based on the diversification of the Client's assets among
various investment vehicles and asset classes, popularly termed "Asset Allocation." Our Firm's recommendations
focus primarily on achieving a diversified portfolio of investment assets with desirable risk and return
characteristics. We meet regularly to evaluate new and reevaluate existing investment opportunities. During
these meetings, we deliberate on issues regarding the proper allocation of Client assets based on current
conditions.
TACTICAL ASSET ALLOCATION
Tactical asset allocation is an active management portfolio strategy that shifts the percentage of assets held in
various categories to take advantage of market pricing anomalies or strong market sectors. This strategy allows
portfolio Managers to create extra value by taking advantage of certain situations in the marketplace. It is a
moderately active strategy since Managers return to the portfolio's original asset mix once reaching the desired
short-term profits.
VALUE INVESTING
Value investing is buying stocks that trade at a significant discount to their intrinsic value. Value investors achieve
this by looking for companies on cheap valuation metrics, typically low multiples of their profits or assets, for
reasons not justified over the longer term. This approach requires a contrarian mindset and a long-term
investment horizon.
Value investing seeks to exploit the irrational behavior of emotional investors. Emotion is a constant feature of
investment markets through time. While the companies available to stock market investors change from decade
to decade, the human nature of the investors does not. Fear and greed remain ever-present and frequently lead
to poor investment decisions based on perception and emotion rather than reality. Periodically these miss
pricings can become extreme (e.g., the tech bubble of the 1990s or, conversely, the great depression of the
1930s); however, they exist to a greater or lesser extent in most markets. This creates an opportunity for long-
term value investors.
USE OF ALTERNATIVE INVESTMENTS
If deemed appropriate for your portfolio, our Firm may recommend "alternative investments.” Alternative
investments may include a broad range of underlying assets including hedge funds, private equity, venture
capital, registered, publicly traded securities, structured notes, and private real estate investment trusts.
Alternative investments are speculative, not suitable for all Clients, and intended for only experienced and
sophisticated investors who are willing to bear the high risk of the investment, which can include: loss of all or a
substantial portion of the investment due to leveraging, short-selling, or other speculative investment practices;
lack of liquidity in that there may be no secondary market for the fund and none expected to develop; volatility
of returns; potential for restrictions on transferring an interest in the fund; potential lack of diversification and
resulting higher risk due to concentration of trading authority with a single adviser; absence of information
regarding valuations and pricing; potential for delays in tax reporting; less regulation and often higher fees than
other investment options such as mutual funds. The SEC requires investors to be accredited to invest in these
more speculative alternative investments. Investing in a fund concentrating on a few holdings may involve
heightened risk and greater price volatility.
DESCRIPTION OF MATERIAL, SIGNIFICANT OR UNUSUAL RISKS
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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 Asset Management and Comprehensive Portfolio Management services, as
applicable.
RISK OF LOSS
A Client’s investment portfolio is affected by general economic and market conditions, such as interest rates,
availability of credit, inflation rates, economic conditions, changes in laws, and national and international political
circumstances.
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Our Firm will assist Clients in determining an appropriate
strategy based on their tolerance for risk.
While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.
ACTIVE MANAGEMENT RISK
Due to its active management, a portfolio could underperform other portfolios with similar investment objectives
or strategies.
ALLOCATION RISK
A portfolio may use an asset allocation strategy to pursue its investment objective. There is a risk that a portfolio’s
allocation among asset classes or investments will cause a portfolio to lose value or cause it to underperform
other portfolios with a similar investment objective or strategy or that the investments themselves will not
produce the returns expected.
ALTERNATIVE RISK
Alternative investments include other additional risks. Lock-up periods and other terms obligate Clients to
commit their capital investment for a minimum period, typically no less than one or two years and sometimes up
to 10 or more years. Illiquidity is considered a substantial risk and will restrict the ability of a Client to liquidate
an investment early, regardless of the success of the investment. Alternative investments are difficult to value
within a Client’s total portfolio. There may be limited availability of suitable benchmarks for performance
comparison; historical performance data may also be limited.
In some cases, there may be a lack of transparency and regulation, providing an additional layer of risk. Some
alternative investments may involve the use of leverage and other speculative techniques. As a result, some
alternative investments may carry substantial additional risks, resulting in the loss of some or all the investment.
Using leverage and certain other strategies will result in adverse tax consequences for tax-exempt investors,
such as the possibility of unrelated business taxable income, as defined under the U.S. Internal Revenue Code.
CAPITALIZATION RISK
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Small-cap and mid-cap companies may be hindered due to limited resources or less diverse products or services.
Their stocks have historically been more volatile than the stocks of larger, more established companies.
CALL RISK
Some bonds allow the issuer to redeem the bond before its maturity date. If an issuer exercises this option
during declining interest rates, the proceeds from the bond may have to be reinvested in an investment offering
a lower yield and may not benefit from an increase in value due to declining rates. Callable bonds are also
subject to increased price fluctuations during market illiquidity or rising interest rates. Finally, the capital
appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above
the price at which the issuer may call the bond.
COMPANY RISK
The risk related to a Firm’s business plans, stock valuation, profitability, accounting practices, growth strategy,
and other factors particular to a company rather than the overall market. Some of these risks cannot be predicted,
such as the retirement or death of a senior executive, which may lead to negative performance in the future.
CONCENTRATION RISK
Strategies concentrated in only a few securities, sectors or industries, regions or countries, or asset classes could
expose a portfolio to greater risk. They may cause the portfolio value to fluctuate more widely than a diversified
portfolio. Overexposure to certain sectors or asset classes (e.g., MLPs, REITs, etc.) may be detrimental to an
investor if there is a negative sector move.
CREDIT RISK
The credit rating of an issuer of a security is based on, among other things, the issuer’s historical financial
condition and the rating agencies’ investment analyses at the time of rating. An actual or perceived deterioration
of the ability of an issuer to meet its obligations would harm the value of the issuer’s securities.
CURRENCY RISK
If an account invests directly in non-U.S. currencies or in securities that trade in and receive revenues in non-U.S.
currencies or in derivatives that provide exposure to non-U.S. currencies, it will be subject to the risk that those
currencies will decline in value relative to the U.S. dollar. Currency rates in foreign countries may fluctuate
significantly over short periods for several reasons, including changes in interest rates, intervention (or the failure
to intervene) by U.S. or foreign governments, central banks, or supranational entities such as the International
Monetary Fund, or by the imposition of currency controls or other political developments in the United States
or abroad. As a result, an account’s investments in non-U.S. currency-denominated securities may reduce the
account's returns. Foreign currency exchange transactions are conducted on a spot (i.e., cash) basis at the spot
rate prevailing in the foreign currency exchange market or through entering forward contracts to purchase or
sell the currency.
CYBERSECURITY RISK
Increased Internet use makes a portfolio susceptible to operational and informational security risks. In general,
cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include but are not
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limited to infection by computer viruses or other malicious software code, gaining unauthorized access to
systems, networks, or devices through “hacking” or other means to misappropriate assets or sensitive
information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches of third-party
service providers may cause disruptions at third-party service providers and impact our business operations,
potentially resulting in financial losses; the inability to transact business; violations of applicable privacy and
other laws, regulatory fines, or penalties; reputational damage; unanticipated expenses or other compensation
costs; or additional compliance costs. Our Firm has an established business continuity and disaster recovery plan
and related cybersecurity procedures designed to prevent or reduce the impact of such risks; there are inherent
limitations in such plans and systems due in part to the evolving nature of technology and cyberattack tactics.
EQUITY RISK
Equity instruments are subject to equity market risk, the risk that common stock prices fluctuate over short or
extended periods. Equity securities have greater price volatility than fixed-income securities. The market price
of equity securities may increase or decrease, sometimes rapidly or unpredictably. Equity securities may decline
in value due to factors affecting markets, industries, sectors or geographic regions represented in those markets,
or individual security concerns.
EVENT RISK
The possibility is that an unforeseen event will negatively affect a company or industry and, thus, increase security
volatility.
ETF & ETN RISK
ETFs and ETNs are, by definition, portfolios of securities. Although the unsystematic risk associated with
investments in ETFs and ETNs may be low relative to investments in securities of individual issuers, some events
can trigger sharp, and sometimes adverse, price movements in ETFs and ETNs unrelated to the markets' general
activities. These events include unexpected dividends, changes to regular dividend amounts, announcements
of rights offerings, and possible unexpected revisions to the net asset values of the ETF and ETN. ETFs are
subject to market risk, whereas ETNs are subject to both market risk and the credit risk of the issuer of the ETN.
Further, certain Client accounts may hold (or short-sell) positions in volatility-related ETFs and ETNs. Leveraged
ETFs and mutual funds, sometimes labeled “ultra” or “2x,” for example, are designed to provide a multiple of
the underlying index’s return, typically daily. Inverse products are designed to provide the opposite of the
underlying index's return, typically daily. These products differ and can be riskier than traditional ETFs and
mutual funds. Although these products are designed to provide returns that correspond to the underlying index,
they may not be able to exactly replicate the performance of the index because of fund expenses and other
factors. This is referred to as a tracking error. Continual re-setting of returns within the product may add to the
underlying costs and increase the tracking error. As a result, this may prevent these products from achieving
their investment objective. In addition, compounding of the returns can produce a divergence from the
underlying index over time, particularly for leveraged products. Return distortions may be magnified in highly
volatile markets with significant positive and negative swings. Some deviations from the stated objectives to the
positive or negative are possible and may or may not correct themselves over time. These products use various
strategies to accomplish their objectives, including swaps, futures contracts, and other derivatives. These
products may not be diversified and can be based on commodities or currencies. These products may have
higher expense ratios and be less tax-efficient than more traditional ETFs and mutual funds.
FIXED INCOME & DEBT RISK
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Debt securities are affected by changes in interest rates. When interest rates rise, the value of debt securities is
likely to decrease. Conversely, when interest rates fall, the values of debt securities are likely to increase. The
values of debt securities may also be affected by changes in the issuing entities' credit rating or financial
condition.
FREQUENT TRADING RISK
A portfolio Manager may actively and frequently trade investments in a portfolio to carry out its investment
strategies. Frequent trading of investments increases the possibility that a portfolio, as relevant, will realize
taxable capital gains (including short-term capital gains, which are typically taxable at higher rates than long-
term capital gains for U.S. federal income tax purposes), which could reduce a portfolio's after-tax return.
Frequent trading can also mean higher brokerage and other transaction costs, which could reduce a portfolio's
return. The trading costs and tax effects of portfolio turnover can adversely affect its performance.
INDUSTRY OR SECTOR RISK
An account that focuses its investments in specific industries or sectors is more susceptible to developments
affecting those industries and sectors than a more broadly diversified fund. Issuers in a single industry can react
similarly to market, economic, industry, social, political, regulatory, and other conditions. For example, suppose
an account has significant investments in technology companies. In that case, the account may perform poorly
during a downturn in one or more industries or sectors that heavily impact technology companies.
INTEREST RATE RISK
When interest rates increase, the value of the account’s investments may decline, and the account’s share value
may decrease. This effect is typically more pronounced for intermediate and longer-term obligations. This effect
is also typically more pronounced for mortgages and other asset-backed securities since the value may fluctuate
more significantly in response to interest rate changes. When interest rates decrease, the account’s current
income may decline.
ISSUER RISK
The risk is that an issuer of a security may perform poorly, and therefore, the value of its securities may decline.
Poor management decisions, competitive pressures, technological breakthroughs, reliance on suppliers, labor
problems or shortages, corporate restructurings, fraudulent disclosures, natural disasters, or other events,
conditions, or factors may cause inferior performance.
LEGACY HOLDING RISK
Investment advice may be offered on any investment a Client holds at the start of the advisory relationship.
Depending on tax considerations and Client sentiment, these investments will be sold over time, and the assets
invested in the appropriate strategy. As with any investment decision, there is the risk that timing with respect
to the sale and reinvestment of these assets will be less than ideal or even result in a loss to the Client.
LIQUIDITY RISK
Low trading volume, large positions, or legal restrictions are some conditions that could limit or prevent a
portfolio from selling securities or closing positions at desirable prices. Securities that are relatively liquid when
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acquired could become illiquid over time. The sale of any such illiquid investment might be possible only at
substantial discounts or might not be possible at all. Further, such investments may take more work to value.
MANAGEMENT RISK
An account is subject to the risk that judgments about the attractiveness, value, or potential appreciation of the
account’s investments may prove to be incorrect. If the selection of securities or strategies fails to produce the
intended results, the account could underperform other accounts with similar objectives and investment
strategies.
MARKET RISK
Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events
will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is
the risk that you will lose money, and your investment may be worth less upon liquidation. Due to a lack of
demand in the marketplace or other factors, an account may only be able to sell some or all the investments
promptly or may only be able to sell assets at desired prices.
MUNICIPAL BOND RISK
Investments in municipal bonds are affected by the municipal market and the factors in the cities, states, or
regions where the strategy invests. Issues such as legislative changes, litigation, business and political conditions
relating to a particular municipal project, municipality, state, or territory, and fiscal challenges can impact the
value of municipal bonds. These matters can also impact the ability of the issuer to make payments. Also, the
public information about municipal bonds is less than that for corporate equities or bonds. Additionally, supply
and demand imbalances in the municipal bond market can cause deterioration in liquidity and a lack of price
transparency.
MUTUAL FUND OR ETF RISK
Our models and accounts may use certain ETFs and mutual funds to invest primarily in alternative investments
or strategies. Investing in these alternative investments and strategies may only be suitable for some of our
Clients. These include special risks, such as those associated with commodities, real estate, and leverage, selling
securities short, use of derivatives, potential adverse market forces, regulatory changes, and potential ill-liquidity.
Special risks are associated with ETFs that invest principally in real estate securities, such as sensitivity to changes
in real estate values or changes in interest rates and price volatility due to the ETF’s concentration in the real
estate market.
The risks with mutual funds include the costs and expenses within the fund that can impact performance, change
of Managers, and the fund straying from its objective (i.e., style drift). Mutual funds have certain costs associated
with underlying transactions and operating costs, such as marketing and distribution expenses and advisory fees.
Mutual fund costs and expenses vary from fund to fund and will impact a mutual fund’s performance.
Additionally, mutual funds typically have different share classes, as further discussed below, that trade at different
Net Asset Values (“NAV”) as determined at the daily market close and have different fees and expenses.
NON-LIQUID ALTERNATIVE INVESTMENT RISK
From time to time, our Firm will recommend to certain qualifying Clients that a portion of such Clients’ assets
be invested in private funds, private fund-of-funds, or other alternative investments (collectively, “Non-liquid
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Alternative Investments”). Non-liquid Alternative Investments are not suitable for all our Firm’s Clients. They are
offered only to those qualifying Clients for whom our Firm believes such an investment is suitable and in line
with their overall investment strategy. Non-liquid Alternative Investments typically are available to only a limited
number of sophisticated investors who meet the definition of “accredited investor” under Regulation D of the
Securities Act of 1933, as amended (the “Securities Act”), or “qualified Client” under the Investment Advisers
Act of 1940 or “qualified purchaser” under the Investment Company Act of 1940. Non-liquid Alternative
Investments present special risks for our Firm’s Clients, including, without limitation, limited liquidity, higher fees
and expenses, volatile performance, no assurance of investment returns, heightened risk of loss, limited
transparency, additional reliance on underlying management of the investment, special tax considerations,
subjective valuations, use of leverage and limited regulatory oversight. When a Non-liquid Alternative
Investment invests part or all of its assets in real estate properties, there are additional risks that are unique to
real estate investing, including but not limited to: limitations of the appraisal value, the borrower’s financial
conditions (if a loan has obtained the underlying property), including the risk of foreclosures on the property;
neighborhood values; the supply of and demand for properties of like kind; and certain city, state or federal
regulations.
Additionally, real estate investing is also subject to possible loss due to uninsured losses from natural and artificial
disasters. The above list is not exhaustive of all risks related to an investment in Non-liquid Alternative
Investments. A more comprehensive discussion of the risks associated with a particular Non-liquid Investment is
set forth in that fund’s offering documents, which will be provided to each Client subscribing to a Non-liquid
Alternative Investment for review and consideration. It is important that each potential, qualified investor
carefully read each offering or private placement memorandum before investing.
OPTIONS RISK
Transactions in options carry a high degree of risk. A small market movement will have a proportionately larger
impact, which may work for or against the investor. The placing of certain orders, which are intended to limit
losses to certain amounts, may not be effective because market conditions may make it impossible to execute
such orders. Selling ("writing" or "granting") an option entails greater risk than purchasing options. Although
the premium received by the seller is fixed, the seller may sustain a loss well more than that amount. The seller
will also be exposed to the risk of the purchaser exercising the option and will be obliged to settle it in cash or
to acquire or deliver the underlying investment. The risk may be reduced if the option is "covered" by the seller
holding a corresponding position in the underlying investment or a future on another option.
PERFORMANCE OF UNDERLYING MANAGER RISK
We select the mutual funds and ETFs in the asset allocation portfolios. However, we depend on the Manager of
such funds to select individual investments in accordance with their stated investment strategy.
PREPAYMENT RISK
Like call risk, this risk is associated with the early unscheduled principal repayment on a fixed-income security.
When the principal is returned early, future interest payments will not be paid. The proceeds from the repayment
may be reinvested in securities at a lower prevailing rate.
REAL ESTATE SECURITIES AND RELATED DERIVATIVES RISK
The Fund may gain exposure to the real estate sector by investing in real estate-linked derivatives, REITs, and
common, preferred, and convertible securities of issuers in real estate-related industries. Each of these types of
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investments are subject to risks similar to those associated with direct ownership of real estate, including loss to
casualty or condemnation, increases in property taxes and operating expenses, zoning law amendments,
changes in interest rates, overbuilding and increased competition, variations in market value, and possible
environmental liabilities.
REITs are subject to management fees and other expenses, and so the Fund, when investing in REITs, will bear
its proportionate share of the costs of the REITs’ operations. An investment in a REIT or a real estate-linked
derivative instrument that is linked to the value of a REIT is subject to additional risks, such as inferior
performance by the manager of the REIT, adverse changes to the tax laws or failure by the REIT to qualify for
tax-free pass-through of income under the Code. In addition, some REITs have limited diversification because
they invest in a limited number of properties, a narrow geographic area, or a single type of property.
Furthermore, REITs are not diversified because they only operate in the real estate business and are heavily
dependent on cash flow. Also, the organizational documents of a REIT may contain provisions that make changes
in control of the REIT difficult and time-consuming.
REINVESTMENT RISK
The possibility of investing a bond’s cash flows at a rate lower than the expected rate of return assumed at the
time of buying the bond. Reinvestment risk is high for bonds with long maturities and high coupons.
SECTOR RISK
The danger is that the stocks of many companies in one sector (like health care or technology) will fall in price
simultaneously because of an event that affects the entire industry.
SECURITIES LENDING RISK
Securities lending involves the risk that the fund loses money because the borrower fails to return the securities
promptly. The fund could also lose money if the value of the collateral provided for loaned securities, or the
value of the investments made with the cash collateral, falls. These events could also trigger adverse tax
consequences for the fund.
SHORT SALE RISK
A short sale is affected by selling a security that the seller does not own or selling a security that the seller owns
but which it does not deliver upon consummation of the sale. To make delivery to the buyer of a security sold
short, the prime broker or Custodian must borrow the security on behalf of the seller. In so doing, it incurs the
obligation to replace that security, whatever its price may be, at the time it is required to deliver it to the lender.
The seller must also pay to the lender of the security any dividends or interest payable on the security during
the borrowing period and may have to pay a premium to borrow the security. This obligation must, unless the
seller then owns or has the right to obtain, without payment, securities identical to those sold short, be
collateralized by a deposit of cash or marketable securities with the lender. Short selling is subject to the
theoretically unlimited risk of loss because there is no limit on how much the price of a security may appreciate
before the “short” position is closed out.
Further, short sales of securities involve a form of investment leverage, and the amount of the portfolio’s
potential loss is theoretically unlimited. See Borrowing and Leverage Risk.
SOCIALLY RESPONSIBLE INVESTING & ESG RISK
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Clients utilizing responsible investing strategies and environmental, social responsibility, and corporate
governance (ESG) factors may underperform strategies that do not utilize responsible investing and ESG
considerations. Responsible investing and ESG strategies may operate by excluding certain issuers' investments
or by selecting investments based on compliance with factors such as ESG. This strategy may exclude certain
sectors or industries from a Client’s portfolio, potentially negatively affecting the Client’s investment
performance if the excluded sector or industry outperforms. Responsible investing and ESG are subjective by
nature. Our Firm may rely on analysis and ‘scores’ provided by third parties in determining whether an issuer
meets our Firm’s standards for inclusion or exclusion. A Client’s perception may differ from our Firm or a third
party on how to judge an issuer's adherence to responsible investing principles.
In particular, Elevate uses Biblically Responsible Investing (BRI). The idea of BRI is to invest with the “good” and
steer clear of those investments that go against biblical principles. We use these strategies for our client who
desire to invest in a manner that aligns with the morals and beliefs.
TIMING RISK
The risk is that the investment needs to perform better after its purchase or sale. Moreover, if the Client requires
redemption, the Client may face a loss due to poor overall market performance or security performance at that
time.
VALUE INVESTING RISK
Value investing risk is the risk that value stocks do not increase in price, not issue the anticipated stock dividends,
or decline in price, either because the market fails to recognize the stock’s intrinsic value or because the expected
value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those
securities might not appreciate as anticipated. They also may decline in price even though they are already
undervalued in theory. Value stocks are typically less volatile than growth stocks but may lag behind growth
stocks in an up market.
ITEM 9 - DISCIPLINARY INFORMATION
Registered investment advisers are required to provide information about all disciplinary information that would
be material to a Client’s evaluation of our Firm or the integrity of its management. Clients should refer to the
Advisor’s Form ADV Part 2B Brochure Supplement. If the Client did not receive the Advisor’s Form ADV Part 2B
Brochure Supplement, the Client should contact the Chief Compliance Officer using the information provided
on the cover page of this Brochure. Our Chief Compliance Officer is available to address any questions a Client
or prospective client may have regarding the above or any information outlined in this Brochure.
Our Firm has no legal or disciplinary events that are material to a Client or prospective clients, evaluation of our
advisory business, or the integrity of our management services.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS
INDUSTRY ACTIVITIES
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Clients should review our IARs Form ADV Part 2B Brochure Supplement to determine whether the Client’s IAR
is engaged in any of the activities described below that may create a conflict of interest. If the Client did not
receive the Advisor’s Form ADV Part 2B Brochure Supplement, the Client should contact the Firm’s Chief
Compliance Officer using the information on the cover page of this Brochure. The Chief Compliance Officer is
available to address any questions a Client or prospective client may have regarding any of the below conflicts
of interest, or any other information outlined in this Brochure.
INSURANCE COMPANIES
In their individual capacities, some of our Firm’s IARs are agents for various third-party insurance companies. As
such, these individuals may receive separate yet customary commission compensation for implementing product
transactions on our advisory Clients' behalf. Clients, however, are not obligated to engage IARs when
considering implementing advisory or insurance recommendations. Implementing any or all recommendations
is solely at the Client's discretion.
PERSONAL RELATIONSHIPS
From time to time, our firm may provide investment advisory services to individuals with whom our personnel
have personal relationships, such as friends or family members. These relationships may include jointly held
accounts, informal financial assistance, or investment management services provided at a reduced or waived
fee.
While these accounts are subject to the same investment process, policies, and procedures as all other client
accounts, there is a potential for perceived or actual conflicts of interest, including the possibility of preferential
treatment or allocation of investment opportunities. To address this, we monitor and supervise these accounts
as we would any other client account, and any deviations in treatment (e.g., fees or access to products) are
documented and reviewed by the Chief Compliance Officer.
Our policies prohibit favoritism and require that investment decisions be made in the best interest of each client,
regardless of relationship status.
SEMINARS & WORKSHOPS
Occasionally, our IARs may present financial or investment-related seminars to educate our Clients and the
general investing public. The seminar materials and any handouts provided may be prepared by an IAR or an
unaffiliated publisher or distributor of investment seminar materials. The materials presented at the seminars
and in general are intended to be purely educational. Neither the information discussed at seminars nor
contained in the seminar materials, or any handouts, is intended as specific investment advice to any individual,
Client, or prospective client. We do not represent that any information provided during a seminar will be
appropriate for your situation or help you meet your financial goals or objectives.
Client attendance at a seminar can be done without completing an Investment Advisory Agreement with our
IAR. If you attend a seminar, you are considered a prospective client only for the seminar's purposes. You can
cease to be our prospective client following the seminar's conclusion unless you subsequently engage us to
provide additional advisory services through the execution of an Investment Advisory Agreement.
OTHER FINANCIAL AFFILIATIONS
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Elevate is under common ownership with, or otherwise affiliated with, Frontier Asset Management, an investment
adviser registered with the U.S. Securities and Exchange Commission. Although both firms are separately
registered and operate independently, certain supervised persons of Elevate may also be associated with
Frontier Asset Management in dual roles, or may refer clients between firms when such referrals are deemed
appropriate and consistent with the client’s best interests.
This affiliation presents a potential conflict of interest, as it creates an incentive to favor one affiliated firm over
another when making recommendations or referrals. Elevate addresses these conflicts by maintaining policies
and procedures designed to ensure that any such recommendations are made in accordance with each client’s
investment objectives, and that clients are fully informed of any material conflicts.
Clients are under no obligation to utilize the services of Frontier Asset Management, and no preferential
treatment is given to affiliated clients in terms of fees, access, or services unless otherwise disclosed in writing
and agreed upon by the client.
OTHER FINANCIAL INDUSTRY ACTIVITIES
Our Firm, and our IARs, do not have a related company that is a (1) broker-dealer, municipal securities dealer,
government securities dealer or broker, (2) investment company or other pooled investment vehicle (including
a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge
fund,” and offshore fund), (3) other investment adviser or financial planner, (4) futures commission merchant,
commodity pool operator, or commodity trading advisor, (5) banking or thrift institution, (6) accountant or
accounting firm, (7) lawyer or law firm, (8) insurance company or agency, (9) pension consultant, (10) real estate
broker or dealer, or (11) sponsor or syndicator of limited partnerships.
ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT
TRANSACTIONS, & PERSONAL TRADING
Our Firm maintains a Code of Ethics to reinforce the fiduciary principles governing our Firm and its employees.
The Code, among other things, requires all employees to act with integrity and ethics, and professionalism.
Policies against overreaching, self-dealing, insider trading, and conflicts of interest are outlined in our Code. Our
Code forbids employees from trading, either personally or on behalf of others, based on non-public material
information or communicating non-public material information to others violating the law.
Additionally, our Code sets forth restrictions and quarterly attestations on receiving gifts, outside business
activities, personal trading activity, maintenance of personal brokerage accounts, and other matters. The Code
is appropriately designed and implemented to prevent or eliminate potential conflicts of interest between our
Firm, our employees and IARs, Clients, and investors. We always strive to make decisions in our Client's best
interest should a conflict of interest arise.
Clients should be aware that no set of rules, policies, or procedures can anticipate, avoid, or address all potential
conflicts of interest.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING
Our employees, IARs, and our associated persons are not prohibited from owning or trading securities bought,
sold, and recommended to our Clients, provided such personal trading activity complies with the parameters,
limitations, and requirements of the Code. Employees, IARs, and associated persons must receive approval from
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our Firm’s CCO when engaging in reportable securities transactions. Our CCO is responsible for reviewing all
employees', IARs, and associated persons' trading when they occur and periodically reviewing trading activity.
Our CCO has broad discretion to reject employee trading for any reason. Our Firm’s policies and procedures
related to the personal trading activity of employees aim to demonstrate our commitment to placing Clients’
interests ahead of our trading interests.
While our Firm does not maintain a proprietary trading account and therefore does not have a direct material
financial interest in any securities it recommends to Clients, in certain situations, our Firm’s employees and
associated persons may purchase interests in the same securities at the same or different portfolio percentages
or risk levels, in which one or more Clients is investing or has invested. Conversely, a Client may purchase
interests in security where our employees, IARs, and associated persons are investing or have invested.
Any exceptions to the Code require the prior approval of the CCO. We will provide a copy of the Code to any
Client or prospective client upon such written or verbal request. Such requests should be directed to our Firm’s
CCO at the contact information listed in Item 1 - Cover Page of this Brochure.
ITEM 12 - BROKERAGE PRACTICES
INVESTMENT MANAGEMENT SERVICES
Clients must maintain assets in an account with a “qualified Custodian,” a broker-dealer or bank. If our Firm is
asked to give a recommendation, our recommendation is based on the broker’s cost and fees, skills, reputation,
dependability, and compatibility with the Client. The Client may obtain lower commissions and fees from other
brokers.
FIDELITY INSTITUTIONAL,CHARLES SCHWAB & CO. INC. & ALTRUIST
Elevate Wealth Management will recommend Custodians. We recommend that our clients use Fidelity Advisor
Services™ (formerly called Fidelity Institutional®) (“Fidelity”), Charles Schwab & Co., Inc. Advisor Services
(“Schwab”), a registered broker-dealer, member SIPC, or Altruist Financial, LLC (“Altruist”) as the qualified
custodian. We are independently owned and operated, and unaffiliated with Fidelity, Schwab or Altruist. Our
custodians will hold client assets in a brokerage account and buy and sell securities when we instruct them to.
We have selected our Custodians based on price, reliability, speed of processing, tools and “best execution” in
addition to other considerations. And while you are not required to effect transactions through any broker-dealer
recommended by us, we feel we have made our selections based on a totality of benefits they offer and can
only offer our services based on our recommendations.
The Custodians send statements and confirms. We strongly urge you to compare our invoices and reports to
the custodian statements for accuracy.
Elevate Wealth Management may purchase software, tools, training programs or seminar services from our
broker- dealer. Elevate Wealth Management also receives soft dollar benefits from the Custodians. The
Custodians may provide services, tools, or other non-financial benefits to us as a benefit for using the custodian’s
services. However, we endeavor at all times to put the interests of our clients first. You should be aware,
however, that the receipt of the types of benefits discussed above can create a conflict of interest by influencing
our choice of a Custodian.
To avoid creating a conflict of interest in recommending custodians, we have established the following
restrictions in order to ensure its fiduciary responsibilities:
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• Elevate Wealth Management adheres to our Code of Ethics as outlined in Item 11 above.
•
If Elevate Wealth Management receives separate compensation for transactions, we will fully disclose
them.
• Elevate Wealth Management will always act in accordance with all applicable federal and state
regulations governing registered investment advisory practices.
• Elevate Wealth Management emphasizes that you always have the right to choose another investment
advisor to avoid any conflict of interest.
Elevate Wealth Management is authorized to aggregate purchases and sales and other transactions made for
your account with purchases and sales and other transactions in the same or similar securities or instruments for
other clients of ours. When we aggregate transactions, the actual prices applicable to the aggregated
transactions will be averaged, and the account will be deemed to have purchased or sold its proportionate share
of the securities or instruments involved at the average price obtained. Stock exchange regulations may in
certain instances prevent the executing broker-dealer from delivering to the account a confirmation slip with
respect to its participation in the aggregated transaction and, in such event, we will advise you in writing of any
purchase or disposition of instruments for the account with respect to any such aggregated transaction.
CLIENT BROKERAGE AND CUSTODY COSTS
For our clients’ accounts that our Custodians maintain, the Custodians generally do not charge separately for
custody services. However, the Custodians receive compensation by charging ticket charges, or other fees on
trades that it executes, or that settle into clients’ accounts. In addition to commissions, the Custodians charges
a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different
broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into
a client’s account. These fees are in addition to the ticket charges or other compensation the client pays the
executing broker-dealer. Because of this, in order to minimize trading costs, we have our Custodians execute
most trades for client accounts. We have determined that having the Custodians execute most trades is
consistent with our duty to seek “best execution” of client trades. Best execution means the most favorable
terms for a transaction based on all relevant factors, including those listed above (see How We Select
Brokers/Custodians).
PRODUCTS AND SERVICES AVAILABLE TO US
Our Custodians are in the business of serving independent investment advisory firms like us. They provide Fidelis
and our clients with access to its institutional brokerage, trading, custody, reporting, and related services, many
of which are not typically available to retail customers. Our Custodians also makes available various support
services. Some of those services help us manage or administer our clients’ accounts; others help us manage and
grow our business. Their support services generally are available on an unsolicited basis (we do not have to
request them) and at no charge to us. These are considered soft dollar benefits because there is an incentive to
do business with either Fidelity or Schwab. This creates a conflict of interest. We have established policies in
this regard to mitigate any conflicts of interest. We believe that our selection of Fidelity or Schwab as custodian
and broker is in the best interests of clients. Fidelis will at all times act in the best interest of their clients and act
as a fiduciary in carrying out services to clients. The following is a more detailed description of the Custodian’s
support services:
SERVICES THAT BENEFIT OUR CLIENTS
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Our Custodians services include access to a broad range of investment products, execution of securities
transactions, and custody of client assets. The investment products available include some to which we might
not otherwise have access or that would require a significantly higher minimum initial investment by our clients.
The services described in this paragraph generally benefit our clients and their accounts.
SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS
Our Custodians also make available other products and services that benefit us but may not directly benefit our
clients or their accounts. These products and services assist us in managing and administering our clients’
accounts. They include investment research, both their own and that of third parties. We may use this research
to service all or a substantial number of our clients’ accounts, including accounts not maintained at Fidelity or
Schwab. In addition to investment research, our Custodians also make available software and other technology
that:
• Provide access to client account data (such as duplicate trade confirmations and account statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
SERVICES THAT GENERALLY BENEFIT ONLY US
Our Custodians also offer other services intended to help us manage and further develop our business
enterprise.
These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
The may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide
the services to us. They may also discount or waive its fees for some of these services or pay all, or a part of, a
third party’s fees. Fidelity and Schwab may also provide us with other benefits, such as occasional business
entertainment of our personnel.
OUR INTEREST IN OUR CUSTODIAN’S SERVICES
The availability of these services from our Custodians benefits us because we do not have to produce or purchase
them. These services are not contingent upon us committing any specific amount of business to Fidelity and
Schwab in trading commissions. We believe that our selection of these custodians and brokers are in the best
interests of our clients.
Some of the products, services, and other benefits provided by the Custodians benefit Fidelis and may not
benefit our client accounts. Our recommendation or requirement that you place assets in Fidelity 's or Schwab’s
custody may be based in part on the benefits they provide to us or our agreement to maintain certain Assets
Under Management and not solely on the nature, cost, or quality of custody and execution services provided.
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We place trades for our clients' accounts subject to its duty to seek best execution and its other fiduciary duties.
Fidelity 's or Schwab’s execution quality may be different than other broker-dealers.
We do not routinely recommend, request, or require that you direct us to execute transactions through a
specified custodian. Additionally, we typically do not permit you to direct brokerage. We place trades for your
account subject to our duty to seek best execution and other fiduciary duties.
We will aggregate trades for ourselves or our associated persons with your trades, providing that the following
conditions are met:
• Our policy for the aggregation of transactions shall be fully-disclosed separately to our existing clients
(if any) and the broker/dealer(s) through which such transactions will be placed
• We will not aggregate transactions unless we believe that aggregation is consistent with our duty to
seek the best execution (which includes the duty to seek best price) for you and is consistent with the
terms of our investment advisory agreement with you for which trades are being aggregated
• No advisory client will be favored over any other client; each client that participates in an aggregated
order will participate at the average share price for all our transactions in a given security on a given
business day, with transaction costs based on each client’s participation in the transaction
• We will prepare a written statement (“Allocation Statement”) specifying the participating client accounts
and how to allocate the order among those clients
•
If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the
allocation statement; if the order is partially filled, the accounts that did not receive the previous trade’s
positions should be “first in line” to receive the next allocation
• Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in
the Allocation Statement if all client accounts receive fair and equitable treatment and the reason for
difference of allocation is explained in writing and is reviewed by our compliance officer. Our books
and records will separately reflect, for each client account, the orders of which aggregated, the securities
held by, and bought for that account
• We will receive no additional compensation or remuneration of any kind as a result of the proposed
aggregation; and
•
Individual advice and treatment will be accorded to each advisory client
BROKERAGE FOR CLIENT REFERRALS
Elevate Wealth Management does not receive economic benefits from third parties for the advice we render to
our clients. Elevate Wealth Management does not directly or indirectly compensate any person for client
referrals.
AGGREGATION AND ALLOCATION OF TRANSACTIONS
We may aggregate transactions if we believe that aggregation is consistent with the duty to seek best execution
for our clients and is consistent with the disclosures made to clients and terms defined in the client investment
advisory agreement. No advisory client will be favored over any other client, and each account that participates
in an aggregated order will participate at the average share price (per custodian) for all transactions in that
security on a given business day.
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If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro rata basis. If we
determine that a pro rata allocation is not appropriate under the particular circumstances, we will base the
allocation on other relevant factors, which may include:
• When only a small percentage of the order is executed, with respect to purchase allocations, allocations
may be given to accounts high in cash
• With respect to sale allocations, allocations may be given to accounts low in cash
• We may allocate shares to the account with the smallest order, or to 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
• We may allocate to one account when that account has limitations in its investment guidelines
prohibiting it from purchasing other securities that we expect to produce similar investment results and
that can be purchased by other accounts in the block
•
If an account reaches an investment guideline limit and cannot participate in an allocation, we may
reallocate shares to other accounts. For example, this may be due to unforeseen changes in an account’s
assets after an order is placed
•
If a pro rata allocation of a potential execution would result in a de Minimis allocation in one or more
accounts, we may exclude the account(s) from the allocation
• We will document the reasons for any deviation from a pro rata allocation.
TRADE ERRORS
We have implemented procedures designed to prevent trade errors; however, trade errors in client accounts
cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade errors in a manner
that is in the best interest of the client. In cases where the client causes the trade error, the client will be
responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade
error, the client may not be able to receive any gains generated as a result of the error correction. In all situations
where the client does not cause the trade error, the client will be made whole and we will absorb any loss
resulting from the trade error if the error was caused by the Firm. If the error is caused by the Custodian, the
Custodian will be responsible for covering all trade error costs. If an investment gain results from the correcting
trade, the gain will be donated to charity. We will never benefit or profit from trade errors.
DIRECTED BROKERAGE
We do not routinely recommend, request, or require that you direct us to execute transaction through a specified
broker dealer. Additionally, we typically do not permit you to direct brokerage. We place trades for your account
subject to our duty to seek best execution and other fiduciary duties.
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific
broker or dealer to obtain goods or services on the plan's behalf. Such direction is permitted provided that the
goods and services provided are reasonable expenses of the 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,
we 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.
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ITEM 13 - REVIEW OF ACCOUNTS
CLIENT REVIEWS
Our Firm reviews Client accounts and financial plans periodically. Our IARs will monitor Client accounts regularly
and perform annual reviews with each Client. All accounts are reviewed for consistency with Client investment
strategy, asset allocation, risk tolerance, and performance. More frequent reviews may be triggered by changes
in an account holder’s personal, tax, or financial status. Geopolitical and macroeconomic-specific events may
also trigger reviews. Our recommendations depend on the information provided by the Client. Our Client must
notify our Firm of any situation that would impair our ability to manage our Client accounts properly.
The Client receives a copy of each trade confirmation (unless the Client has authorized the Custodian to suppress
the confirmations) and the standard written account statement from the qualified account Custodian every
quarter.
ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION
BROKERAGE PRACTICES
As disclosed under Item 12 Brokerage Practices, we participate in the Custodian’s institutional customer
programs, and we may recommend a Custodian to our Clients for custody and brokerage services. There is no
direct link between our participation in the program and the investment advice we give to our Clients. However,
we receive economic benefits through our participation in the program that is typically not available to any other
independent advisors participating in the program. These benefits include the following products and services
(provided without cost or at a discount):
• Receipt of duplicate Client statements and confirmations.
• Research-related products and tools.
• Consulting services.
• Access to a trading desk serving adviser participants.
• Access to block trading (which provides the ability to aggregate securities transactions for execution
and then allocate the appropriate shares to Client accounts);
• The ability to have advisory fees deducted directly from Client accounts.
• Access to an electronic communications network for Client order entry and account information.
• Access to mutual funds with no transaction fees and certain institutional money Managers.
• Discounts on compliance, marketing, research, technology, and practice management products or
services provided to us by third-party vendors.
Custodians may also have paid for business consulting and professional services received by some of our IARs.
Some of the products and services made available by Custodians through the program may benefit us but may
not benefit your account. These products or services may assist us in managing and administering Client
accounts, including accounts not maintained at our recommended Custodian. Other services made available by
the Custodian are intended to help us manage and further develop our business enterprise. The benefits our
Firm or our IARs receive through participation in the program do not depend on the amount of brokerage
transactions directed to the Custodian. Due to these arrangements, our Client does not pay more for assets
maintained at Schwab. As part of our fiduciary duties to Clients, we always endeavor to put our Client's interests
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first. Clients should be aware, however, that receiving economic benefits from our Firm or our IARs in and of
itself creates a conflict of interest because the cost of these services would otherwise be borne directly by us.
These arrangements could indirectly influence our choice of Custodian for custody and brokerage services.
Clients should consider these conflicts of interest when selecting a Custodian. The products and services
provided by the Custodian, how they benefit us, and the related conflicts of interest are described above.
LEAD GENERATION & REFERRALS
Effective November 4, 2022, our Firm adopted Rule 206(4)-1 under the Advisers Act, known as the new
“Marketing Rule.” All Client solicitation activity will comply with the provisions of the new Marketing Rule.
PROMOTERS
We may enter into agreements with individuals who will promote our Firm (“Promoters”). If a Client is introduced
to our Firm by a Promoter, we will pay that Promoter a referral fee per the requirements of Rule 206(4)-1 of the
Investment Advisers Act of 1940 and any corresponding state securities law requirements. Any referral fee will
be paid solely from advisory fees and will not incur additional charges to the Client. The Promoter, at the time
of the referral, will disclose the nature of the Promoter relationship and provide each prospective client with a
copy of the written disclosure statement from the Promoter to the Client disclosing the terms of the arrangement
between our Firm and the Promoter, including the compensation to be received by the Promoter from our Firm.
OTHER PROFESSIONALS
Our Firm may refer business to estate planning attorneys, accountants, insurance brokers, and other
professionals. However, we do not receive monetary or other material compensation for referring Clients to such
professionals. We also do not pay any person or firm commissions or other items of material value when referring
Clients to us. If we receive or offer an introduction to a Client, we do not pay or earn a referral fee, nor are there
established quid pro quo arrangements. Each Client can accept or deny such referral or subsequent services.
ITEM 15 - CUSTODY
Regulators have defined custody as having access or control over Client funds or securities. As it applies to our
Firm, we do not have physical custody of funds or securities.
FEE DEDUCTION
Our Firm is deemed to have constructive custody over those Client accounts where it can deduct our fees directly
from the Client account. If we comply with certain regulatory requirements, this constructive custody does not
mandate that our Firm undergo a surprise audit for those accounts. Our Clients receive account statements
directly from the qualified Custodian at least quarterly. Our Firm may send Clients quarterly reports that our Firm
produces using our portfolio accounting system, Tamarac or Advyzon.
We strongly urge our Clients to compare such reports with the statements received from the qualified Custodian.
Furthermore, when our Firm calculates our investment management fees and instructs the Custodian to remit
these fees to us directly from Clients’ accounts, the Custodian does not verify our calculation of fees. Our Firm
performs quarterly testing to ensure that our fees are charged per the Client’s Investment Advisory Agreement
on file with our Firm.
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STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Additionally, our Firm is deemed to have custody of the Client’s funds or securities when you have standing
authorizations with their Custodian to move money from your account to a third-party Standing Letter of
Authorization (“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of transfers
with the Custodian. The SEC has set forth standards to protect your assets in such situations, which we follow.
We do not have a beneficial interest in any of the accounts we are deemed to have Custody of where SLOAs
are on file. In addition, account statements reflecting all activity on the account(s) are delivered directly from the
qualified Custodian to each Client or the Client’s independent representative at least monthly. You should
carefully review those statements and are urged to compare the statements against reports received from us.
When you have questions about your account statements, contact us, your Advisor, or the qualified Custodian
preparing the statement.
ITEM 16 - INVESTMENT DISCRETION
DISCRETIONARY AUTHORITY
Upon receiving written authorization from the Client, our Firm provides discretionary investment advisory
services for Client accounts. For discretionary accounts, before engaging our Firm to provide investment
advisory services, you will enter into a written Investment Advisory Agreement with us granting our Firm the
authority to supervise and direct, on an ongoing basis, investments per the Client's investment objective and
guidelines. In addition, our Client will need to execute additional documents required by the Custodian to
authorize and enable our Firm, in its sole discretion, without prior consultation with or ratification by our Client,
to purchase, sell or exchange securities in and for your accounts. We are authorized, at our discretion and
without prior consultation with the Client, to (1) buy, sell, exchange, and trade any stocks, bonds, or other
securities or assets and (2) determine the amount of securities to be bought or sold and (3) place orders with the
Custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by you,
the Client.
The limitations on investment and brokerage discretion held by our Firm are:
• For discretionary accounts, we require that we be given the authority to determine which securities and
the amounts to be bought or sold.
• Any limitations on this discretionary authority shall be in writing as indicated in the Investment Advisory
Agreement. Clients may change or amend these limitations as required.
ITEM 17 - VOTING CLIENT SECURITIES
PROXY VOTING
Our Firm cannot vote for Client securities. Clients will receive proxies or other solicitations directly from the
Custodian or a transfer agent. Clients are responsible for obtaining and voting proxies for all securities
maintained in their portfolios. We may provide advice to you regarding your voting of proxies. Clients can
contact our Firm with any questions or concerns about a particular solicitation.
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CLASS ACTION LAWSUITS
Our Firm does not advise or instruct Clients on whether to participate as a member of class action lawsuits and
will not automatically file claims on the Client’s behalf. However, if a Client notifies us that they wish to participate
in a class action, we will provide the Client with transaction information about the Client’s account that is required
to file a proof of claim in a class action.
ITEM 18 - FINANCIAL INFORMATION
FINANCIAL CONDITION
Our Firm has no financial commitment that impairs its ability to meet Client contractual and fiduciary obligations
and has not been the subject of a bankruptcy proceeding. We do not require or solicit prepayment of more than
$1,200 in fees per Client six months or more in advance. Therefore, we are not required to include a balance
sheet for the most recent fiscal year.
ADDITIONAL INFORMATION
PRIVACY POLICY
Our Firm collects non-public personal information about Clients from information received on applications or
other forms and information about Client transactions with firm affiliates, others, or our Firm. We do not disclose
any nonpublic personal information about current or former Clients except as permitted by law or to provide
services. Firm employees have limited access to Clients' data based on their responsibilities to provide products
or services to Clients.
Our Firm maintains physical, electronic, and procedural safeguards in compliance with federal standards to
protect Client information. If the IAR servicing a Client account leaves our Firm to join another firm, the IAR is
not permitted to retain copies of specific Client information.
A copy of our Firm's Privacy Policy is given to each Client at account opening, upon request, and provided
annually.
OPTING OUT
If a Client does not want an IAR to retain copies of the Client's non-public personal information when the IAR
leaves our Firm to join another firm, the Client can contact our Compliance Department by calling 307.461.5550.
BUSINESS CONTINUITY PLAN
Our Firm has developed a Business Continuity Plan to address how our Firm will respond to events that
significantly disrupt the operation of our business. Since the timing and impact of disasters and disruptions are
unpredictable, our Firm will be flexible in responding to current events as they occur.
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Within 24 hours after a significant business disruption, our Firm plans to quickly recover and resume business
operations and respond by safeguarding employees and property, making a financial and operational
assessment, protecting our Firm’s books and records, and allowing Clients to transact business. Given the scope
and severity of the significant business disruption, our business continuity plan is designed to permit our Firm to
resume operations as quickly as possible.
Our Firm’s business continuity plan addresses: data back-up and recovery; all mission critical systems; financial
and operational assessments; alternative communications with customers, employees, and regulators; alternate
physical location of employees; critical supplier, contractor, bank, and counter-party impact; regulatory
reporting; and assuring Clients’ prompt access to their funds and securities if our Firm is unable to continue as
a business.
Our Firm backs up essential records in a geographically separate area. At the same time, every emergency poses
unique problems based on external factors, such as the time of day and the severity of the disruption. Its
objective is to restore operations and be able to complete existing transactions and accept new transactions
and payments within four hours of the disruptive event. Client orders and requests for funds and securities could
be delayed during this period.
CONTACTING US
If a Client cannot contact our Firm via 307.461.5550 after a significant business disruption, please visit the
website at https://www.elevateasset.com to review updated contact information.
VARYING DISRUPTIONS
Significant business disruptions can vary in scope, such as disruption that affects only our Firm, a single building
housing our Firm, the business district where our Firm is located, the city where our Firm is located, or the whole
region. Within each area, the disruption's severity can also vary from minimal to severe. In a disruption to only
our Firm or a building housing our Firm, our Firm will transfer operations to a local site when needed and expect
to recover and resume business within 24 hours.
In a disruption affecting our Firm’s business district, city, or region, our Firm will transfer operations to a site
outside the affected area and recover and resume business within three (3) days. In either situation, our Firm
plans to continue the business, transfer operations to its clearing firm if necessary, and provide Clients with
instructions on contacting our Firm through its company’s website: https://www.elevateasset.com. If the
significant business disruption is so severe that it prevents our Firm from remaining in business, our Firm will
ensure the Client’s prompt access to their funds and securities.
This information is provided solely to Clients of our Firm, and no further distribution or disclosure is permitted
without the prior written consent of our Firm. No person other than our Firm Clients can rely on any statement
herein. Our Firm’s Business Continuity Plan is reviewed and updated regularly and is subject to change.
Please visit the website at https://www.elevateasset.com for the most current copy of this disclosure. You can
request an updated copy by contacting our Firm at 307.461.5550 or writing our Firm at the following:
Elevate Wealth Management
50 E Loucks, Suite 125
Sheridan, WY 82801
307-461-5550
information@elevateasset.com
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https://www.elevateasset.com
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