Overview
- Headquarters
- Appleton, WI
- Average Client Assets
- $2.4 million
- SEC CRD Number
- 108652
Fee Structure
Primary Fee Schedule (ENDOWMENT WEALTH MANAGEMENT, INC. ADV BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $2,500,000 | 0.90% |
| $2,500,001 | $5,000,000 | 0.80% |
| $5,000,001 | $7,500,000 | 0.70% |
| $7,500,001 | $10,000,000 | 0.60% |
| $10,000,001 | $20,000,000 | 0.50% |
| $20,000,001 | $30,000,000 | 0.40% |
| $30,000,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $43,500 | 0.87% |
| $10 million | $76,000 | 0.76% |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- HNW Share of Firm Assets
- 56.87%
- Total Client Accounts
- 3,057
- Discretionary Accounts
- 2,401
- Non-Discretionary Accounts
- 656
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Pension Consulting, Investment Advisor Selection, Educational Seminars
Regulatory Filings
Primary Brochure: ENDOWMENT WEALTH MANAGEMENT, INC. ADV BROCHURE (2026-03-30)
View Document Text
Item 1 Cover Page
Endowment Wealth Management, Inc.
W6272 Communication Court
Appleton, Wisconsin 54914-8531
Phone: 920-785-6010
Fax: 920-227-0521
http://www.EndowmentWM.com
March 30, 2026
FORM ADV PART 2A
BROCHURE
This brochure provides information about the services, business practices, fees, and conflicts of
interest of Endowment Wealth Management, Inc. If you have any questions about the contents of this
brochure, please contact us at 920-785-6010. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission or by any state securities
authority.
Additional information about Endowment Wealth Management, Inc. is also available on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Endowment Wealth
Management, Inc. is 108652.
Endowment Wealth Management, Inc. is a registered investment adviser. Registration does not imply
a certain level of skill or training.
Endowment Wealth Management, Inc.
Form ADV Part 2 Brochure
March 30, 2026
Item 2 Summary of Material Changes
EWM updates this brochure at least annually and will deliver to clients Within 120 days after the end of
our fiscal year either (i) a summary of material changes or (ii) the full updated brochure, as required.
Clients may request a complete copy at any time without charge. A current copy of Endowment Wealth
Management, Inc.’s Form ADV Part 2A is available upon request at no charge by contacting Timothy
Landolt, Chief Compliance Officer, at (920) 785-6010.
Since our last annual update dated March 31, 2025, the following material changes have been made :
Item 4. Clarified that EWM provides general education—not recommendations—regarding retirement plan
rollovers.
Item 5. Updated alternative investment fee billing to allow for retroactive adjustments when delayed
valuations materially differ from prior reports
Items 5, 6, and 11. Added disclosure that EWM charges or may charge performance-based fees for certain
private equity and venture capital investments for Qualified Clients.
Item 11. Expanded conflict of interest disclosures related to alternative investments and affiliated private
funds.
Item 12. We updated Item 12 (Brokerage Practices) to clarify that, in certain cases involving large
transactions, EWM or its affiliate may negotiate commission rates with broker-dealers in the secondary
market as part of our efforts to seek best execution.
This summary highlights material changes only. Clients should review the full brochure for
complete information.
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Item 3 Contents
Item 1 Cover Page ....................................................................................................................................... 1
Item 2 Summary of Material Changes ...................................................................................................... 3
Item 3 Contents ........................................................................................................................................... 4
Item 4 Advisory Business ........................................................................................................................... 7
A. Description of Services ....................................................................................................................... 7
B. Financial Planning Services................................................................................................................ 7
C. Investment Advisory and Portfolio Management Services ................................................................ 7
D. Retirement Plan Consulting Services ............................................................................................... 11
E. Pension, 401(k), and Retirement Plan Advisory Services ................................................................ 11
F. Fiduciary Status ................................................................................................................................ 12
G. Wrap Fee Programs .......................................................................................................................... 12
H. Insured Cash Program ...................................................................................................................... 12
I. Assets Under Management ............................................................................................................... 13
Item 5 Fees and Compensation ................................................................................................................ 13
A. Financial Planning Fees .................................................................................................................... 13
B. Asset-Based Advisory Fees .............................................................................................................. 14
C. Standard Billing Practices ................................................................................................................ 15
D. Envestnet Accounts .......................................................................................................................... 16
E. Direct Billing Accounts .................................................................................................................... 16
F. Performance Fees (Direct Billing) .................................................................................................... 17
G. Account Aggregation (Householding) .............................................................................................. 17
H. Cash Assets Billing Policies ............................................................................................................. 17
I. Additional Fee Billing Disclosures for Alternative Investments ...................................................... 18
J. Fee Negotiation Policy ..................................................................................................................... 18
K. Termination ...................................................................................................................................... 18
L. Advisory Consulting Fees ................................................................................................................ 19
M. Family Office Services ..................................................................................................................... 19
N. Additional Fees and Expenses .......................................................................................................... 19
Item 6 Performance-Based Fees and Side-By-Side Management ......................................................... 20
A. Performance Based Fees ................................................................................................................... 20
B. Side-by-Side Management ............................................................................................................... 20
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Item 7 Types of Clients ............................................................................................................................. 21
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .................................................. 21
A. Methods of Analysis ......................................................................................................................... 21
B. Investment Strategies ........................................................................................................................ 22
C. Material Risks Involved ................................................................................................................... 23
Investment Strategies Risks .............................................................................................................. 24
D. Risks of Specific Securities Utilized and Underlying Fund Holdings ............................................. 25
E. Recommendation of Particular Types of Securities ......................................................................... 32
Item 9 Disciplinary Information .............................................................................................................. 32
Item 10 Other Financial Industry Activities and Affiliations ............................................................... 32
A. Registration as a Broker-Dealer ....................................................................................................... 32
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity
Trading Advisor................................................................................................................................ 32
C. Registration Relationships Material to this Advisory Business and Possible Conflicts of
Interests ............................................................................................................................................ 32
D. Selection of Other Advisers or Managers and How We are Compensated for Those Selections .... 33
E. Insurance........................................................................................................................................... 34
F. Related Person- Accountant ............................................................................................................. 34
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ...................................................................................................................................................... 34
A. Description of EWM’s Code of Ethics ............................................................................................. 34
B. Material Financial Interest (Potential Conflict of Interest) ............................................................... 35
C. Participation or Interest in Client Transactions ................................................................................ 36
D. Investing Personal Money in the Same Securities as Clients ........................................................... 36
E. Trading Securities At/Around the Same Time as Clients’ Securities ............................................... 37
Item 12 Brokerage Practices .................................................................................................................... 37
A. Recommendation of Custodians ....................................................................................................... 37
B. Discussion of Benefits to EWM as to Selection of Custodians ........................................................ 38
C. Custody Services Requiring Trusts or Assets Requiring Special Handling ..................................... 40
D. Brokerage for Client Referrals ......................................................................................................... 40
E. Directed Brokerage ........................................................................................................................... 40
F. Block Trades ..................................................................................................................................... 40
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Item 13 Review of Accounts ..................................................................................................................... 41
Item 14 Client Referrals and Other Compensation ............................................................................... 41
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients ............................... 41
B. Compensation to Non-Advisory Personnel for Client Referrals ...................................................... 41
C. Economic Benefits Provided to Unaffiliated Third Parties .............................................................. 42
Item 15 Custody ........................................................................................................................................ 42
Item 16 Investment Discretion ................................................................................................................. 43
Item 17 Voting Client Securities .............................................................................................................. 43
Item 18 Financial Information ................................................................................................................. 43
A. Balance Sheet ................................................................................................................................... 43
B. Financial Condition .......................................................................................................................... 44
C. Bankruptcy ....................................................................................................................................... 44
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Item 4 Advisory Business
A. Description of Services
Endowment Wealth Management, Inc. (“EWM”) is a fee-only registered investment adviser based in
Appleton, Wisconsin. Founded in 1996, the firm was recapitalized and renamed in 2013. Robert Riedl
and Prateek Mehrotra are the firm’s principal owners.
EWM provides the following advisory services:
Investment Advisory and Portfolio Management
Financial Planning
Private Fund Management
Advisory Consulting
Alternative Investment Advisory
Retirement Plan Consulting
Services are tailored based on client-provided information, including investment objectives, financial
circumstances, risk tolerance, time horizon, and any client-imposed restrictions.
In this brochure, “EWM,” “we,” or “us” refers to the firm. “Client” refers to current or prospective
clients.
EWM’s Associated Persons or Investment Adviser Representatives are EWM’s officers, employees, and
all other individuals providing investment advice on behalf of EWM.
B. Financial Planning Services.
Financial planning is a process that evaluates your current financial position and develops a strategy to
help achieve your goals. EWM provides customized financial planning based on each client’s goals and
financial situation. Plans may include retirement planning, estate considerations, cash flow analysis, tax
planning coordination, and other relevant topics.
Fees are charged on an hourly or fixed-fee basis depending on complexity. EWM may, in its discretion,
waive or reduce fees if a client is not satisfied with the services provided.
Clients are not required to engage EWM for ongoing investment management.
EWM may discuss tax and estate strategies but does not provide legal or tax advice. Clients should
consult their attorney or tax professional.
C. Investment Advisory and Portfolio Management Services
EWM provides discretionary and non-discretionary portfolio management services to individuals,
businesses, non-profits, and institutions.
Portfolios may include traditional investments (such as stocks, bonds, ETFs, and mutual funds)
(“Traditional Investments” or “Traditional Assets”) and alternative investments. Recommendations are
based on each client’s objectives, risk tolerance, and financial circumstances.
As part of its investment advisory and financial planning services, EWM may consider certain tax factors,
such as a client’s tax rate, asset location, and tax-loss harvesting. However, tax considerations may not be
applied in all cases and are not the primary focus of EWM’s investment management services unless
otherwise agreed to in writing. Clients should consult with their own tax professionals regarding their
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individual tax situations. For additional information, please see Item 8 (Methods of Analysis, Investment
Strategies and Risk of Loss).
Accounts are managed on either a discretionary basis (where EWM makes investment decisions without
prior client approval) or a non-discretionary basis (where client approval is required prior to each
transaction).
EWM may provide advisory services across a variety of account types, including brokerage accounts,
retirement accounts, and other tax-advantaged accounts, as described below.
Use of Envestnet
EWM may recommend that clients use Envestnet, a third-party platform that provides portfolio
management, rebalancing, reporting, and access to third-party managers.
Envestnet charges a separate fee (typically 0.15% annually). EWM does not receive any portion of this
fee.
Clients may choose not to use Envestnet and instead have accounts managed directly through a custodian
such as Fidelity.
Separately Managed Account Programs
Many of EWM’s discretionary accounts are managed through separately managed accounts (“SMAs”). In
an SMA, assets are held directly in the client’s account and are not pooled with other investors, as they
would be in a mutual fund. This structure allows for greater customization based on each client’s
investment objectives, risk tolerance, and financial circumstances. SMA managers may invest in a range
of securities, including equities, fixed income, and alternative investments.
EWM may also recommend unified managed accounts (“UMAs”). A UMA allows multiple investment
strategies, managers, and asset classes to be combined within a single account. In these arrangements, a
platform provider (such as Envestnet) typically acts as an overlay manager, implementing trades,
rebalancing the portfolio, and coordinating multiple strategies within the account.
EWM selects SMA managers and model portfolios based on each client’s investment objectives, risk
tolerance, and overall financial circumstances. Depending on client needs, EWM may recommend one or
more of the following:
Third-party managers. Unaffiliated investment managers, typically accessed through platforms
such as Envestnet, may be selected for their specialized expertise in managing specific asset
classes or strategies on a discretionary basis.
Third-party models. Model portfolios developed by unaffiliated managers may be implemented
through platforms such as Envestnet. These models provide diversified exposure with generally
lower minimum investment requirements, and the platform executes trades to align client
accounts with the model.
EWM-managed models. EWM may manage proprietary model portfolios on a discretionary
basis. No additional advisory fees are charged on assets allocated to these models beyond EWM’s
standard advisory fee. If implemented through a platform such as Envestnet, applicable platform
fees will still apply.
Affiliate-managed models. EWM may recommend models developed by its affiliate, ETF
Model Solutions®, LLC (“ETFMS”). While ETFMS develops the models, EWM retains
discretion over their implementation in client accounts. These models are provided as part of
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EWM’s advisory services without additional fees; however, platform, custody, and transaction
fees may apply. The use of affiliated models creates a conflict of interest, as described in Item 10.
SMA or unified managed account (“UMA”) programs are subject to multiple layers of fees, which may
include platform fees, third-party manager fees, and custodial or brokerage costs.
Clients are not required to use SMA programs or any specific manager or model.
Alternative Investments
EWM may provide non-discretionary advice regarding investments in alternative investments
(“Alternative Investments”) such as private placements offered pursuant to exemptions from registration,
private equity funds, hedge funds, private real estate investments (including private REITs and Delaware
Statutory Trusts), business development companies (BDCs), interval funds, Qualified Opportunity Zone
(“QOZ”) investments, private debt instruments or funds, secondary market private equity interests, and
other similar structures.
Many Alternative Investments are not registered under the Securities Act of 1933 and are not publicly
traded. As a result, they may involve limited liquidity, limited transparency, higher fees, and greater risk
of loss, including the potential loss of the entire investment. These investments are typically available
only to certain investors who meet applicable eligibility or suitability standards.
EWM’s role with respect to Alternative Investments is generally limited to providing due diligence,
education, and recommendations. Clients retain full discretion over whether to invest and should carefully
review all offering documents, including the private placement memorandum and related materials,
before making an investment decision.
Alternative Investments- Private Funds and Partnerships Managed by Unaffiliated Managers.
EWM may research, identify, and source private investment funds managed by unaffiliated
advisors or general partners.
Alternative Investments- Secondary Market Private Equity and Direct Placements. EWM may
research, identify, and source or facilitate direct investments in private companies by purchasing
their securities in the secondary market or otherwise. These investments primarily target late-
stage venture funded and/or private equity companies.
Affiliated Private SPV Funds.
EWM and its affiliate, Global Alternative Investment Management LLC (“Global Alts”), sponsor and
manage private investment funds (“SPV Funds”).
EWM may recommend that clients invest in these funds. EWM or Global Alts receive management,
accounting fees, and/or performance-based compensation from the SPV Funds, which are borne by
investors in those funds. This creates a conflict of interest because EWM has an incentive to recommend
investments that generate additional compensation. EWM does not charge advisory fees on assets
invested in SPV Funds.
Clients should be aware that investments in SPV Funds involve additional risks, including limited
liquidity, lack of transparency, and reliance on the manager’s discretion.
All relevant information, terms and conditions, risks, and fees relative to the SPV Funds re set forth in
each SPV Fund’s confidential private placement memorandum, the operating agreement, and other related
documents or disclosures.
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Types of Accounts and Related Services
Brokerage and Custodial Accounts. EWM manages client assets held at qualified custodians, such as
Fidelity. These accounts may include individual, joint, trust, and other taxable or non-qualified
accounts. EWM provides ongoing portfolio management, monitoring, and rebalancing services for
these accounts.
Health Savings Accounts (HSA). Clients must establish HSA accounts through Fidelity, and EWM is
limited to the investment options available on that platform. HSA assets are managed using EWM’s
standard asset allocation approach based on the client’s risk tolerance and overall financial situation.
Custodial and investment-related fees may apply. These fees are paid directly by clients to the service
providers. EWM does not receive any portion of fees charged by third-party HSA-related service
providers in connection with HSA accounts.
Participant-Directed Retirement Accounts (e.g., 401(k)). EWM may provide advisory services to
participants in employer-sponsored retirement plans, including 401(k) plans.
Discretionary Services (Brokerage Window Accounts): Where available, participants may access
a self-directed brokerage window (such as Fidelity BrokerageLink). EWM may manage these
assets on a discretionary basis using diversified portfolio models. Use of a brokerage window and
engagement of EWM are optional. Clients should be aware that:
Advisory fees will apply Investment costs may be higher than plan-provided options
There is no guarantee of improved performance.
Non-Discretionary Advice: EWM may provide non-discretionary advice to individual Clients
regarding investment options available within a Plan’s standard investment menu. This may
include asset allocation recommendations and fund selection guidance. Clients retain full
decision-making authority in these arrangements.
General Considerations for Retirement Plan Accounts. Clients are under no obligation to engage
EWM for retirement account advice. Investment options available within employer-sponsored
plans may be limited, and certain securities or strategies may not be available. Where necessary,
EWM may recommend substitute investments.
All services are provided under a written agreement, and clients are responsible for any
applicable advisory and investment-related fees.
Alternative Investments in Retirement Accounts. For eligible Clients, EWM may provide
non-discretionary advice regarding alternative investments held within retirement
accounts. These investments are typically managed by third-party managers and may:
Require minimum investment thresholds
Include additional fees and expenses
Require accredited investor status
Clients should review all offering documents carefully before investing.
Tailoring Services to Client Objectives
EWM tailors its investment advice to each client’s investment objectives, risk tolerance, and financial
circumstances (“Suitability Information”). At the beginning of the advisory relationship, we gather this
information and use it to develop an appropriate investment strategy.
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As part of our portfolio management services, EWM may construct and manage a customized portfolio
consistent with the client’s Suitability Information. We monitor portfolios on an ongoing basis and may
rebalance or adjust investments based on market conditions or changes in client circumstances.
Clients are responsible for informing EWM of any material changes to their financial situation,
investment objectives, or risk tolerance. EWM may also periodically request updated information and
recommend adjustments as appropriate.
Clients may impose reasonable restrictions on the management of their accounts, which must be provided
to EWM in writing. Clients should promptly notify EWM of any changes to such restrictions.
EWM manages accounts on either a discretionary or non-discretionary basis:
Discretionary accounts: Clients grant EWM authority to make investment decisions, including the
selection and amount of securities to be purchased or sold, without prior client approval. This authority is
granted through the advisory agreement or other written authorization. Clients may limit this authority in
writing.
Non-discretionary accounts: EWM provides investment recommendations, but client approval is required
prior to executing transactions.
D. Retirement Plan Consulting Services
EWM provides non-discretionary retirement plan consulting services, including pension consulting, to
employee benefit plans and their fiduciaries, as requested by the plan sponsor or other named fiduciary (the
“Plan”). The Plan’s fiduciaries retain full decision-making authority. (Note: The term “plan” or “Plan” is
a general reference and not intended as a reference to any “Plan” unless the context reasonably refers to
a specific “Plan.”)
Services may include plan review and analysis, recommendations on investment options and fund selection,
performance monitoring, participant education, enrollment support, and ongoing consulting. Educational
services may cover topics such as diversification, asset allocation, risk tolerance, investment time horizon,
and other plan-specific matters. These services are educational in nature and do not constitute individualized
investment advice to participants.
Additional or customized services may be provided as agreed in writing with the Plan and will be consistent
with the plan documents.
Either party may terminate the agreement upon 30 days’ written notice. Fees will be prorated for the quarter
of termination, and any unearned fees will be refunded.
E. Pension, 401(k), and Retirement Plan Advisory Services
EWM provides non-discretionary advisory and consulting services to employee benefit plans and their
participants to assist plan fiduciaries in meeting their obligations under ERISA.
As required by Department of Labor regulations, EWM provides plan fiduciaries with written disclosures
describing its services, compensation, and fiduciary status. These details are set forth in the applicable
service agreement.
EWM does not expect to receive compensation beyond what is disclosed. If additional compensation is
received, it will be disclosed and offset against EWM’s fees, as applicable.
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F. Fiduciary Status
EWM acts as a fiduciary under the Employee Retirement Income Security Act of 1974 (“ERISA”) and the
Internal Revenue Code (the “IRC”) when providing investment advice or management services to ERISA
plans, plan participants, and IRA owners. As a fiduciary, EWM is required to act in the client’s best interest
and to comply with applicable rules governing conflicts of interest and prohibited transactions.
A conflict of interest may arise when an investment adviser provides advice regarding retirement plan
distributions or rollovers, particularly if the adviser receives compensation (such as advisory fees) as a
result of a client rolling assets into an account managed by the adviser.
EWM does not provide individualized recommendations as to whether a client should take a distribution
from a retirement plan or roll over assets to another account. Instead, EWM provides general educational
information regarding rollover options. This may include a discussion of the differences between leaving
assets in a current employer-sponsored plan, transferring assets to a new employer’s plan, or rolling assets
into an IRA. This generalized information is intended to assist clients in making an informed decision, is
not intended to be individualized investment advice, and is not based on a client’s specific circumstances.
Clients are not required to roll over assets to EWM.
If a client independently decides to roll over assets to an account managed by EWM, EWM will provide
investment advice with respect to the allocation and investment of those assets. In providing such advice,
EWM acts as a fiduciary and will act in the client’s best interest in accordance with applicable laws and
regulations.
G. Wrap Fee Programs
A wrap fee program is an arrangement in which a single fee covers investment management, trading costs,
and other administrative expenses. EWM does not sponsor or participate in wrap fee programs.
H. Insured Cash Program
EWM makes available the Cantor Fitzgerald Insured Cash Program (“CF Cash”), offered by StoneCastle
Network, LLC (“StoneCastle”). The program places client cash into deposit accounts at participating banks
and credit unions (“Insured Depositories”) to provide FDIC or NCUA insurance, as applicable, subject to
applicable limits.
Participation requires a minimum investment of $100,000. EWM assists clients with enrollment and
transfers between like-named accounts.
StoneCastle, an SEC-registered investment adviser, administers the program and has discretion to select
participating institutions and allocate deposits among them to help maintain insurance coverage limits.
Accounts are held at a custodian bank. StoneCastle is not affiliated with EWM.
EWM receives an administrative fee of 0.10% annually on client assets in the program. Cantor Fitzgerald
also receives a fee. The administrative fee reduces the yield clients receive on their deposits
EWM’s receipt of an administrative fee in connection with client participation in the CF Cash program
creates a conflict of interest because it provides EWM with a financial incentive to recommend or retain
client assets in the program. EWM mitigates this conflict by making the program available on an optional
basis, not requiring client participation, and disclosing the nature of this compensation. However, this
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conflict cannot be eliminated. Other cash management or investment options may be available that do not
provide compensation to EWM and may offer similar or higher yields, and clients should consider these
alternatives when evaluating EWM’s recommendation of the program.
EWM does not place client assets into the program on a discretionary basis (except for certain private funds
it manages). Clients decide whether to participate and should review the program’s terms and disclosures
carefully.
Deposits held outside the program at participating institutions may be aggregated for insurance purposes
and could reduce available FDIC or NCUA coverage. Clients are responsible for providing information
about their existing banking relationships.
For private funds managed by EWM or its affiliate, EWM may place cash in the program on a discretionary
basis. In those cases, any administrative fees received by EWM or its affiliates are rebated to the fund when
EWM or its affiliates are otherwise compensated for managing those assets.
I. Assets Under Management
As most recent fiscal year end dated 12/31/2025, EWM manages $609,222,636 in Client assets including
$402,535,915 on a discretionary basis and $206,686,721 on a non-discretionary basis.
Item 5 Fees and Compensation
EWM is a fee-only investment adviser and is compensated through fees paid by its clients, including asset-
based advisory fees and, in certain cases, performance-based fees and administrative fees. As described in
this brochure, EWM and its affiliates may also receive certain indirect economic benefits. Fees are primarily
based on a percentage of assets under management (“AUM”), as described below.
EWM generally charges asset-based advisory fees. However, in certain circumstances described below,
EWM and/or its affiliates may receive performance-based compensation in connection with specific
investments. These arrangements are limited to certain private investments and are subject to applicable
regulatory requirements. Clients should carefully review the disclosures below and in Item 6 for a complete
description of these arrangements.
All fees described in this brochure are paid directly or indirectly by clients unless otherwise identified as
an indirect economic benefit.
A. Financial Planning Fees
Financial planning is billed either at a fixed fee or hourly rate of $350, depending on complexity. Total
fees generally range from $1,000 to $3,500.
Fees are due upon delivery of the plan. Clients are not required to implement recommendations through
EWM.
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B. Asset-Based Advisory Fees
Traditional Investments: Taxable and Qualified Accounts
EWM charges the following annual fee based on AUM:
Assets Under Management (AUM)
Annual Fee Percentage
$0-$1.0 million
1.00%
$1.0 million to $2.5 million
0.90%
$2.5 million to $5.0 million
0.80%
$5.0 million to $7.5 million
0.70%
$7.5 million to $10.0 million
0.60%
$10.0 million to $20.0 million
0.50%
$20.0 million to $30.0 million
0.40%
$30.0 million and above
Negotiable
Alternative Investments (Taxable Accounts)
EWM charges an annual advisory fee of 1.00% on alternative investments.
EWM may charge performance-based fees in connection with certain private investments, including private
equity and venture capital investments. These fees:
Are typically structured as a percentage of realized profits (generally 10%).
Are assessed upon a liquidity event (such as a sale, distribution, or transfer of the investment).
Are calculated on an investment-by-investment basis; and
Are only charged to clients who meet the definition of a “Qualified Client” under applicable SEC
rules.
The specific terms, calculation methodology, and timing of such fees are set forth in a written agreement
or addendum executed at the time of the investment.
Qualified Accounts (e.g., IRA, Roth IRA, 401(k))
All assets (traditional and alternative) in qualified accounts are charged using the same AUM-based fee
schedule shown above (see Traditional Investments: Taxable and Qualified Accounts).
EWM does not charge performance-based fees directly to qualified accounts (such as IRAs or 401(k)
accounts). In addition, EWM generally does not recommend or permit qualified accounts to invest in private
investments or affiliated funds that involve performance-based compensation, as such arrangements may
result in prohibited transactions under applicable law.
As a result, clients should not expect to incur performance-based fees, either directly or indirectly, within
qualified accounts.
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401(k) Plans
Employer-sponsored plans are charged based on the same AUM schedule above (see Traditional
Investments: Taxable and Qualified Accounts). Fees are billed quarterly in arrears through the plan or its
service providers.
Public Charities & Non-Profits
Traditional assets:
Assets Under Management (AUM)
Annual Fee Percentage
$0-$1.0 million
0.50%
$1.0 million to $2.5 million
0.45%
$2.5 million to $5.0 million
0.40%
$5.0 million to $7.5 million
0.35%
$7.5 million to $10.0 million
0.30%
$10.0 million to $20.0 million
0.25%
$20 million to $30.0 million
0.20%
Alternative investments: 1.00% annually. Performance fees may apply to certain private equity or venture
capital investments, as described in a written addendum executed at the time of investment. Performance
fees are equal to 10% of profits and are assessed upon a liquidity event or transfer of the investment. All
performance-based fees described above are paid directly by clients or indirectly through their
investments and are not paid by third parties in connection with the sale of investment products.
Private Funds (SPVs)
For private funds sponsored or managed by EWM or its affiliate, Global Alternative Investment
Management LLC (“Global Alts”), EWM and/or its affiliate may receive performance-based compensation
(such as carried interest or incentive allocations).
These fees:
Are paid at the fund level and are borne indirectly by investors in the fund.
Are based on the overall performance of the fund.
Are governed by the terms of the fund’s offering documents; and
May be in addition to other fees and expenses charged by the fund.
Although EWM does not charge its standard advisory fee on assets invested in these affiliated funds, the
receipt of performance-based compensation by EWM or its affiliates creates a conflict of interest, as
described in Items 10 and 11
C. Standard Billing Practices
Billing practices differ by account type: Envestnet accounts are billed in advance, while all other accounts
are billed in arrears.
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Advisory fees (for non-Envestnet accounts) are calculated annually and billed quarterly. The annual fee is
divided by four to determine the quarterly fee. Fees are pro-rated based on the number of days your
account is managed during the quarter.
EWM may deduct fees directly from your account if you provide written authorization and the custodian
provides you with account statements showing all transactions, including advisory fees. The custodian
will send account statements at least quarterly. Clients should carefully review these statements and
compare them to any invoices received from EWM.
If assets are distributed from an EWM-advised SPV Fund (where fees were already charged for that
quarter) into a brokerage account managed by EWM, EWM will not charge additional fees on those
assets until the start of the next quarter.
Closed-end interval funds and similar investments are generally treated as alternative investments. If such
investments later transition to daily liquidity and are reclassified as traditional assets, EWM will continue
to apply the alternative investment fee rate until the transition is complete. Any fee adjustments for that
period will be made at EWM’s discretion.
D. Envestnet Accounts
Traditional assets managed through the Envestnet platform are billed quarterly in advance based on the
account value at the end of the prior quarter.
Fees are charged on a calendar quarter basis in advance and prorated to the end of the quarter upon inception
of the account. For mid-quarter deposits or withdrawal exceeding a de minimis threshold ($10,000, unless
Advisor agrees on a different threshold with applicable custodian), Envestnet will calculate an adjustment
to the Fee for those assets for the remainder of the quarter (“Intra-Quarter Billable Assets”). Withdrawal or
deposits for those Intra-Quarter Billable Assets will be calculated in accordance with the allocation of the
assets in the managers or Funds at the time of the intra-quarter billing.
Fees are typically deducted directly from your account with authorization (see Item 5.C. “Standard Billing
Practices”).
Clients should note that billing practices differ depending on account type. Envestnet accounts are billed in
advance, while other accounts are billed in arrears, as described above.
E. Direct Billing Accounts
Accounts not managed through Envestnet are billed directly to the client unless otherwise agreed in writing.
These may include:
Traditional accounts not managed on Envestnet
Alternative investments
Private placements
Health Savings Accounts (HSAs)
Individually managed 401(k) or BrokerageLink accounts
These fees are billed quarterly in arrears based on the average daily balance of the account during the prior
quarter, using the applicable fee rate based on assets under management at quarter-end.
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EWM will send an invoice, which is due upon receipt. Fees may be paid directly or deducted from your
account with authorization.
Clients should review invoices alongside custodian statements and promptly report any discrepancies to
EWM
F. Performance Fees (Direct Billing)
Performance fees for certain private equity and venture capital investments are billed separately and are
not based on account balances. Performance fees are calculated based on realized gains on an investment-
by-investment basis, in accordance with the calculation methodology, including the timing of realization
and/or transfer, treatment of losses, and other terms as set forth in the applicable agreement
G. Account Aggregation (Householding)
EWM may combine, or “household,” the value of non-qualified (taxable) accounts held by related clients
such as family members (first degree), or affiliated individuals or entities, to determine the applicable fee
rate for traditional assets. EWM may also include assets managed by its affiliates in this calculation.
Alternative investments held in non-qualified accounts, including investments in SPV Funds managed by
EWM or its affiliates, may also be included when determining the fee rate for traditional assets.
EWM determines eligibility for account aggregation at its sole discretion, typically at account opening or
upon client request. Any approved aggregation will apply prospectively at the start of a new quarter.
EWM does not apply aggregation retroactively or provide refunds for prior periods.
EWM cannot aggregate assets in qualified accounts (IRA, Roth IRA, and retirement/401(k) accounts)
when aggregating or “householding” assets for fee discounts for non-qualified accounts. Fees for non-
qualified accounts are based only on eligible non-qualified assets.
Fees for qualified accounts are otherwise based on the assets held by each account owner. EWM does not
generally aggregate qualified accounts due to regulatory considerations. Any exception is at EWM’s sole
discretion and requires the client to consult an independent advisor and agree in writing to hold EWM
harmless for any resulting tax, legal, or regulatory consequences.
H. Cash Assets Billing Policies
EWM treats cash and cash equivalents as part of your managed assets when they are included in a
portfolio or model allocation, including cash held for liquidity within the strategy. These balances are
included in assets under management and are subject to advisory fees. In certain market conditions, the
advisory fee may exceed the yield earned on cash or money market holdings.
Cash held temporarily in a funding account for pending investments or distributions is not considered a
managed asset and is not subject to advisory fees.
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I. Additional Fee Billing Disclosures for Alternative Investments
Valuations for alternative investments are often provided by third-party managers on a delayed basis and
may be revised after initial reporting. As a result, the value used to calculate advisory fees may differ
from the investment’s updated or final reported value.
Unless otherwise stated, fees for alternative investments are based on either (i) the most recent valuation
provided by the investment manager as of the end of the quarter, or (ii) a valuation determined by EWM
in accordance with its written valuation policies and procedures, which are available upon request.
EWM may make adjustments to prior fees to reflect updated valuations. These adjustments may result in
additional fees being charged or credits being applied to a client’s account. Any such adjustments will be
applied in a manner that is fair and equitable to clients and consistent with disclosed valuation policies.
EWM will not apply retroactive increases without providing notice and a reasonable explanation.
Clients should be aware that:
Retroactive adjustments may occur when valuation changes are material, as determined by EWM
in its reasonable discretion.
Such adjustments may be applied in a subsequent billing period rather than at the time the
original fee was charged.
The timing, frequency, and magnitude of these adjustments are dependent on the timing and
accuracy of information provided by third-party investment sponsors.
EWM does not control the timing or methodology of valuations provided by third-party
managers.
This practice creates a conflict of interest because EWM has an incentive to apply valuation
methodologies that increase fee calculations. EWM seeks to mitigate this conflict by applying its
valuation policies consistently, relying primarily on third-party valuations, and disclosing this practice to
clients.
Clients should review account statements and invoices carefully and contact EWM with any questions
regarding fee calculations or adjustments.
Private investments vary in structure, and fee arrangements may differ by investment. EWM generally
does not offer fee discounts on alternative investments but may negotiate different fee terms for large
investments (typically over $10 million). Any such arrangements will be documented in a written
agreement with the client.
J. Fee Negotiation Policy
EWM’s fees are negotiable and may vary based on factors such as the size of the account or the scope of
services provided.
K. Termination
Clients or EWM may terminate the advisory agreement at any time with written notice.
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For traditional assets, fees are charged on a prorated basis through the date of termination. Any prepaid,
unearned fees will be refunded.
Termination of advisory services does not eliminate EWM’s right to receive fees related to alternative
investments already made. Clients remain responsible for advisory fees associated with those investments
for their duration, as described in the applicable agreement.
For private equity or venture capital investments subject to a performance fee, the performance fee will be
calculated based on the value of the investment as of the date of the liquidity event or account transfer
termination, in accordance with EWM’s valuation policy.
L. Advisory Consulting Fees
EWM charges an hourly fee of $250 to $500 for advisory consulting services. Fees are negotiable based on
the scope and complexity of the services.
Fees are billed at the end of each consulting session and are due upon receipt of the invoice.
M. Family Office Services
EWM charges an hourly fee of $60 to $250 for Family Office Services. The rate varies based on the scope
and complexity of the services.
These administrative services may include personal business support, checkbook management, and other
financial tasks related to a client’s personal affairs that are separate from portfolio or asset management.
Fees are billed quarterly in arrears.
N. Additional Fees and Expenses
Fees paid to EWM are separate from fees and expenses charged by other service providers.
For example, clients may incur:
Platform fees (such as Envestnet for SMA or UMA accounts)
Management and performance fees charged by private fund managers
Fees and expenses charged by mutual funds, ETFs, exchange-traded notes, or closed-end funds
Custodial, brokerage, or transaction fees when buying or selling securities
These fees are charged by third parties, such as custodians or investment managers, and reduce
investment returns.
Clients should review all applicable fees, including those charged by EWM, third-party managers,
platforms, and custodians. Additional information is available in the “Brokerage Practices” section of this
brochure.
For participant-level retirement plan accounts, clients are responsible for all plan-related fees, including
administrative, recordkeeping, investment, custody, and transaction costs associated with the plan.
EWM does not receive any portion of these third-party fees.
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Item 6 Performance-Based Fees and Side-By-Side Management
A. Performance Based Fees
As described in Item 5 (Private Funds- SPVs), EWM and/or its affiliates may receive performance-based
compensation in connection with certain private investments. These arrangements fall into two primary
categories:
(1) Performance Fees Applicable to Certain Direct Private Equity and Venture Capital Investments.
As described in Item 5, EWM charges performance-based fees on certain private equity and
venture capital investments. These fees are generally equal to a percentage of realized profits and
apply only to clients who meet the definition of a “Qualified Client.”
(2) Affiliated Private Funds (SPV Funds). Clients invested in SPV Funds managed by EWM or its
affiliate, Global Alternative Investment Management LLC (“Global Alts”), will also be subject to
performance-based fees as described in Item 5. These fees are also described in the applicable
fund’s offering documents.
These performance-based fee arrangements create conflicts of interest because EWM and its affiliates
have a financial incentive to recommend investments that generate such compensation. EWM does not
allocate investment opportunities based on fee structure and seeks to allocate opportunities on a fair and
equitable basis over time. Additional information about these conflicts and how EWM addresses them is
provided in Item 11.
Who is a “Qualified Client”?
Under SEC rules, only “Qualified Clients” may be charged performance-based fees. A Qualified Client is
generally a client who meets one or more of the following criteria at the time of entering into the advisory
agreement:
Has at least $1,100,000 under EWM’s management; or
Has a net worth of more than $2,200,000 (excluding the value of a primary residence, and
including assets held jointly with a spouse, if applicable).
These thresholds are subject to periodic adjustment by the SEC.
B. Side-by-Side Management
EWM and its affiliate, Global Alts, manage accounts and investments that are subject to different fee
structures, including accounts that pay asset-based fees and investments that generate performance-based
compensation. This creates a conflict of interest because EWM may have an incentive to favor investments
or allocate resources to those that generate higher compensation.
EWM’s recommendations are based on each client’s investment objectives, financial circumstances, and
risk tolerance, and are made in accordance with EWM’s fiduciary duty to act in the client’s best interest.
EWM addresses these conflicts through policies and procedures designed to promote fair and equitable
treatment of clients. These may include allocation policies that govern how investment opportunities are
distributed among clients and affiliated funds, supervisory review of recommendations and allocations, and
monitoring of accounts subject to performance-based fees. However, these measures may not eliminate the
conflict of interest.
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Item 7 Types of Clients
EWM provides investment advisory services to individuals (including non-accredited, accredited, qualified,
and sophisticated investors), pension, and profit-sharing plans, 401(k) plans, trusts, estates, endowments,
foundations, public charities, non-profit organizations, corporations, and other business entities.
EWM also provides advisory services to pooled investment vehicles and private funds.
EWM does not generally impose a minimum account size; however, certain services or investment
strategies may require minimum investment amounts.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Investing involves risk. The value of your investments may go down, and you may lose money, including
the loss of your entire investment in certain cases. There is no guarantee that any investment strategy or
recommendation will be successful or that your investment objectives will be achieved.
A. Methods of Analysis
EWM provides asset allocation and portfolio management services to clients who engage the firm for
advisory services. EWM uses a variety of analytical methods to develop and manage client portfolios. No
single method is used exclusively, and different methods may be applied depending on the client,
investment type, and market conditions. These methods include:
Fundamental Analysis – evaluating financial condition, earnings, and competitive position of
companies or investments
Technical Analysis – reviewing price movements and market trends
Macroeconomic (Top-Down) Analysis – assessing economic conditions, interest rates, inflation,
and market cycles.
Quantitative and Model-based Analysis – using data, models, and statistical relationships.
Modern Portfolio Theory (MPT) – an approach that seeks to balance risk and return by diversifying
investments across asset classes based on expected returns, volatility, and correlations.
EWM uses these methods to allocate assets and construct portfolios based on each client’s financial
situation, investment objectives, time horizon, and risk tolerance.
Portfolios are typically constructed using a combination of:
Publicly traded securities (such as stocks, bonds, ETFs, and mutual funds)
Separate account managers or model portfolios
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Alternative investments (such as private equity, private credit, hedge funds, and real estate-related
investments). EWM uses this framework to construct portfolios based on each client’s financial
situation, investment objectives, and time horizon.
The allocation among these categories may vary significantly between clients.
B. Investment Strategies
Endowment Investment Philosophy® (EIP)
The Endowment Investment Philosophy® is a framework EWM uses to build client portfolios. It is not a
guarantee of performance and does not protect against loss. Under this approach, investments are generally
grouped into three categories:
Growth – investments intended to provide long-term capital appreciation, including public equities
and certain private investments
Income – investments intended to generate income, such as fixed income securities and income-
oriented strategies
Risk-Managed –investments intended to provide diversification and that may help manage overall
portfolio volatility, including certain alternative investments
EWM may implement this approach directly or through investment vehicles such as mutual funds,
exchange-traded funds (ETFs), or third-party managers.
In managing portfolios within the EIP, EWM may use strategies such as:
Long-term investing – holding investments for extended periods, which is subject to market,
economic, interest rate, inflation, and regulatory risks
Passive or index investing – tracking market indices rather than trying to outperform them; this
approach will reflect overall market declines
Strategic asset allocation – spreading investments across different asset classes to pursue long-term
goals; this does not guarantee a profit or prevent losses and may not take all tax considerations into
account
The EIP is based on investment approaches commonly used by endowments and foundations. EWM has
adapted this framework for individual clients based on their financial situation, investment objectives, and
time horizon. The way assets are allocated among these categories may vary significantly from one client
to another.
Additional Strategies (Limited Use or Through Third Parties)
These strategies may be used on a limited basis or by third-party managers or other investment vehicles,
including mutual funds, ETFs, separate accounts, or private placements:
Active or tactical asset allocation
Margin (borrowing to invest)
Options and option writing strategies
Short selling
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Short-term or frequent trading
These strategies involve additional risks, including leverage risk, higher volatility, increased costs, and
the potential for substantial or unlimited losses.
Tax Considerations
EWM’s strategies and investments may have significant tax consequences. When providing investment
advice or financial planning services, EWM may consider certain tax factors, such as a client’s tax rate,
asset location, availability of qualified accounts, and tax-loss harvesting. However, EWM may choose not
to consider some or all tax implications when making investment decisions.
While EWM may seek to optimize clients’ after-tax returns (referred to as “tax optimization”), tax
efficiency is not the primary objective in managing client assets unless otherwise agreed to in writing.
EWM recommends that clients consult with a qualified tax professional before and throughout their
relationship with EWM, regardless of account size or other factors.
C. Material Risks Involved
General Investment Risks
All investments involve risk, including loss of principal. EWM does not guarantee that its strategies or
recommendations will be successful or that client objectives will be achieved.
Risks of the Endowment Investment Philosophy
Alternative Investment Risks. Alternative investments used within the EIP typically have higher internal
management fees, expenses, and operational costs than traditional stock and bond ETFs. These higher costs
reduce net returns. There is no assurance that the performance of alternative investments will offset these
additional expenses. As a result, portfolios utilizing the EIP may underperform more traditional portfolios
with similar risk characteristics.
Concentration Risk within the Endowment Index. Multiple alternative asset classes, including private equity
and venture capital, may be represented by a single ETF, currently the Invesco Global Listed Private Equity
ETF (PSP). As of the date of this brochure, the Endowment Index has a target allocation of approximately
29% to PSP. This creates concentration risk, as a higher allocation to a single security increases the impact
of that security’s performance—positive or negative—on overall portfolio results.
Index and Proxy Risk. Certain client portfolios are constructed based on, or derived from, the Endowment
Index. The Endowment Index uses proxy ETFs to represent certain alternative asset classes where direct
investment vehicles are not available. These proxies may not accurately reflect the performance, liquidity,
or risk characteristics of the underlying asset classes.
Liquidity Risk. Alternative investments, particularly private placements, are generally illiquid. Clients may
not be able to sell or redeem these investments on a timely basis, if at all. These investments often have
lock-up periods, limited redemption opportunities, or restrictions on transfer. As a result, clients may be
unable to access their invested capital when needed or may be required to sell at a discount.
Private Placement Risk. Private placements involve additional risks compared to publicly traded securities.
These risks may include limited disclosure, lack of transparency, limited operating history, use of leverage,
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and higher fees. Private placements are generally only available to qualified investors and can be affected
by regulatory and contractual restrictions. There is a higher risk of loss, including the potential loss of the
entire investment.
Valuation Risk. Alternative investments, especially private investments, are often not publicly traded and
may not have readily available market prices. Valuations are typically determined by the investment
sponsor or based on models, estimates, or appraisals, which may be subjective. In addition, reported
valuations may be provided on a delayed basis and may not reflect current market conditions. As a result,
reported performance and account values may differ materially from the price at which the investment could
actually be sold.
Methods of Analysis Risk
Each analytical method involves limitations, is subject to changing market conditions, and may not produce
the intended results.
Charting and Technical Analysis rely on historical price patterns. These patterns may not persist, and
market movements may be unpredictable or random.
Cyclical Analysis assumes repeating economic or market cycles. These cycles may not occur as expected
or may change due to external factors or investor behavior.
Fundamental Analysis depends on the accuracy and completeness of financial and economic information.
Market prices may not reflect a company’s perceived value, and expectations about future performance
may be incorrect.
Modern Portfolio Theory relies on assumptions about risk, return, correlations, and investor behavior. These
assumptions may not hold under actual market conditions, which may affect portfolio outcomes
Quantitative Models depend on data inputs, model design, and historical relationships. Changes in market
conditions, incorrect assumptions, or implementation errors may reduce their effectiveness.
Top-Down Analysis focuses on macroeconomic trends and may overlook individual securities that perform
differently than broader market expectations.
Investment Strategies Risks
Each investment strategy involves risks and may not produce the intended results.
Asset Allocation and Diversification Risk. Asset allocation and diversification are used to manage risk but
do not guarantee a profit or protect against loss, particularly during declining markets.
Long-term Investing Risk. Long-term investing seeks to capture market returns over time but exposes clients
to risks that may arise throughout economic cycles. These risks include inflation (purchasing power) risk,
interest rate risk, market risk, economic risk, and political or regulatory risk. There is no assurance that
long-term investments will be profitable.
Passive Investing/Indexing Risk. Passive or index investing seeks to track the performance of a specific
market index or indices. This approach does not attempt to outperform the market and typically results in
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returns that reflect overall market performance. As a result, clients will not avoid market declines and may
experience losses consistent with the index being tracked.
Adaptive, Dynamic or Tactical Asset Allocation depends on investment decisions, models, or forecasts that
may be incorrect. Frequent trading can increase trading costs and poor timing decisions may result in
underperformance compared to benchmarks or passive strategies.
Leverage and Derivatives Risks. Margin, options, and short selling can result in significant or unlimited
losses.
Short-Term Trading Risk. Frequent trading or market timing may result in increased costs and volatility
may reduce returns.
Risk That Objectives May Not Be Met. EWM does not guarantee that its strategies, services,
recommendations, or methods of analysis will predict future results, identify market highs or lows, or
protect clients from losses during market declines. Investment advice and financial planning
recommendations are subject to market, interest rate, liquidity, marketability, currency, economic, political,
legal, business, and other known and unknown risks. These risks may negatively affect investment
performance and a client’s ability to meet financial objectives. There is no assurance that EWM’s
recommendations will be profitable or that your goals will be met. Past performance does not guarantee
future results.
D. Risks of Specific Securities Utilized and Underlying Fund Holdings
EWM recommends investments in pooled investment vehicles (such as mutual funds and ETFs), private
managers, and private placements that invest across a range of asset classes and strategies. All investments
involve risk of loss, and clients should be prepared to lose some or all their investment. Except for certain
U.S. government securities (such as Treasury Inflation-Protected Securities), these investments are not
insured or guaranteed by the FDIC or any other government agency and may fluctuate in value.
The risks of any fund or investment recommended by EWM are generally related to the risks of the
underlying securities held by the fund or the strategies used by the fund manager. Funds that invest in
alternative investments—such as hedge fund strategies, private equity, commodities, futures, short selling,
or options—generally involve a higher risk of loss. All funds charge fees and expenses, which reduce
investment returns.
Alternative Investments may involve greater risks than traditional investments such as stocks and bonds.
These risks may include market risk, liquidity risk, limited transparency, higher fees, use of leverage,
counterparty risk, default risk, manager risk, and foreign currency risk. These investments may also be more
volatile and less regulated than traditional investments, and performance may vary significantly.
Mutual Funds involve the risk of loss of principal. The value of mutual fund shares will fluctuate based on
the value of the underlying holdings. Mutual funds may invest in equity or fixed income securities, each of
which carries its own risks. Mutual funds calculate their net asset value (NAV) at the end of each business
day, although the value of underlying securities may change throughout the day. Mutual funds charge fees
and expenses, which reduce returns. Funds with higher costs must perform better than lower-cost funds to
achieve the same returns.
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EWM may not always hold the lowest-cost share class of a mutual fund. Other factors may be considered,
including access to a particular strategy, minimum investment requirements, or potential tax consequences
associated with selling existing holdings. In some cases, EWM may select investments that are appropriate
for a model portfolio but may not be optimal for a specific client’s individual circumstances.
Exchange Traded Funds (ETFs) trade on securities exchanges and are bought and sold at market prices,
which may differ from their net asset value (NAV). Shares may trade at a premium or discount to NAV due
to market conditions or trading inefficiencies. There is no guarantee that an active trading market will be
maintained. ETFs typically redeem shares only in large blocks (creation units), which may limit liquidity
for some investors. All ETFs charge fees and expenses that reduce returns.
EWM may invest in ETFs that seek exposure to traditional or alternative asset classes. These ETFs may
use proxy investments, which may not accurately reflect the performance of the intended asset class.
Investments in ETFs involve the risk of loss, including the potential loss of the entire investment.
Certain ETFs, including those investing in commodities, precious metals, or digital assets, may be affected
by factors such as market supply and demand, investor sentiment, and changes in industry practices. Some
ETFs may be structured as grantor trusts, which can result in complex tax reporting. Clients should consult
a tax professional regarding these investments. ETFs charge fees that reduce returns.
Exchange Traded Notes (ETNs) are unsecured debt securities issued by financial institutions that seek to
provide returns linked to an index or benchmark. Unlike ETFs, ETNs do not hold underlying assets. Instead,
they rely on the issuer’s promise to pay the return of the referenced index. As a result, ETNs are subject to
credit risk, including the risk that the issuer may be unable to meet its obligations.
The market price of an ETN may differ significantly from its indicative value. Returns depend on market
price changes if sold before maturity or on the issuer’s payment at maturity. ETNs may also be subject to
issuance limits, which can affect pricing and liquidity. ETNs charge fees that reduce returns and may not
be suitable for all investors due to their complexity and risks.
Risks of Other Assets, Asset Classes, or Types of Securities
EWM may recommend or invest client assets in a wide range of securities, funds, private managers, and
private placements. Except for certain insured bank deposits and certain U.S. government obligations, these
investments are not insured or guaranteed by the FDIC, SIPC, or any other government agency and may be
worth more or less than the original investment.
The risks of a fund or other pooled vehicle generally include the risks of its underlying holdings, the
strategies used by the manager, and the fees and expenses charged by the vehicle will reduce your net
investment return. Funds and managers that invest in alternative investments, derivatives, private securities,
short selling, or leveraged strategies generally involve greater risk of loss and higher expenses. These
investments and their associated risks include:
Bank Deposits such as checking and savings accounts are typically used for short-term cash needs and
generally do not provide significant returns. Interest rates are usually low, and inflation can reduce the value
of your money over time. Banks may also charge fees, which can further reduce returns. Deposits held at
FDIC-insured banks are generally insured up to $250,000 per depositor, per bank, per ownership category.
Amounts above these limits are not insured.
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Bank Deposits through the CF Cash Management Program. StoneCastle Cash Management, LLC
administers the CF Cash program. StoneCastle is not a bank, does not itself offer bank deposits, and its
services are not insured or guaranteed by the FDIC or any other government agency. StoneCastle has
represented that it has internal controls and procedures designed to detect and reduce operational and other
risks. These risks may arise from human error, misconduct, failed or inadequate processes, technology or
systems failures, security breaches, processing or communication errors, or failures to comply with
applicable laws and regulations by StoneCastle, its custodian, or their employees, agents, or service
providers. These controls may not detect or prevent all risks or failures. As a result, full insurance coverage
may not be available if funds are not properly placed with insured institutions or if program requirements
for FDIC or NCUA coverage are not met. EWM does not guarantee the effectiveness of StoneCastle’s
controls or the performance of StoneCastle, the custodian, or their personnel or service providers.
Business Development Companies (BDCs) invest in private or less actively traded companies, which may
have limited public information and higher risk. These companies are often smaller, financially distressed,
or lower quality, which increases the risk of default or loss. BDCs may be volatile, less liquid, and have
higher fees than traditional investments. Their shares may trade at prices above or below the value of their
underlying assets, and returns may be affected by the performance of the companies they invest in. BDCs
and ETFs that invest in them may also report acquired fund fees, which can increase overall expense ratios.
Closed End Funds (CEFs) are subject to market volatility and the risks of their underlying securities which
might include market volatility and the risks of their underlying holdings, which may include smaller
companies, foreign securities, commodities, and fixed income investments. Shares may be worth more or
less than their original cost when sold. CEFs with specialized or complex strategies may be more volatile.
CEF shares may trade at prices significantly above or below net asset value (“NAV”), and many CEFs trade
at discounts to NAV. There is no assurance that market price will move to NAV.
Commodities are tangible assets ranging from agricultural products like wheat or orange juice to natural
resources such as oil or metals used to manufacture and produce goods or services. Commodity prices are
affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints,
and weather. Because of those risk factors, even a well-diversified investment in commodities can be
uncertain.
Delaware Statutory Trusts or “DST” are entities used to hold title to investment real estate to qualify for
1031 like-kind exchange property according to the IRS revenue ruling 2004-86. The risks of DSTs include
the risks of investing in real estate (see Risks of Real Estate Funds), the use of leverage (borrowing),
operator risk relating to property managers, and asset manager risk related to the quality of the DST
managers. Potential distributions, potential returns, and potential appreciation are not guaranteed.
Digital (Crypto) Currencies Digital assets (such as cryptocurrencies) are not issued or backed by a
government and are not legal tender. Their value can change significantly over short periods and may be
highly volatile. These investments carry unique risks. If private keys or account access are lost or
compromised, the investment may be permanently lost. Transactions are generally irreversible, and errors
or theft may not be recoverable. Cryptocurrencies are not protected by FDIC or SIPC insurance. Digital
asset markets may be less regulated and may not offer the same protections as traditional investments. They
may also be affected by regulatory, tax, and technological changes, as well as cybersecurity risks and market
disruptions.
Emerging Markets involve risks beyond those of U.S. securities, including foreign currency risk, sovereign
risk, inefficient markets, liquidity risk, political instability, custody risk, and inconsistent accounting and
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reporting standards. These countries may be more likely to experience political turmoil, economic
disruption, nationalization, or expropriation of assets. It may also be difficult to enforce legal rights in those
jurisdictions. These risks may increase price volatility and make investments harder to value.
Equity Investments include stocks and ownership interests in other entities. Their value may rise or fall
based on company-specific events, industry conditions, market conditions, and broader economic factors.
Fixed Income investments bonds and similar securities issued by governments, companies, or other entities.
These investments can lose value due to changes in interest rates, inflation, or the financial condition of the
issuer. When interest rates rise, bond prices generally fall, and longer-term bonds are typically more
affected. There is also a risk that an issuer may not make interest or principal payments. Some fixed income
investments may be harder to sell, especially during market stress. Investments issued outside the U.S.
involve additional risks. Even U.S. government-backed securities, such as Treasury Inflation-Protected
Securities (TIPS), can lose value due to market conditions.
Foreign Securities may involve greater risks than investments in U.S. issuers. These include adverse foreign
economic, political, and regulatory developments; currency exchange risk; exchange controls; different
accounting, legal, and reporting standards; different market structures; and higher transaction costs.
Futures Contracts are standardized agreements to buy or sell an asset at a future date at a price agreed upon
today. Futures may involve market risk, economic risk, commodity risk, counterparty risk, and regulatory
risk. Because futures often involve margin, losses may exceed the initial investment. Futures may also be
more volatile than traditional investments.
Hedge Funds may be structured as private placements or registered investment companies. They often use
non-traditional strategies, derivatives, leverage, short selling, or other speculative techniques in domestic
or international markets. Hedge funds may have lower correlation to traditional stock and bond portfolios,
but they also may involve higher fees, manager risk, liquidity risk, counterparty risk, valuation risk,
complex tax reporting, limited regulatory oversight, and the risks of the underlying strategies and securities
they use. Hedge funds may be highly illiquid, may not provide regular pricing information, and may engage
in practices that increase the risk of loss.
Interest Rate Risk. Interest rates rise and fall over time. When rates are low, bond yields and total returns
may also be low. Rising rates may reduce the value of fixed income investments and fixed income funds.
Longer-duration investments are generally more sensitive to interest rate changes.
International Developed Markets. Investments in stocks and bonds in international developed market
countries subject investors to certain risks not present in domestic securities, including, not limited to
foreign currency risk, sovereign investing risk, inefficient markets risk, liquidity risk, and political risks.
Listed Private Equity Company Risk. Listed private equity companies, including BDCs and similar vehicles,
invest in or lend to private companies. Risks involve limited public information, credit risk, bankruptcy
risk, and leverage limitations under the Investment Company Act of 1940. These companies often invest in
smaller, less mature businesses, which may involve greater risk than established public companies.
Manager/Performance Risk. There is no guarantee that any manager will achieve a portfolio’s investment
objective or perform as expected.
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Master Limited Partnerships (MLPs) often invest in energy and infrastructure assets. They are publicly
traded partnerships and generally pass through income, gains, losses, deductions, and credits to investors,
often on Schedule K-1 forms, regardless if cash distributions are made. MLPs involve risks that differ from
common stock, including limited control and voting rights, interest rate sensitivity, investor sentiment,
changes in tax law, sector-specific risks, and the risks of their underlying assets or any fund that holds them.
Money Market Mutual Funds are mutual funds, not bank deposits, and are not FDIC insured. They invest
in short-term debt instruments and generally seek to maintain a stable NAV of $1.00 per share. Although
rare, a money market fund can lose value and break the $1.00 NAV. These funds also may have low returns
that do not keep pace with inflation.
Mortgage-Backed and Mortgage Pass-Through Securities Risk. Mortgage-backed securities (“MBS”)
represent interests in pools of mortgage loans and are subject to credit risk, interest rate risk, prepayment
risk, and extension risk. Their value may react differently to interest rate changes than other bonds, and
small changes in rates may significantly affect certain MBS. Some MBS transactions settle on a “to-be-
announced” (“TBA”) basis, where the specific securities are not identified until shortly before settlement.
If a counterparty to a TBA transaction defaults or becomes insolvent, a fund may experience losses, delays,
or additional costs.
Non-Correlation Risk. A fund may not match the return of its underlying index. Differences may result
from fees, transaction costs, rebalancing, valuation differences, legal restrictions, liquidity constraints, or
differences between the fund’s holdings and the index.
Non-U.S. Issuer Risk. Funds may hold securities issued by non-U.S. corporations, governments, agencies,
or supranational entities. These investments may involve greater economic, political, regulatory,
accounting, legal, market structure, and transaction cost risks than securities of U.S. issuers. These risks
may be greater in emerging markets.
Options Risks. Options are complex investments and can involve significant risk. Certain strategies, such
as selling options without owning the underlying investment (known as “uncovered” or “naked” options),
can result in large losses, including losses greater than the amount initially invested. Other strategies, such
as spreads or covered calls, may help limit some risks but can also reduce potential gains and may not
protect against losses if the underlying investment declines in value. Options are affected by many of the
same risks as stocks, including market movements, company-specific risks, and economic conditions.
Portfolio Turnover Risk. Funds that trade frequently may incur higher transaction costs, which can reduce
performance. This risk may be higher for funds using active management or strategies involving mortgage-
backed securities and TBA roll transactions.
Premium/Discount Risk. ETFs, closed-end funds, BDCs, and similar securities may trade above or below
NAV. If a client buys at a premium or sells at a discount, the client may experience losses unrelated to the
performance of the underlying holdings.
Prepayment and/or Call Risk. Certain fixed income investments may be called or repaid earlier or later than
expected. This may cause a fund to reinvest at lower interest rates or hold lower-yielding investments,
which may reduce yield or market value.
Private Equity Funds may issue capital calls on short notice. Failure to meet a capital call may result in
serious consequences, including dilution, penalties, or loss of the entire investment. Private equity funds
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may have high fees, limited liquidity, delayed tax reporting, valuation challenges, and significant risks
related to the underlying portfolio companies. EWM is an adviser to one or more private equity funds that
it recommends to certain clients.
Private Equity – Secondary Investments (also often called private equity secondaries or secondaries)
involve the purchase or sale of existing interests in private equity or other alternative investment funds.
These transactions can be complex and costly because there is often no established trading market. Buyers
may assume unfunded commitments, and investments are generally illiquid and long-term. Risks include
limited liquidity, valuation uncertainty, high transaction costs, lack of diversification, possible dilution, and
the business and management risks of the underlying portfolio companies. There is no assurance that a
liquidity event, such as a sale or initial public offering, will occur.
Private Equity - Co-Investments (or co-investment) are minority investments made directly in operating
companies alongside a lead private equity or venture capital sponsor. These investments are typically
passive and non-controlling. Risks may include concentration risk, business risk, liquidity risk, lack of
control, and manager risk. Fees may be materially higher than those of traditional investments.
Private Placements are investments that are not publicly traded and are subject to less regulation than public
securities. These investments are typically long-term and may be difficult or impossible to sell, and any
sale may occur at a significant discount. Because there is no active market, valuing these investments can
be difficult. Private placements often have higher fees and expenses than traditional investments. EWM
may recommend private placements directly or through funds, including private equity, private credit,
hedge funds, real estate, and similar investments. EWM is also an adviser to certain private funds it may
recommend. Clients should carefully review the investment’s offering documents for a full description of
the risks, fees, and terms.
Precious Metals prices may be volatile and are affected by supply and demand, new discoveries, and
changes in mining and refining. Precious metals do not pay interest or dividends, so returns depend on price
appreciation. They may also involve storage and insurance costs and less favorable tax treatment, including
taxation as collectibles.
Proxy ETF. A proxy ETF is used when no ETF provides direct access to a targeted asset class. Proxy ETFs
may not perform like the asset class they are intended to represent. As a rules-based index, certain
alternative investment asset classes (private equity and venture capital) utilize the same ETF, currently the
Invesco Global Listed Private Equity ETF (PSP—NYSEArca) as their representative proxy. The
performance of a higher weighted ETF within a portfolio will influence overall portfolio returns to a greater
extent (positive or negative) than positions with lesser weightings.
Qualified Opportunity Zones (“QOZ”) may offer tax benefits for investing in real estate located in certain
distressed areas. These investments involve the risks of real estate investing, leverage, property manager
risk, and asset manager or developer risk. QOZ investments are generally long-term and may face supply
and exit risks that affect value at the end of the holding period. Potential distributions, returns, and
appreciation are not guaranteed.
Real Estate Funds (including REITs) are affected by the risks of the real estate market, which can be
cyclical and volatile. Performance may be affected by local and national economic conditions, property
market conditions, competition, interest rates, access to debt and equity capital, capital expenditure needs,
real estate taxes, operating expenses, changes in laws or zoning, and environmental liabilities or compliance
costs.
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Sampling Index Risk. Some index funds use representative sampling rather than holding every security in
the index. As a result, the fund may hold securities not included in the index and may not track the index
as closely as a fully replicated fund.
Short Selling Risk. Short selling involves the risk of potentially unlimited loss because the price of a security
can continue to rise. A short seller must also pay amounts due on borrowed securities, such as dividends or
other distributions. Brokers may require the return of borrowed securities or liquidate positions, which can
cause substantial losses, especially if prices rise sharply.
Tracking Error Risk. Index funds seek to track a benchmark index but may not do so successfully. The
difference between a fund’s performance and its benchmark is called tracking error. Tracking error may be
caused by fees, trading costs, cash holdings, sampling, valuation differences, and market or liquidity
conditions.
Unseasoned Issuers Risk. Securities issued by newer companies may be more volatile and harder to sell
because these issuers often have limited operating histories, fewer financial resources, narrower product
lines, and greater dependence on key personnel. These issuers may be more susceptible to losses and
bankruptcy.
Volatility Risk. Some securities or funds may increase or decrease significantly in value over short periods.
This may cause sharp changes in portfolio value. All investments, whether held short-term or long-term,
involve risk of loss.
Liquidity Risks
While EWM considers liquidity when selecting investments, some securities may be less liquid, have lower
trading volume, or wider bid-ask spreads. This may make it more difficult to buy or sell these investments
at favorable prices or achieve favorable execution, particularly during periods of market stress or high
trading activity across client accounts.
Market Risk
The success of some recommendations depends on correctly assessing future price movements in stocks,
bonds, and other investments over both short and long periods. There is no assurance that EWM will
accurately predict those movements. Incorrect assessments may result in losses.
Information Security Risks
Like other financial services firms, EWM faces operational and information security risks, including
cybersecurity risks. Cyber incidents may result from intentional attacks or unintentional events and may
include unauthorized access to systems or credentials, theft of assets or sensitive information, data
corruption, or operational disruption, including denial-of-service attacks. EWM maintains policies and
procedures reasonably designed to reduce cybersecurity risk and the risk of violations of federal securities
laws arising from cyber incidents. However, no system is completely secure, and EWM cannot guarantee
that a cyber incident will not occur.
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E. Recommendation of Particular Types of Securities
As described in Item 4 (Advisory Business), EWM may provide investment advice with respect to a broad
range of securities. EWM does not generally recommend one type of security over another, as investment
recommendations are based on each client’s individual objectives, financial circumstances, and risk
tolerance.
All investments involve risk, and it is not possible to identify all risks associated with every investment or
strategy. In addition, the risks associated with a particular investment may vary significantly within the
same asset class. As a general matter, investments with higher expected returns are subject to a greater risk
of loss.
Item 9 Disciplinary Information
EWM has been providing investment advisory services as a registered investment adviser since 1996,
including services provided under its current name and ownership since 2013. EWM has no reportable
disciplinary events under this item.
Item 10 Other Financial Industry Activities and Affiliations
A. Registration as a Broker-Dealer
EWM, its representatives, and its affiliates are not registered as broker-dealers or representatives of a
broker-dealer, and none have any pending applications for such registration.
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or
a Commodity Trading Advisor
EWM, its representatives, and its affiliates are not registered as a futures commission merchant, commodity
pool operator, or commodity trading advisor, and none have any pending applications for such registration.
EWM and these individuals are also not associated persons of any such entities.
C. Registration Relationships Material to this Advisory Business and Possible
Conflicts of Interests
ETF Model Solutions®, LLC (“ETFMS”) and Global Alternative Investment Management LLC (“Global
Alts”) are affiliated with Endowment Wealth Management, Inc. (“EWM”) through common ownership and
control. Each entity is a separate legal entity and maintains its own operations, services, and business
activities.
The affiliation creates a potential conflict of interest because EWM may have an incentive to recommend
services or investments involving its affiliates. EWM addresses this conflict through disclosure and by
acting in the best interest of its clients.
Clients are not required to engage ETFMS, Global Alts, or any affiliated entity as a condition of receiving
advisory services from EWM and are free to select any service provider of their choice.
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Affiliated Funds and Fund Manager. EWM and its affiliate, Global Alts, serve as manager to one or more
private special purpose vehicle (“SPV”) funds that may be offered to certain clients. EWM and Global Alts
may receive management fees and/or performance-based compensation (a share of gains) from these funds,
which are borne by the investors in the funds.
This arrangement creates a conflict of interest because EWM and Global Alts have a financial incentive to
recommend investments in these affiliated funds over other investments, including unaffiliated managers
or traditional assets, where such compensation would not be received.
EWM addresses this conflict by disclosing it to clients and by not investing client assets in affiliated SPV
funds on a discretionary basis. Clients are not required to invest in any affiliated SPV fund.
EWM, Global Alts, and their principals, employees, or related persons may invest their own capital in these
affiliated funds alongside client investments. These investments are generally made on the same terms and
conditions as those offered to Clients, unless otherwise disclosed in the applicable offering documents.
Global Alts relies on the investment adviser registration of EWM based on certain no-action letters issued
to the American Bar Association. Its advisory activities are subject to the Investment Advisers Act of 1940
and applicable rules and are subject to examination by the Securities and Exchange Commission.
EWM and/or Global Alts may also provide accounting services to the affiliated funds and may be
compensated on an hourly basis. As disclosed in Item 4, EWM waives its advisory fees on client assets
invested in these affiliated SPV funds. However, the affiliation with Global Alts still creates a conflict of
interest because the affiliated entity may receive management and performance-based compensation.
Affiliated Registered Investment Adviser. EWM is affiliated, through common control and ownership, and
shares offices, with ETFMS, a registered investment adviser. Some or all EWM’s investment adviser
representatives are also registered as investment adviser representatives of ETFMS. Under a licensing
agreement, ETFMS licenses its investment model portfolios to EWM, and EWM may invest client assets
in these models on a discretionary basis. EWM does not charge additional fees beyond its standard asset-
based advisory fee for client assets invested in model portfolios it has licensed from ETFMS.
A client may have a separate advisory relationship with both Embark and EWM. However, EWM does not
necessarily provide advisory services to Embark clients. The services and fees of each firm are separate and
distinct.
This relationship creates a conflict of interest because EWM may have an incentive to use ETFMS model
portfolios. EWM addresses this conflict by not charging additional fees for use of these models and by
maintaining separate advisory agreements and fee structures for each firm. Clients are not required to
engage ETFMS or any affiliated person for services outside of EWM.
D. Selection of Other Advisers or Managers and How We are Compensated for
Those Selections
EWM may recommend that clients use third-party investment managers, either directly or through a
separately managed account (“SMA”) program, including programs offered by Envestnet.
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Accounts managed through an SMA program are subject to program or platform fees, which may include
fees charged by Envestnet and the third-party investment manager. In addition, accounts in model
management programs may incur custodial and brokerage fees.
Clients will pay EWM its standard advisory fee in addition to the fees charged by the third-party investment
managers.
EWM does not receive referral fees, revenue sharing, or other direct compensation for recommending third-
party managers. However, EWM may receive other economic benefits from these managers. Please see
Item 14 (Client Referrals and Other Compensation) for additional information.
E. Insurance
EWM may refer clients to individuals licensed to sell insurance products. EWM, its affiliates, and its
associated persons do not receive referral fees, commissions, or other compensation for these referrals.
F. Related Person- Accountant
Christopher Platten, CPA, is an employee of Endowment Wealth Management, Inc. (“EWM”) and its
affiliates. Mr. Platten provides tax preparation services on a limited basis outside of his role with EWM.
These services are performed independently and not on behalf of EWM.
Mr. Platten does not provide tax advice or tax preparation services as part of EWM’s advisory services, and
he does not share any fees earned from these services with EWM.
EWM or its associated persons may refer clients to Mr. Platten for tax preparation services. Clients are not
required to engage Mr. Platten and are free to select any tax professional of their choosing.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. Description of EWM’s Code of Ethics
EWM has adopted a Code of Ethics designed to comply with applicable laws and regulations and to
establish standards of conduct for its associated persons. The Code of Ethics reflects EWM’s commitment
to its fiduciary duty to act with honesty, good faith, and fair dealing in the best interests of clients.
EWM requires that its associated persons conduct their personal financial activities in a manner that does
not harm clients or take advantage of access to client information. All associated persons are expected to
follow these standards.
The Code of Ethics also requires certain associated persons to report their personal securities holdings and
transactions. These reports are reviewed periodically by the Chief Compliance Officer or designated
personnel. Associated persons are also required to report any violations of the Code of Ethics.
In addition, EWM maintains and enforces written policies reasonably designed to prevent the misuse or
improper sharing of material non-public information about clients or their account holdings.
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Clients and prospective clients may request a copy of EWM’s Code of Ethics by contacting EWM at the
telephone number listed on the cover page of this brochure.
B. Material Financial Interest (Potential Conflict of Interest)
General Conflicts of Interest. A potential conflict of interest is governed by the duties owed by Registered
Investment Advisors to their clients including the disclosure of all material facts concerning the client
relationship, ensuring that investment advice is suitable for the client’s needs, and seeking the best
execution of client transactions. Where a conflict of interest exists, we will seek to eliminate, mitigate, or
disclose the conflict that may interfere with EWM’s ability to render disinterested advice to allow the
client to give informed consent or to take other action to protect their interests.
Alternative Investments. EWM has a conflict of interest when recommending or allocating client assets to
alternative investments. In taxable accounts, EWM charges a flat advisory fee of 1.00% on these
investments, which is higher than the fees typically charged on traditional investments under EWM’s
standard fee schedule. This creates a financial incentive for EWM to favor alternative investments over
other investment options.
Venture Capital /Private Equity Performance Fee. EWM may charge performance-based fees on certain
venture capital or private equity investments held in client accounts. These investments generally involve
higher risk, limited liquidity, and longer holding periods. The receipt of performance-based compensation
creates a conflict of interest because EWM has a financial incentive to recommend or allocate client assets
to these investments to earn management and performance fees. This may conflict with a client’s interest
in receiving objective investment advice.
SPV Funds. EWM and its affiliates, including Global Alts, may create, manage, or offer private special
purpose vehicle (“SPV”) funds. These arrangements create several conflicts of interest:
EWM and/or its affiliates typically receive management fees, performance-based compensation
(such as carried interest), or other compensation from affiliated funds, which may be in addition to
advisory fees paid by clients. This creates an incentive to recommend affiliated funds over other
investments.
EWM may have an incentive to allocate investment opportunities, time, or resources in a manner
that benefits affiliated funds or its own invested capital. EWM personnel may have personal or
affiliated investments in these funds, which may create differing economic interests from clients.
EWM may receive distributions of publicly traded securities as incentive compensation from SPV
funds. This creates a conflict of interest because EWM may hold the same or similar securities as
clients but may have different financial objectives or time horizons.
EWM seeks to address these conflicts through internal policies and procedures, including allocation
policies, supervisory oversight, and disclosure practices. Clients are not obligated to invest in any SPV
Funds managed by EWM or Global Alts.
IAR Ownership in Private Companies. EWM or its investment adviser representatives (IARs”) may hold
direct or indirect ownership interests in private companies. EWM may also sponsor, manage, or raise capital
for funds that invest in these companies.
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This creates a conflict of interest because EWM or its IARs may have a financial incentive to recommend
investments in funds that invest in companies in which they have a personal interest. Such recommendations
may be influenced by a desire to increase the value of those holdings or create liquidity opportunities, rather
than being based solely on the client’s best interests.
EWM/Global Alts Incentive Distributions. EWM from time to time will receive distributions of shares of
publicly traded equities as earned incentive compensation arising from management of the SPV Funds.
EWM may have a conflict of interest arising from the circumstance that EWM holds the same or similar
securities as its clients that were received from the SPV Funds. EWM’s financial objectives and
investment time horizon may be different than those of the client who received the same securities as a
distribution. To mitigate this conflict, EWM maintains policies and procedures designed to ensure that
investment decisions are made in the best interest of Clients, including trade allocation practices, periodic
reviews, and adherence to fiduciary obligations.
Personal Trading by Associated Persons. EWM and its associated persons may own securities (such as
ETFs and mutual funds) that are held in our model portfolios and/or are recommended to clients. This
may be deemed a conflict of interest. EWM has adopted a Code of Ethics to address any conflicts or
potential conflicts of interest. EWM restricts its associated persons from transacting in securities during
any model trading periods unless such employees have invested in the Model and account is being
rebalanced along with all others in the model. EWM’s compliance officer reviews personal securities
transactions of associated persons on a quarterly basis to ensure compliance with this policy.
EWM seeks to mitigate these conflicts through policies and procedures that include:
Requiring adherence to fiduciary duties to act in the best interest of our clients.
Providing full and fair disclosure of material conflicts, fees, and holdings.
Evaluating recommendations for consistency with client objectives and suitability.
Supervisory review of communications and recommendations; and
Requiring pre-clearance and ongoing disclosure of personal investments by IARs.
EWM does not allocate investment opportunities based on fee structure and seeks to allocate opportunities
on a fair and equitable basis over time. Clients are not required to invest in any private investment or fund
recommended by EWM or its IARs, including those in which EWM or its IARs have a financial interest.
Clients should review offering documents carefully and determine whether such investments are
appropriate for their circumstances. Clients may decline these recommendations without penalty, and EWM
will continue to provide advisory services regardless of participation.
C. Participation or Interest in Client Transactions
EWM, its employees, and its affiliates do not engage in proprietary trading and do not receive revenue
sharing or similar compensation from third parties in connection with securities transactions recommended
to clients.
D. Investing Personal Money in the Same Securities as Clients
EWM, its affiliates, and its associated persons may buy or sell the same securities for their own accounts
that are recommended to clients. These activities create a potential conflict of interest. All such transactions
must be conducted in accordance with EWM’s policies and procedures.
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EWM has adopted a Code of Ethics that establishes standards of conduct for its associated persons and
requires compliance with applicable securities laws. Consistent with Section 204A of the Investment
Advisers Act of 1940, the Code of Ethics includes policies designed to prevent the misuse of material non-
public information.
Our Code of Ethics also requires pre-clearance of certain personal trades, restrictions on trading during
blackout periods, and ongoing monitoring of personal securities transactions. The Chief Compliance
Officer reviews personal trading activity on a periodic basis to help ensure compliance with these policies.
E. Trading Securities At/Around the Same Time as Clients’ Securities
Representatives of EWM and its affiliates may buy or sell securities for their own accounts at or around the same time
as client transactions. This creates a conflict of interest because representatives may benefit from trading before or
after client transactions (sometimes referred to as “front-running” or “following” trades).
EWM addresses this conflict through its Code of Ethics, which includes requirements for preclearance of certain
trades, restrictions on trading during blackout periods, and monitoring of personal trading activity. EWM seeks to
prevent trading that disadvantages clients and requires that client interests be placed ahead of personal interests.
Item 12 Brokerage Practices
A. Recommendation of Custodians
Client assets must be held with a “qualified custodian,” typically a broker-dealer or bank. Custodians hold
client assets and execute transactions. Clients establish accounts with a custodian and authorize EWM to
place trades through that custodian. In practice, EWM generally requires clients to maintain their accounts
with Fidelity Investments (“Fidelity”) or another approved platform or custodian in order to receive
EWM’s services. As a result, client choice of custodian is limited. EWM does not have discretionary
authority to select custodians for separately managed accounts and does not negotiate commissions on a
trade-by-trade basis for accounts holding traditional assets.
Custodians typically do not charge separate custody fees but are compensated through commissions and
other transaction-based or asset-based fees. Clients are subject to the fee schedules established by the
custodian. Clients may reduce certain fees, such as commissions, by electing electronic delivery of
statements and trade confirmations. Clients are responsible for selecting their preferred delivery method.
Although clients select the custodian, EWM may recommend custodians for execution and custody
services. For separately managed accounts and other accounts holding traditional assets, EWM does not
maintain custody of client assets. However, EWM may be deemed to have custody in certain
circumstances, including:
when clients authorize EWM to deduct advisory fees directly from their accounts (see Item 15);
or
when clients provide written Standing Letters of Authorization permitting EWM to transfer funds
from their accounts to third parties.
Clients establish accounts with a custodian and authorize EWM to place trades through that custodian
under the advisory agreement. In practice, EWM generally requires use of Fidelity Investments
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(“Fidelity”), a member of the New York Stock Exchange and the Securities Investor Protection
Corporation (SIPC) or another approved platform or custodian for many of its services.
EWM believes that Fidelity provides quality trade execution and custody services at competitive overall
costs. When seeking best execution for client transactions, EWM considers a number of factors and does
not rely solely on price. These factors may include the broker-dealer’s reputation, execution quality,
commission and transaction costs, financial strength, and responsiveness to both clients and EWM.
Because EWM considers multiple factors in addition to price, clients may pay higher commissions or
transaction costs than those available through other broker-dealers.
When selecting and evaluating custodians, EWM considers a range of factors, including:
The reasonableness of commissions and fees charged to clients.
Availability on the Envestnet platform.
The range of products and services available to clients and to EWM.
The ability to provide both custody and trade execution services.
Capability to execute, clear, and settle transactions efficiently.
The ability to process account transfers and client payments (such as wires and checks).
The availability of investment products, including stocks, bonds, mutual funds, and ETFs.
The quality of service and operational support.
The competitiveness of pricing and willingness to negotiate fees.
The custodian’s reputation, financial condition, regulatory history, and overall stability.
EWM’s prior experience working with the custodian on behalf of its clients.
EWM periodically reviews its custodial relationships to determine whether they continue to meet its
standards for best execution and client service.
EWM primarily uses Fidelity as its custodian. In most cases, clients are required to maintain their
accounts at Fidelity to receive EWM’s services.
If a client prefers to use a different custodian, EWM may consider that request on a case-by-case basis.
However, EWM may not be able to accommodate all such requests due to operational, service, or other
considerations. As a result, clients who do not wish to custody their assets at Fidelity may not be able to
engage EWM for advisory services.
For SPV Funds where EWM or its affiliate, Global Alts, serves as managing member, EWM or Global Alts
selects the custodian to hold fund assets, when required. Custodians are selected based on best execution
factors, as described above. For large transactions, EWM or Global Alts will negotiate commission rates
with secondary market brokers.
B. Discussion of Benefits to EWM as to Selection of Custodians
As described above, EWM generally recommends Fidelity to clients for custody and brokerage services.
EWM is independently owned and operated and is not affiliated with Fidelity or any other broker-dealer.
EWM’s recommendation of Fidelity is separate from the investment advice it provides. However, EWM
does receive certain economic benefits from Fidelity that are not typically available to retail investors,
which creates a conflict of interest.
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Form ADV Part 2 Brochure
March 30, 2026
Fidelity provides EWM with access to institutional trading, custody, technology, and investment products
that may not otherwise be available or may require higher minimum investments. These services are
provided at no cost to EWM and are not contingent on EWM directing a specific amount of assets or trading
activity to Fidelity.
These benefits are not fees paid by clients but are instead indirect economic benefits provided to EWM in
connection with its custodial relationship with Fidelity.
These services include brokerage, custody, technology, and access to certain investment products (such as
mutual funds and other investments) that may otherwise require higher minimum investments or be
available only to institutional investors. EWM does not receive payments or reimbursements from Fidelity
and does not make significant use of brokerage firm’s research. EWM does not select custodians based on
the availability of research.
Fidelity also provides additional products and services that benefit EWM but may not directly benefit client
accounts. These are not soft-dollar arrangements and are not tied to trading activity, although they are
generally available only if EWM maintains a minimum level of client assets at Fidelity.
These benefits may include:
Technology and tools to manage client accounts, including access to account data, trading systems
(including block trading), pricing and market data, billing support, and back-office functions such
as recordkeeping and reporting.
Access to certain mutual funds (including no-transaction-fee funds) and institutional managers.
Practice management tools, compliance updates, research, and financial planning resources.
Discounts or access to third-party vendors (such as compliance, insurance, and research providers)
and software
Business consulting, coaching, and educational events (often at no cost), covering topics such as
practice management, marketing, investment strategies, and regulatory compliance.
Compliance, legal, technology, marketing, and business support services, as well as publications
Fee waivers, discounts, or payment of third-party vendor costs
Occasional business entertainment and educational events
Some of these services benefit all or many of EWM’s Clients, including those not held at Fidelity, while
others may not directly benefit client accounts.
The benefits EWM receives are not based on the amount of brokerage transactions directed to Fidelity.
However, these benefits create a conflict of interest because they may influence EWM’s recommendation
of Fidelity over other custodians.
Upon request, EWM can provide a list of other custodians available through the Envestnet platform.
However, if a client chooses not to use Fidelity or another available custodian on that platform, EWM may
not be able to manage the account.
Additional information about economic benefits EWM receives is provided in Item 14.
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Endowment Wealth Management, Inc.
Form ADV Part 2 Brochure
March 30, 2026
C. Custody Services Requiring Trusts or Assets Requiring Special Handling
EWM may refer clients to Millennium Trust Company, Fiduciary Partners, Inc., Kingdom Trust, or Legacy
Private Trust Company for custody or trustee services when an account requires specialized handling or
trustee services. Clients are not required to use these providers and may choose other service providers.
EWM does not receive any compensation, revenue sharing, or other economic benefit from these firms in
connection with these referrals.
D. Brokerage for Client Referrals
EWM does not receive client referrals from broker-dealers in exchange for cash or any other compensation,
including brokerage services or research.
E. Directed Brokerage
Some clients may direct EWM to use a specific broker-dealer for transactions in their accounts. If a client
does so, EWM may not be able to combine (or “aggregate”) that client’s trades with trades for other clients
or negotiate commission rates on the client’s behalf.
As a result, the client may pay higher commissions or receive less favorable execution than they would if
EWM selected the broker. Directed brokerage may also limit EWM’s ability to obtain best execution for
the account.
Clients who direct brokerage should consider whether the broker they select provides reasonable
commissions, execution quality, and clearing and settlement services compared to those EWM would
otherwise obtain.
F. Block Trades
EWM generally places trades for each client account separately. However, when EWM buys or sells the
same security for multiple clients at or around the same time, EWM (or Envestnet and/or the broker-
dealer holding the account) may combine these transactions into a single order. This is called “block
trading.” EWM is not required to use block trading.
When block trades are used, EWM allocates the shares among participating accounts in a fair and
equitable manner. Allocations are typically based on the size of each account and are not based on
account performance or the amount or structure of advisory fees.
When orders are combined, each participating account generally receives the same average price per
share and pays a proportionate share of transaction costs for that trade.
Accounts owned by EWM or its employees may participate in block trades along with client accounts.
These accounts are not given preferential treatment.
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Endowment Wealth Management, Inc.
Form ADV Part 2 Brochure
March 30, 2026
Item 13 Review of Accounts
EWM provides ongoing portfolio management services. Accounts are reviewed at least quarterly by Robert
L. Riedl, President and Director of Wealth Management, Prateek Mehrotra, Vice President and Chief
Investment Officer, or other investment adviser representatives.
These reviews consider each client’s individual circumstances, including risk tolerance, investment goals,
market conditions, the performance, and characteristics of securities held in the account, sector exposure,
and overall asset allocation. Reviews include accounts holding both traditional and alternative investments.
Clients receive account information directly from their custodian(s), including trade confirmations, periodic
account statements (typically monthly or quarterly), and year-end tax documents. Clients may also access
their account information online through their custodian and, if applicable, through Envestnet.
EWM also offers clients complimentary access to the eMoney wealth portal. This portal allows clients to
view and consolidate financial information, including assets not managed by EWM, and provides a secure
document vault for storing important financial documents.
Item 14 Client Referrals and Other Compensation
Please see the “Brokerage Practices” section of this brochure for a description of the research and other
benefits EWM may receive in connection with its relationships with recommended custodians.
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients
EWM is compensated through fees paid by its clients, including advisory fees, performance-based fees,
and administrative fees, as described in this brochure. EWM and its personnel may also receive certain
indirect economic benefits from third party providers such as Envestnet, mutual fund or ETF sponsors,
and other investment-related firms.
These benefits may include attendance at educational conferences, seminars, and meetings; meals; small
gifts; or reimbursement for certain educational, marketing, or product-related events. EWM personnel
may also receive access to advisor-only websites that provide research, practice management resources,
newsletters, educational materials, software, and investment data.
These benefits create a potential conflict of interest because they provide value to EWM and its
personnel. EWM has policies and procedures designed to address this conflict, including restrictions on
accepting items of material value or inappropriate gifts, entertainment, or accommodations that could
influence decision-making.
EWM believes these benefits are modest and do not affect the advice provided to clients. EWM is not
obligated to recommend, and will not recommend, any investment based on the receipt of these benefits.
B. Compensation to Non-Advisory Personnel for Client Referrals
EWM pays referral fees to unaffiliated individuals or entities (“Solicitors”) for referring clients. These
Solicitors must comply with applicable legal requirements in the jurisdictions where they operate.
If a client is referred by a Solicitor, the Client will receive this brochure (Form ADV Part 2), Form ADV
Part 3 (if applicable), and a separate disclosure statement from the Solicitor at the time of the referral.
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Endowment Wealth Management, Inc.
Form ADV Part 2 Brochure
March 30, 2026
Solicitors are compensated either:
A percentage of the advisory fee (subject to an annual dollar cap) paid by the client for as long as
the client relationship continues (or as long as required under the agreement), or
A one-time, flat referral fee
Clients do not pay additional fees as a result of these arrangements. Referral fees are paid by EWM from
its advisory fees.
Because Solicitors are compensated for referrals, they have a financial incentive to recommend EWM,
which creates a conflict of interest. Clients are not obligated to retain EWM and may be able to obtain
similar services at a lower cost from other firms.
Solicitors are limited to marketing and educational activities. They are not authorized to provide
investment advice on behalf of EWM.
C. Economic Benefits Provided to Unaffiliated Third Parties
Depending on the service or strategy, EWM may require clients to maintain accounts with Fidelity,
Envestnet, or another approved platform or custodian. As a result, these firms receive fees, commissions,
or other revenue from services provided to client accounts.
Because EWM directs client assets to these firms, they receive an indirect economic benefit. This creates
a conflict of interest, as EWM’s requirement that clients use these providers results in revenue to those
firms.
Item 15 Custody
Traditional Assets. EWM is considered to have limited custody of client assets in certain situations. For
example, EWM is authorized to deduct its advisory fees directly from client accounts held at independent
custodians. In addition, if a client provides a Standing Letter of Authorization (“SLOA”), EWM may have
the authority to transfer funds from the client’s account to a designated third party.
Because of this limited custody, EWM relies on the applicable custody rule provisions for fee deduction
authority and standing letters of authorization and therefore is not required to undergo an annual surprise
examination for those arrangements.
Client funds and securities are held by independent, qualified custodians, such as banks or broker-dealers.
Clients receive account statements directly from these custodians at least quarterly. These statements show
all account activity, including the advisory fees deducted by EWM.
Clients should review their custodian statements carefully for accuracy. If a client has questions about their
statement or does not receive a statement, they should contact EWM using the phone number listed on the
cover of this brochure.
Alternative Assets. For certain special purpose vehicle (“SPV”) funds advised by EWM, EWM or its
affiliate, Global Alts, may be deemed to have custody. This is disclosed in EWM’s Form ADV Part 1.
For these assets, EWM follows applicable custody requirements, including arranging for an annual audit of
each fund by an independent public accounting firm that is registered with and subject to inspection by the
Public Company Accounting Oversight Board (PCAOB). Audited financial statements are provided to
investors in these funds within 120 days after the end of each fiscal year, or as otherwise required.
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Endowment Wealth Management, Inc.
Form ADV Part 2 Brochure
March 30, 2026
Item 16 Investment Discretion
Before EWM can buy or sell securities for your account, you must sign a discretionary management
agreement and/or trading authorization form.
If you grant EWM discretionary authority, EWM may select the type and amount of securities to be bought
or sold for your account without obtaining your approval before each transaction. You may place reasonable
restrictions on this authority. For example, you may limit investments in certain securities, industries, or
asset classes, or set maximum percentage limits for specific investments.
Additional information about EWM’s discretionary services is provided in the “Advisory Business” section
of this brochure.
If you choose a non-discretionary arrangement, EWM will obtain your approval before executing any
transactions in your account. You have the right to accept or reject any recommendation made by EWM.
Item 17 Voting Client Securities
Proxy voting authority varies by account type and investment structure. For most separately managed
client accounts, EWM does not vote proxies unless specifically agreed. For certain private funds managed
by EWM or its affiliate, EWM or Global Alts votes proxies at the fund level. For accounts managed by
third-party managers, proxy voting may be handled by the applicable manager.
When EWM does vote proxies, it does so in what it believes to be the best interests of clients as a whole.
Clients for whom EWM votes proxies may request information on how their proxies were voted by
contacting Prateek Mehrotra, Chief Investment Officer. Clients may also request a copy of EWM’s proxy
voting policy.
For clients where EWM does not have proxy voting authority, clients are responsible for voting their own
proxies and making decisions regarding corporate actions for their investments, including stocks, ETFs,
mutual funds, and other securities. Upon request, EWM may provide advice on proxy voting or corporate
actions.
If EWM receives proxy materials (paper or electronic) for accounts where it does not have voting
authority, EWM will forward those materials to the client. If the client has consented to electronic
communications, EWM will forward electronically-received proxy materials by email.
For private funds managed by EWM, EWM votes proxies and acts on corporate actions in what it
believes to be the best interests of the fund. Global Alts follows the same approach for private funds it
manages.
For clients invested in separately managed accounts, the third-party asset manager may vote proxies.
Clients should review the proxy voting policies of those managers for more information.
Item 18 Financial Information
A. Balance Sheet
EWM does not require or solicit clients to pay more than $1,200 in fees six months or more in advance.
As a result, EWM is not required to include a balance sheet in this brochure.
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Endowment Wealth Management, Inc.
Form ADV Part 2 Brochure
March 30, 2026
B. Financial Condition
EWM is not aware of any financial condition that is reasonably likely to impair its ability to meet its
contractual commitments to clients.
C. Bankruptcy
EWM has not been the subject of a bankruptcy petition in the past ten years.
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