Overview
- Headquarters
- Santa Rosa, CA
- Total Firm Assets
- $119 million
- Average High-Net-Worth Client Portfolio Size
- $3.5 million
- Stated Minimum Account Size
- $1,000,000
Fee Disclosure
ENSPIRE WEALTH MANAGEMENT ADV2A & 2B
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $2,000,000 | 1.00% |
| $2,000,001 | $5,000,000 | 0.75% |
| $5,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.40% |
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $42,500 | 0.85% |
| $10 million | $67,500 | 0.68% |
| $50 million | $227,500 | 0.46% |
| $100 million | $427,500 | 0.43% |
Clients
- High-Net-Worth Share of Firm Assets
- 85.02%
- Number of High-Net-Worth Clients
- 29
- Total Client Accounts
- 130
- Discretionary Accounts
- 130
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 325723
Primary Brochure: ENSPIRE WEALTH MANAGEMENT ADV2A & 2B (2026-09-29)
View Document Text
ITEM 1 - COVER PAGE
Form ADV, Part 2A Brochure
Enspire Wealth Management, LLC
90 South E Street
Suite 300
Santa Rosa, CA 95404
Tel: (707) 525-1099
www.enspirewealth.com
September 29, 2026
This brochure provides information about the qualifications and business practices of
Enspire Wealth Management, LLC. If you have any questions about the contents of this
brochure, please contact us at (707) 525-1099 or mark@enspirewealth.com. The
information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Any reference to or use of the terms “registered investment adviser” or “registered,” does
not imply that Enspire Wealth Management, LLC, or any person associated with Enspire
Wealth Management, LLC has achieved a certain level of skill or training. Additional
information about Enspire Wealth Management, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov.
ITEM 2 - MATERIAL CHANGES
The purpose of this page is to inform you of material changes to our brochure. If you are receiving
this brochure for the first time, this section may not be relevant to you.
Enspire Wealth Management, LLC (“Enspire”) reviews and updates our brochure at least annually
to confirm that it remains current. We made the following material changes to our brochure with
the annual update, dated February 18, 2026:
Item 1 – Cover Page
• We updated our main office address to 90 South E Street, Suite 300, Santa Rosa, CA 95404
Item 4 – Advisory Business
• We no longer operate as a related adviser of Meritas Wealth Management.
Please see the corresponding sections in this brochure for complete information regarding the
above changes.
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ITEM 3 - TABLE OF CONTENTS
ITEM 1 - COVER PAGE ............................................................................................................. 1
ITEM 2 - MATERIAL CHANGES ............................................................................................. 2
ITEM 3 - TABLE OF CONTENTS ............................................................................................ 3
ITEM 4 - ADVISORY BUSINESS .............................................................................................. 5
Description of Advisory Firm ..................................................................................................... 5
Advisory Services Offered .......................................................................................................... 6
Tailored Services and Client Imposed Restrictions .................................................................... 8
Wrap Fee Programs..................................................................................................................... 8
Assets Under Management ......................................................................................................... 8
ITEM 5 - FEES AND COMPENSATION .................................................................................. 9
Fee Schedule ............................................................................................................................... 9
Billing Method ............................................................................................................................ 9
Other Fees and Expenses .......................................................................................................... 10
Termination ............................................................................................................................... 10
Other Compensation ................................................................................................................. 11
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT........ 11
ITEM 7 - TYPES OF CLIENTS................................................................................................ 11
Account Requirements .............................................................................................................. 11
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF
LOSS ............................................................................................................................................ 11
Methods of Analysis and Investment Strategies ....................................................................... 11
Investing Involves Risk............................................................................................................. 13
Specific Security Risks ............................................................................................................. 14
Financial Planning .................................................................................................................... 18
ITEM 9 - DISCIPLINARY INFORMATION ......................................................................... 18
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ....... 18
Unaffiliated Accounting Firm ................................................................................................... 18
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING .................................................................. 19
Code of Ethics ........................................................................................................................... 19
ITEM 12 - BROKERAGE PRACTICES ................................................................................. 21
The Custodian and Brokers We Use ......................................................................................... 21
Aggregation and Allocation of Transactions ............................................................................ 24
ITEM 13 - REVIEW OF ACCOUNTS ..................................................................................... 25
Managed Account Reviews ...................................................................................................... 25
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Account Reporting .................................................................................................................... 25
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ................................ 26
Schwab Support Products and Services .................................................................................... 26
Outside Referrals ...................................................................................................................... 26
ITEM 15 - CUSTODY ................................................................................................................ 26
ITEM 16 - INVESTMENT DISCRETION .............................................................................. 27
Discretionary Management ....................................................................................................... 27
Non-Discretionary Management ............................................................................................... 27
ITEM 17 - VOTING CLIENT SECURITIES .......................................................................... 28
Proxy Voting ............................................................................................................................. 28
Class Actions ............................................................................................................................ 28
ITEM 18 - FINANCIAL INFORMATION .............................................................................. 28
Form ADV, Part 2B Brochure Supplement ................................................................................ i
ITEM 1 - COVER PAGE ............................................................................................................ i
Mark G. Leavitt, CPA .................................................................................................................. ii
Item 2 - Educational Background and Business Experience ...................................................... ii
Item 3 - Disciplinary Information ............................................................................................... ii
Item 4 - Other Business Activities ............................................................................................. iii
Item 5 - Additional Compensation ............................................................................................. iii
Item 6 - Supervision ................................................................................................................... iii
Kaden Wootton, CFP®................................................................................................................. iv
Item 2 - Educational Background and Business Experience ..................................................... iv
Item 3 - Disciplinary Information ............................................................................................... v
Item 4 - Other Business Activities .............................................................................................. v
Item 5 - Additional Compensation .............................................................................................. v
Item 6 - Supervision .................................................................................................................... v
Privacy Policy ............................................................................................................................... A
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ITEM 4 - ADVISORY BUSINESS
Description of Advisory Firm
Enspire Wealth Management, LLC (“Enspire,” “we,” “our,” or “us”), is a limited liability
company headquartered in Santa Rosa, California. Mark Leavitt founded Enspire and registered
the firm in 2023. Enspire is registered as an investment adviser with the U.S. Securities and
Exchange Commission.
Fiduciary Duty
Registered investment advisers are considered fiduciaries under federal law. Our fiduciary duty
carries with it an obligation to act in the best interest of our clients pursuant to a relationship of
trust and confidence. It encompasses a duty of care and a duty of loyalty.
Duty of Care
The duty of care includes, among other things:
1. the duty to provide advice that is in the best interest of the client;
2. the duty to seek best execution of a client’s transactions where the adviser has the
responsibility to select broker-dealers to execute client trades; and
3. the duty to provide advice and monitoring over the course of the relationship.
The duty to provide advice suitable to each client based on a reasonable understanding of the
client’s objectives is a critical component of the duty of care. Providing suitable advice includes
making a reasonable inquiry into the client’s financial situation, investment experience, and
financial goals and then updating this information as necessary throughout the course of the
relationship to reflect the client’s changing objectives over time and adjusting the advice we
provide to reflect any changed circumstances.
When Enspire has the responsibility to select broker-dealers to execute client trades in
discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each
transaction are the most favorable under the circumstances. In doing so, we consider the full
range and quality of a broker’s services and so the determinative factor is not necessarily the
lowest possible commission cost but whether the transaction represents the best qualitative
execution. Moreover, we periodically and systematically evaluate the execution we receive on
behalf of our clients.
Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in
the best interest of the client, taking into account the scope of the agreed relationship. This scope
is indicated by the duration and nature of the services as outlined in each client’s advisory
arrangement and extends to all personalized advice provided to clients.
Duty of Loyalty
Enspire adheres to a duty of loyalty where we seek to serve the best interests of our clients and
never subordinate the interests of our clients to our own. Simply put, Enspire cannot place its
own interests ahead of the interests of our clients. In observance of this duty, we must make full
and fair disclosure to clients of all material facts relating to the advisory relationship. Further, we
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also seek to eliminate or at least expose through full and fair disclosure all conflicts of interest
which might incline Enspire, consciously or unconsciously, to render advice that is not
disinterested. We believe that in order for disclosure to be full and fair, it should be sufficiently
specific so that each client is able to understand the material fact or conflict of interest and make
an informed decision whether to provide consent. Consequently, we provide this ADV 2A
brochure to all prospective clients at or before entering into a contract so that they can use the
information within to decide whether or not to enter into an advisory relationship.
Advisory Services Offered
Enspire offers the following services to advisory clients:
Investment Management Services
Enspire offers wealth management services to advisory clients. We employ a consultative
process to identify a client’s financial circumstances and goals. Enspire will consult with clients
to help them determine an appropriate level of portfolio risk based on their needs, investment
goals, and willingness and ability to accept market risk. After considering these factors and
general suitability information provided by the client, we will propose an asset allocation
strategy.
Enspire generally invests client assets in a diversified portfolio of mutual funds and/or exchange-
traded funds ("ETFs"). Once the portfolio is constructed, we monitor and manage the
investments on a discretionary basis. Enspire may also occasionally utilize additional types of
investments if we believe that they are appropriate to address the individual needs, goals, and
objectives of the client or in response to client inquiry. Enspire may offer investment advice on
any investment held by the client at the start of the advisory relationship. We also offer non-
discretionary advisory services to participant-directed retirement plans. We describe the material
investment risks for the securities that we utilize in Item 8 below. We discuss our discretionary
and non-discretionary authority below under Item 16 - Investment Discretion. For more
information about the restrictions clients can put on their accounts, see Tailored Services and
Client Imposed Restrictions in this item below. We describe the fees charged for investment
management services below under Item 5 - Fees and Compensation.
Financial Planning Services
As part of the financial planning process, Enspire collects information about the client’s financial
situation and needs, which may include net worth, income, expenses, taxes, investments,
retirement plans, life insurance, disability insurance, health insurance, long term care insurance,
business agreements, divorce papers, pre-nuptial agreements, estate documents, and any other
documents that pertain to their overall financial picture. In addition, Enspire asks the client about
their future goals and objectives. Enspire then develops a personalized plan including specific
recommendations in applicable areas.
Enspire may also work with the client to provide advice regarding a particular aspect of the
client’s financial situation. Areas of focus might include:
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1. Preparing for or living in retirement
2. Investment strategies
3. Estate planning strategies
4. Tax planning
5. Stock option analysis and planning
6. Insurance: life, disability, medical, long-term care insurance
7. Family savings and cash flow planning
8. Education planning and funding
9. Charitable gifting
10. Debt management
11. Employee benefit usage
12. Other, as determined between Enspire and the client
Enspire customarily provides financial planning services at no additional charge to the client as
part of our overall investment management services; however, we charge a fee for financial
planning services, as described in Item 5 - Fees and Compensation, when a client’s managed
portfolio does not meet the minimum size stated under Item 7 - Types of Clients. Financial plans
are generally provided in writing but do not include preparation of any kind of income tax, gift,
or estate tax returns nor preparation of any legal documents, including wills or trusts.
Limitations on Investments
Limitation by Plan Sponsor/Employer
In the event Enspire is managing assets within a retirement plan such as 401(k), 403(b), or other
employer plan, Enspire is limited to those investment providers and investment options chosen
by the plan administrator. Similarly, when we provide services to participants in an employer-
sponsored plan, the participant may be limited to investing in securities included in the plan’s
investment options. Therefore, Enspire can only select investments/make recommendations to
the client from among the available options and will not recommend or invest the client’s
account in other securities, even if there may be more suitable options elsewhere.
Mutual Fund Limitations
No Load Mutual Funds
Enspire generally limits recommendations of mutual fund(s)/selections to no load funds or load-
waived equivalents.
Treasury Inflation Protected Securities Funds (TIPS)
Enspire does not utilize individual TIPS but may utilize mutual funds and exchange traded funds
that include TIPS within the underlying fund holdings.
Real Estate Investment Trust Funds (REIT)
Enspire does not utilize individual REITs but may utilize mutual funds/ETFs that include REITs
within the underlying fund holdings.
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Our Fiduciary Duties to Clients with Retirement Plans
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interest
ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Tailored Services and Client Imposed Restrictions
Enspire manages client accounts based on the investment strategy, as discussed below under
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. Enspire applies the
strategy for each client, based on the client’s individual circumstances and financial situation.
We make investment decisions for clients based on information the client supplies about their
financial situation, goals, and risk tolerance. Our investment selections may not be suitable if the
client does not provide us with accurate and complete information. It is the client’s responsibility
to keep Enspire informed of any changes to their investment objectives or restrictions.
We generally do not permit clients to place restrictions on accounts. However, at our discretion,
we may allow client-imposed restrictions on a limited basis. Clients may request other
limitations on the account, such as when a client needs to keep a minimum level of cash in the
account. Enspire reserves the right to not accept and/or terminate management of a client’s
account if we feel that the client-imposed restrictions/limitations would limit or prevent us from
meeting or maintaining the client’s investment strategy.
Wrap Fee Programs
Enspire does not manage accounts as part of a wrap or bundled fee program.
Assets Under Management
Enspire manages client assets in discretionary accounts on a continuous and regular basis. As of
December 31, 2025, the total amount of assets under our management was $119,296,012.
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ITEM 5 - FEES AND COMPENSATION
Fee Schedule
Investment Management Services
Enspire charges advisory fees for investment management services. Enspire’s advisory fees are
charged based on a percentage of the market value of the portfolio, per the following schedule:
Assets Under Management
The first $2,000,000
The next $3,000,000
The next $5,000,000
On amount over $10,000,000
Annual Fee %
1.00%
0.75%
0.50%
0.40%
Enspire typically aggregates the accounts of clients living in the same household with each other
for purposes of calculating the advisory fee. Fees are generally not negotiable; however, we
provide services at a reduced rate or free of charge for some employees, family members, and
friends.
Financial Planning Services
Enspire customarily provides financial planning services at no additional charge to the client as
part of our overall investment management services. When a client’s managed portfolio does not
meet Enspire’s $1,000,000 account size minimum, we charge a negotiable fixed fee ranging from
$2,500 to $7,000 for a financial plan, the total of which is dependent upon the level and scope of
these services.
Billing Method
Investment Management Services
Enspire’s advisory fees are payable quarterly in arrears at the beginning of each calendar quarter.
We charge one fourth of the annual fee rate each quarter based on the market value of the client’s
portfolio as of the last business day of each calendar quarter. The formula used for the
calculation is as follows: (Annual Rate) x (Total Assets Under Management at Quarter-End) / 4.
We adjust clients’ fees on a pro-rata basis for withdrawals removed from and additions made to
their accounts during the billing quarter.
For new client accounts, the first payment is a pro-rata calculation that takes into consideration
the initial value of the portfolio and remaining days in the quarter once the account is funded.
The formula used to calculate the initial advisory fee would be as follows: (Full Quarterly
Calculation) x (Days Remaining in Quarter) / (Total Number of Days in Quarter). For advisory
fee calculation purposes, a calendar quarter is a period beginning on January 1, April 1, July 1, or
October 1 and ending on the day before the next quarter. A day is any calendar day including
weekends and holidays.
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With client authorization, Enspire will automatically withdraw Enspire’s advisory fee from the
client’s account held by an independent custodian. Typically, the custodian withdraws advisory
fees from the client’s account during the first month of each quarter based on Enspire’s
instruction. All clients will receive brokerage statements from the custodian no less frequently
than quarterly. The custodian statement will show the deduction of the advisory fee for those
clients who authorize the advisory fees to be withdrawn directly from their custodian account.
For clients that do not elect to have Enspire’s fee automatically withdrawn from their custodian
account, we will provide an invoice that includes the fee calculation and amount due, which is
payable upon receipt.
Enspire will send a statement to each client. The statement will show the amount of the fee, the
value of the client’s assets upon which we based the fee, and the specific manner in which we
calculated the fee. It is the client’s responsibility to verify the accuracy of the fee calculation.
The custodian will not determine whether the fee is properly calculated.
Financial Planning Services
One-half of the total Financial Planning Services fee is due and payable at the time the client
executes the agreement. The remainder of the fee is due upon presentation of a plan to the client.
Other Fees and Expenses
Enspire’s fees do not include custodian fees. Clients pay all brokerage commissions, stock
transfer fees, margin charges, foreign exchange, and settlement fees, and/or other charges
incurred in connection with transactions in accounts, from the assets in the account. These
charges are in addition to the fees client pays to Enspire. See Item 12 - Brokerage Practices
below for more information on the factors that Enspire considers in selecting or recommending
broker-dealers for client transactions and determining the reasonableness of their compensation
(e.g., commissions).
In addition, any fund shares held in a client’s account are subject to fund-related expenses and, if
applicable, 12b-1 fees and/or early redemption fees on mutual funds. Each fund’s prospectus
fully describes the fees and expenses. All fees paid to Enspire for investment advisory services
are separate and distinct from the fees and expenses charged by funds. Funds pay advisory fees
to their managers, which are indirectly charged to all holders of the fund shares.
Termination
Investment Management Services
Either party may terminate the agreement upon written notice to the other party. For fees billed
in arrears, the client will receive an invoice showing the advisory fees due for services rendered
and not yet paid and any earned unpaid advisory fees will be due and payable.
Financial Planning Services
In the event that either the client or Enspire wishes to terminate a financial planning agreement
before completion of the plan or rendering of services, either party may terminate the agreement
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at any time by providing written notice to the other party. The client may terminate the
agreement at any time by writing Enspire at our office. Upon notice of termination, Enspire will
provide the client with an invoice for services provided through the date of termination. If the
client paid fees in advance that were more than the amount due for services, Enspire will refund
any unearned fees.
Other Compensation
Enspire does not accept compensation for the sale of securities or other investment products,
including asset-based sales charges or service fees from the sale of mutual funds. Financial
Planning Services clients have the option to purchase investment products that Enspire
recommends through any broker or agent they desire.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Enspire does not charge performance-based fees or other fees based on a share of capital gains or
capital appreciation of the assets of a client.
ITEM 7 - TYPES OF CLIENTS
Enspire offers discretionary investment advisory and financial planning services to individuals,
high net worth individuals, trusts and estates, small businesses, and some pension and profit
sharing plans. In addition, we offer non-discretionary advisory services to participant-directed
retirement plans.
Account Requirements
Generally, Enspire requires clients to maintain a minimum account size of $1,000,000.
Withdrawal of significant funds may result in a request for additional fund deposits to continue
with management of accounts. At our discretion, we may combine extended family accounts to
meet the account size minimum or reduce or waive the account minimum requirements.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
Methods of Analysis and Investment Strategies
General Investment Strategies
Enspire’s general investment strategy is to seek real capital growth proportionate with the level
of risk the client is willing to take. Enspire selects categories of investments based on the clients’
attitudes about risk and their need for capital appreciation or income. Different instruments
involve different levels of exposure to risk. Within each investment category, Enspire seeks to
select individual securities with characteristics that are most consistent with the client’s
objectives. We deal with any client restrictions on an account-by-account basis.
It is the objective of Enspire to have an Investment Policy Statement for each client. The
Investment Policy Statement is a document that outlines the policies and procedures that Enspire
will follow on behalf of the client. We individualize each client’s Investment Policy Statement to
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address topics that typically include target asset allocation, triggers for implementation of re-
balancing procedures, investment goals, time horizon, and risk tolerance. In addition, the
Investment Policy Statement may address tax considerations, frequency/type of monitoring and
reporting, criteria for investment selection, overall investment strategy, and any special
considerations and/or restrictions the client chooses to place on the management of the account.
Where appropriate, we discuss such items in detail below. By its nature, investing is long-term
oriented. However, we do not ignore short-term influences that might impact a client's financial
situation.
We select investments for not only long-term growth and/or income potential but also which are
readily convertible to cash should unforeseen circumstances warrant. After these first two needs
appear satisfied, we place emphasis for the client's remaining funds on long-term investments
without regard to liquidity. Tax reduction strategies may also play an important role in our
recommendations.
Each portfolio maintains a target asset allocation. Generally, Enspire reviews each portfolio
every quarter to evaluate the extent to which the actual allocation matches the target allocation.
Where we consider the variance to be excessive, Enspire takes appropriate actions (buys and
sells) in order to bring the actual allocation within acceptable range of the target allocation. We
refer to this process as "rebalancing." Since we believe that all investments are subject to cycles,
this process of rebalancing offers a systematic process to help us sell when investment categories
have been in favor and to buy when they have been out of favor.
After defining client needs, Enspire develops and implements plans for the client’s account.
Then, we monitor the results and make adjustments as needed. As the initial assumptions change,
the plans themselves may need to be adapted. Continuous portfolio management is important in
an effort to keep the client's portfolio consistent with the client's objectives.
Methods of Analysis for Selecting Securities
Enspire primarily uses fundamental analysis in the selection of mutual funds.
Fundamental Analysis
Fundamental analysis in the selection of mutual funds may include the analysis of fund
managers, annual reports, and any competitive advantages. Additionally, in analyzing and
selecting mutual funds, we use public and private research sources, fund reporting, and fund
conference calls. We review key characteristics including historical performance, consistency of
returns, risk level, and size of fund. Expense ratio and other costs are also significant factors in
fund selection. Enspire may also consider cyclical conditions, which is an analysis of business
cycles to find favorable conditions for buying and/or selling a security.
Investment Strategies for Managing Portfolios
Enspire may utilize passive or active fund managers and generally applies long-term holding
strategies in the construction and management of client portfolios. In addition, we may
recommend funds with flexible mandates to our clients. These fund managers may provide
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defensive, hedging, leveraging, margin, and/or concentrated portfolio strategies within the funds
they manage.
Active Management
Actively managed funds seek to outperform the market, or more specifically a pre-determined
benchmark. Managers are chosen that select underlying fund investments based on what they
perceive to be discounts to each security’s intrinsic value.
Passive Management
Passive funds generally track a prescribed index or benchmark and keep a flexible trading
approach in order to maintain the characteristics of that index or benchmark.
Specific Investment Strategies for Managing Portfolios
Enspire generally applies a long-term holding strategy in the construction and management of
client portfolios. There is no guarantee that the strategies we utilize will be successful, and we
make no promises or warranties as to the accuracy of our market analysis.
Long-term Holding
Enspire’s strategy consists of purchasing, holding, and rebalancing a diversified portfolio of
securities. Enspire typically intends to hold these investments for the long term except when
sales are necessary to rebalance the portfolio or to fund replacement acquisitions. When selecting
equity securities, Enspire may focus on the potential for income and/or growth, depending on the
client’s investment objectives. Enspire does not attempt to time short-term market swings. Short
term buying and selling of securities is typically limited to those cases where a purchase has
resulted in an unanticipated gain or loss in which we believe that a subsequent sale is in the best
interest of the client.
Defensive Strategies
Enspire may invest at the exercise of our discretion. Enspire has full discretion in how we
allocate client accounts among security types. Actual allocation will vary over time in accounts.
At any time, client accounts may hold significant levels of cash and/or cash equivalents. Account
allocations are likely to vary significantly compared to the overall equity markets as well as
compared to any particular benchmark.
Additional Strategies
Enspire may also recommend funds that use additional strategies in their management of the
funds. Clients interested in learning more about any strategy should contact us for more
information and/or refer to the prospectus of any fund. We may also consider additional
strategies by specific client request.
Investing Involves Risk
Investing in securities always involves the risk that you will lose money. Before investing in the
securities markets, clients should be prepared to bear that risk. Over time, a client’s account
value will fluctuate. At any time, your assets may be worth more or less than the amount you
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invested. As with any investment strategy, there is no guarantee that our strategies will be
successful. Enspire makes no guarantees or promises that our market analysis will be accurate or
the investment strategies we use will be successful.
When Enspire exercises our discretionary authority to invest in securities, we do so in positions
that we believe are appropriate for the client, based on our understanding of the client’s risk
tolerance and investment objectives. We have generally summarized below what we feel are
relevant risks broadly relating to the types of securities we primarily invest in for client accounts;
however, securities may be subject to additional risks that are specific to that security or issuer,
and we cannot and do not attempt to cover all risks that clients may be exposed to within their
portfolios. Clients are strongly encouraged to review the prospectus disclosures and offering
documents relating to the securities held in their portfolios if they have any questions, as these
documents discuss in more detail the risks relating to the particular product. These documents
are provided to the client by the client’s custodian/broker. Clients with questions regarding a
particular security should contact Enspire or the custodian/broker.
Specific Security Risks
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in
response to certain events taking place around the world. These include events directly involving
the issuers of securities held as underlying assets of funds in a client’s account, conditions
affecting the general economy, and overall market changes. Other contributing factors include
local, regional, or global political, social, or economic instability and governmental or
governmental agency responses to economic conditions. Finally, currency, interest rate, and
commodity price fluctuations may also affect security prices and income.
Mutual Funds (Open-end Investment Company)
A mutual fund is a company that pools money from many investors and invests the money in
stocks, bonds, short-term money-market instruments, other securities or assets, or some
combination of these investments. The portfolio of the fund consists of the combined holdings it
owns. Each share represents an investor’s proportionate ownership of the fund’s holdings and the
income those holdings generate. The price that investors pay for mutual fund shares is the fund’s
per share net asset value (NAV) plus any shareholder fees that the fund imposes at the time of
purchase.
The benefits of investing through mutual funds include:
Professionally Managed
Mutual funds are professionally managed by investment advisers who research, select, and
monitor the performance of the securities the fund purchases.
Diversification
Mutual funds typically have the benefit of diversification, which is an investing strategy that
generally sums up as “Don’t put all your eggs in one basket.” Spreading investments across a
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wide range of companies and industry sectors can help lower the risk if a company or sector
fails. Some investors find it easier to achieve diversification through ownership of mutual funds
rather than through ownership of individual stocks or bonds.
Affordability
Some mutual funds accommodate investors who do not have a lot of money to invest by setting
relatively low dollar amounts for initial purchases, subsequent monthly purchases, or both.
Liquidity
Generally, mutual fund investors can readily redeem their shares at the current NAV, less any
fees and charges assessed on redemption. Less frequently, some mutual funds have the option to
redeem shares using the underlying stocks in the fund’s portfolio or may delay redemption for a
defined period.
Mutual funds also have features that some investors might view as disadvantages:
Costs Despite Negative Returns
Mutual funds pay operating and other expenses from fund assets regardless of how the fund
performs, which are indirectly charged to all holders of the mutual fund shares. Depending on
the timing of their investment, investors may also have to pay taxes on any capital gains
distribution they receive. This includes instances where the fund went on to perform poorly after
purchasing shares.
Lack of Control
Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time,
nor can they directly influence which securities the fund manager buys and sells or the timing of
those trades.
Price Uncertainty
With an individual stock, investors can obtain real-time (or close to real-time) pricing
information with relative ease by checking financial websites or by calling a broker or
investment adviser. Investors can also monitor how a stock’s price changes from hour to hour, or
even second to second. By contrast, with a mutual fund, the price at which an investor purchases
or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate
until many hours after the investor placed the order. In general, mutual funds must calculate their
NAV at least once every business day, typically after the major U.S. exchanges close.
Different Types of Funds
When it comes to investing in mutual funds, investors have literally thousands of choices. Most
mutual funds fall into one of three main categories; money market funds, bond funds (also called
“fixed income” funds), and stock funds (also called “equity” funds). Each type has different
features and different risks and rewards. Generally, the higher the potential return, the higher the
risk of loss.
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Money Market Funds
Money market funds have relatively low risks, compared to other mutual funds (and most other
investments). By law, they can invest in only certain high quality, short-term investments issued
by the U.S. Government, U.S. and foreign corporations, state and local governments, and bank
issued certificates of deposit. Money market funds try to keep their net asset value (NAV), which
represents the value of one share in a fund, at a stable $1.00 per share. However, the NAV may
fall below $1.00 if the fund’s investments perform poorly. Investor losses have been rare, but
they are possible. Money market funds pay dividends that generally reflect short-term interest
rates, and historically the returns for money market funds have been lower than for either bond
or stock funds.
Bond Funds
Bond funds generally have higher risks than money market funds, largely because they typically
pursue strategies aimed at producing higher yields. Unlike money market funds, the SEC’s rules
do not restrict bond funds to high quality or short-term investments. Because there are many
different types of bonds, bond funds can vary dramatically in their risks and rewards.
Some of the risks associated with bond funds include:
Credit Risk
There is a possibility that companies or other issuers may fail to pay their debts (including the
debt owed to holders of their bonds). Consequently, this affects mutual funds that hold these
bonds. Credit risk is less of a factor for bond funds that invest in insured bonds or U.S. Treasury
Bonds. By contrast, those that invest in the bonds of companies with poor credit ratings generally
will be subject to higher risk.
Interest Rate Risk
There is a risk that the market value of the bonds will go down when interest rates go up.
Because of this, investors can lose money in any bond fund, including those that invest only in
insured bonds or U.S. Treasury Bonds. Funds that invest in longer-term bonds tend to have
higher interest rate risk.
Prepayment Risk
Issuers may choose to pay off debt earlier than the stated maturity date on a bond. For example,
if interest rates fall, a bond issuer may decide to “retire” its debt and issue new bonds that pay a
lower rate. When this happens, the fund may not be able to reinvest the proceeds in an
investment with as high a return or yield.
Stock Funds
A stock fund’s value can rise and fall quickly (and dramatically) over the short term but may
demonstrate more stability over the long-term. Overall “market risk” poses the greatest potential
danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons, such
as the overall strength of the economy or demand for particular products or services. Not all
stock funds are the same.
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Tax Consequences of Mutual Funds
When investors buy and hold an individual stock or bond, the investor must pay income tax each
year on the dividends or interest the investor receives. However, the investor will not have to pay
any capital gains tax until the investor actually sells and makes a profit. Mutual funds are
different. When an investor buys and holds mutual fund shares, the investor will owe income tax
on any ordinary dividends in the year the investor receives or reinvests them. Moreover, in
addition to owing taxes on any personal capital gains when the investor sells shares, the investor
may have to pay taxes each year on the fund’s capital gains. That is because the law requires
mutual funds to distribute capital gains to shareholders if they sell securities for a profit that
cannot be offset by a loss.
Exchange-Traded Funds (ETFs)
An exchange-traded fund (“ETF”) is a type of Investment Company (usually, an open-end fund
or unit investment trust) containing a basket of equities, fixed income instruments, and/or
commodities. ETFs may be structured to track the performance of a particular market index,
including broad-based or sector-specific indexes. These “passive” ETFs seek to achieve
investment results that correspond, before fees and expenses, to the performance of the
underlying index by generally holding the same securities, or a representative sample of the
securities, included in the index. However, such ETFs may not perfectly track their target index
due to fees, expenses, tracking error, market conditions, or portfolio rebalancing. Other ETFs do
not seek to replicate the performance of a specific index and instead rely on active portfolio
management. Actively managed ETFs may invest in a more limited number of securities, may
deviate significantly from market indexes, and may underperform or outperform the broader
market depending on market conditions and the effectiveness of the investment manager’s
strategies.
Unlike traditional mutual funds, which can only be redeemed at the end of a trading day, ETFs
trade throughout the day on an exchange. Like mutual funds, the prices of the underlying
securities and the overall market affect ETF prices. Similarly, factors affecting a particular
industry segment typically affect ETF prices that track that particular sector.
Cash and Cash Equivalents
The account may hold cash or invest in cash equivalents. Cash equivalents include:
1. Money market funds and cash sweeps.
2. Commercial paper (for example, short-term notes with maturities typically up to 12
months in length issued by corporations, governmental bodies or bank/corporation
sponsored conduits (asset-backed commercial paper));
3. Short-term bank obligations (for example, bank notes, certificates of deposit, or bankers'
acceptances (time drafts on a commercial bank where the bank accepts an irrevocable
obligation to pay at maturity));
4. Savings association and savings bank obligations (for example, bank notes and
certificates of deposit issued by savings banks or savings associations);
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5. Securities of the U.S. government, its agencies or instrumentalities that mature, or may be
redeemed, in one year or less; and
6. Corporate bonds and notes that mature or that may be redeemed in one year or less.
Cash and cash equivalents are the most liquid of investments. Cash and cash equivalents are
considered very low-risk investments, meaning there is little risk of losing the principal
investment. Typically, low risk also means low return and the interest an investor can earn on
this type of investment is low relative to other types of investing vehicles.
Financial Planning
The financial planning tools Enspire uses to create financial plans for clients rely on various
assumptions, such as estimates of inflation, risk, economic conditions, and rates of return on
security asset classes. Return assumptions generally reflect asset class returns instead of actual
investment returns, and do not always include fees or expenses that clients would pay if they
invested in some specific products.
Financial planning software is only a tool used to help guide Enspire and the client in developing
an appropriate plan, and we cannot guarantee that clients will achieve the results shown in the
plan. Results will vary based on the information provided by the client regarding the client’s
assets, risk tolerance, and personal information. Changes to the program’s underlying
assumptions or differences in actual personal, economic, or market outcomes generally result in
different results for the client.
Clients should carefully consider the assumptions and limitations of the financial planning
software and should discuss the results of the plan with us before making changes to their
investments or financial plan. If the financial plan includes recommendations for investing in
securities, you should understand that investing in securities involves risk of loss, and you should
be prepared to bear that risk.
ITEM 9 - DISCIPLINARY INFORMATION
Enspire and our personnel seek to maintain the highest level of business professionalism,
integrity, and ethics. Enspire does not have any disciplinary information to disclose.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Unaffiliated Accounting Firm
In his sole and separate capacity, Mark G. Leavitt provides accounting services through his CPA
practice, which is not under the control of Enspire. Mr. Leavitt does not have signatory authority
over Enspire’s clients’ accounts in connection with his CPA-related activities. There are times
when Enspire refers clients in need of accounting, income tax and other business advisory
services to Mark G. Leavitt, CPA. Similarly, Mr. Leavitt offers advisory services through
Enspire to some accounting clients. Enspire does not pay or receive compensation for these
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referrals. Professional services and fees of Mark G. Leavitt’s CPA practice are entirely separate
and distinct from Enspire’s investment advisory services and fees.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
Enspire takes the issue of regulatory compliance seriously and is committed to maintaining
compliance with state and applicable federal securities laws. Additionally, Enspire has a position
of public trust, and it is our goal to maintain that trust and provide excellent service, good
investment performance, and advice that is suitable. Enspire places great value on ethical
conduct. Therefore, the ultimate goal of our internal policies is to challenge our staff to live up
not only to the letter of the law, but also to the ideals set forth by Enspire.
Enspire believes that we owe clients the highest level of trust and fair dealing. As a registered
investment adviser, Enspire is a fiduciary to clients. As a fiduciary, our duties to clients include:
1. Providing advice that is suitable;
2. Providing full disclosure of material facts and potential conflicts of interest (so that
clients have complete and honest disclosure in order to make an informed decision about
our services and investment recommendations);
3. Conducting ourselves with the utmost and exclusive loyalty and good faith;
4. Taking reasonable care to avoid misleading clients; and
5. Acting in the best interests of clients.
It is our policy to protect the interests of each of our clients and to place the clients’ interests first
in every situation. We will abide by fair, equitable, and ethical principles to include, but not
limited to the following:
1. We will only place trades in a client account if the client has given us authority to do so.
2. If a third party instructs us to place trades in a client’s account, we will only take the third
party’s instructions if the client has authorized us in writing to do so.
3. We will only exercise discretionary power (including any power of attorney) to place
trades in the client’s account if we have written discretionary authorization from the
client.
4. We will not trade excessively (in terms of size or frequency of trades) in a client’s
account in view of the financial resources, investment objectives, and character of the
account.
5. We will not borrow money from clients unless the client is a broker-dealer, our affiliate,
or a financial institution engaged in the business of loaning funds or securities.
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6. We will not loan money to clients unless we are a financial institution engaged in the
business of loaning funds, or the client is our affiliate.
7. We always seek to represent the qualifications of Enspire and our personnel, the advisory
services we offer, and the fees we charge, fairly and accurately. We will not mislead or
omit stating a material fact necessary to make the statements we make regarding our
qualifications, services, or fees, in light of the circumstances under which we make them.
8. We will provide full disclosure of any material conflict of interest that could impair our
rendering of unbiased and objective advice, under reasonable expectations.
9. We never guarantee that our advice or recommendations will achieve a specific result
(e.g., a gain or no loss).
10. We protect our clients’ confidential information. We only disclose client information to
third parties if we have client consent or are required or permitted by law to do so.
Enspire’s Privacy Notice, which we give to all customers, describes our policies for
guarding client confidential information. You can receive a copy of our Privacy Notice
by contacting our office at the phone number on the cover page of this brochure.
11. Unless we are solely providing impersonal advisory services, all of our advisory contracts
are in writing. Our agreements with clients disclose the services we are providing, the
term of the contract, and whether the contract grants us discretionary power. Our contract
also describes the advisory fee we charge (or the formula for computing the fee) and the
amount (or the manner of calculation of the amount) of the prepaid fee we will return in
the event of contract termination or nonperformance.
12. When we solicit advisory clients, we will not make any untrue statement of a material
fact or omit a statement of material fact necessary in order to make the statements we
made, in light of the circumstances under which we made them.
13. We will not recommend the purchase of a security without the reasonable belief that the
security is registered, or the security or transaction is exempt from registration, in states
where we provide investment advice and based upon information we receive.
14. Our personnel will report all required personal securities transactions to the Chief
Compliance Officer of Enspire as required by securities regulations.
15. Enspire and its associated persons do not recommend to clients, or buy or sell for client
accounts, securities in which we or any related person has a material financial interest.
Personal Trading Practices
Enspire or our personnel may place trades for our own accounts. The securities we trade in may
be the same securities we recommend to clients, or they may be different securities that we do
not feel are appropriate for clients. A conflict of interest could arise when Enspire or our
personnel trade in the same securities as clients. For example, we could have an incentive to
purchase a security in our own account before recommending the security to a client, hoping that
when the client traded, the price of the security would go up and we would benefit.
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Due to the small size of trades placed for clients compared with the large volume traded in those
securities each day, we do not believe that client trades could realistically move the price of a
security and enable us to benefit from client trades. We place trades for our own accounts
independently of decisions to trade for clients. Because the price of securities fluctuates during
the day (other than mutual funds), we could trade in a security on the same day as a client and
receive a better or worse price than the client does. For mutual funds, if we traded on the same
day as clients, we would receive the same price, since mutual funds do not trade but are issued
and redeemed once daily at the fund’s net asset value (“NAV”). As a fiduciary to our clients, we
always seek to put our clients’ interests first. Any difference in the prices we receive is never the
result of our intentionally trading ahead of clients. Enspire prohibits trading in a manner that
takes personal advantage of our recommendations to clients.
Our personnel will report all required personal securities transactions to Enspire as required by
securities regulations. Enspire maintains required personal securities transaction records.
ITEM 12 - BROKERAGE PRACTICES
The Custodian and Brokers We Use
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-dealer
or bank. We require that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered
broker-dealer, member SIPC, as the qualified custodian. We are independently owned and
operated and unaffiliated with Schwab. Schwab will hold your assets in a brokerage account and
buy and sell securities when we instruct them to.
While we require that you use Schwab as custodian/broker, you will decide whether to do so and
will open your account with Schwab by entering into an account agreement directly with them.
We do not open the account for you, although we may assist you in doing so.
How We Select Brokers/Custodians
We seek to recommend a custodian/broker who will hold your assets and execute transactions on
terms that are, overall, most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others:
1. Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
2. Capability to execute, clear, and settle trades (buy and sell securities for your account)
3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
4. Availability of investment research and tools that assist us in making investment
decisions
5. Quality of services
6. Competitiveness of the price of those services (commission rates and other fees) and
willingness to negotiate the prices
7. Reputation, financial strength, and stability
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8. Prior service to us and our other clients
9. Availability of other products and services that benefit us, as discussed below (see
Products and Services Available to Us From Schwab)
Your Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you
separately for custody services. However, Schwab receives compensation by charging you
commissions or other fees on trades that it executes or that settle into your Schwab account. This
commitment benefits you because the overall commission rates you pay are lower than they
would be otherwise. We have determined that having Schwab execute the trades is consistent
with our duty to seek “best execution” of your trades. Best execution means the most favorable
terms for a transaction based on all relevant factors, including those listed above (see How We
Select Brokers/Custodians).
Products and Services Available to Us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms
like us. They provide Enspire and our clients with access to its institutional brokerage, trading,
custody, reporting, and related services, many of which are not typically available to Schwab
retail customers. Schwab also makes available various support services. Some of those services
help us manage or administer our clients’ accounts; others help us manage and grow our
business. Schwab’s support services generally are available on an unsolicited basis (we generally
do not request them) and they are at no charge to us.
Following is a more detailed description of Schwab’s support services:
Services That Benefit You
Schwab’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise have access
or that would require a significantly higher minimum initial investment by our clients. Schwab’s
services described in this paragraph generally benefit you and your account.
Services That May Not Directly Benefit You
Schwab also makes available to us other products and services that benefit us but may not
directly benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts. They include investment research, both Schwab’s own and
that of third parties. We may use this research to service all or a substantial number of our
clients’ accounts, including accounts not maintained at Schwab. In addition to investment
research, Schwab also makes available software and other technology that:
1. Provide access to client account data (such as duplicate trade confirmations and account
statements)
2. Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
3. Provide pricing and other market data
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4. Facilitate payment of our fees from our clients’ accounts
5. Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
1. Educational conferences and events (which may include Schwab paying for related travel
expenses, entertainment and meals associated with attending)
2. Consulting on technology, compliance, legal, and business needs
3. Publications and conferences on practice management and business succession
4. Access to employee benefits providers, human capital consultants, and insurance
providers
Schwab may provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab may also discount or waive its fees for some of
these services or pay all or a part of a third party’s fees. Schwab may also provide us with other
benefits, such as occasional business entertainment for our personnel.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We do not have to pay for Schwab’s services so long as our clients collectively
keep a total of at least $10 million of their assets in accounts at Schwab. Beyond that, these
services are not contingent upon us committing any specific amount of business to Schwab in
trading commissions. The $10 million minimum may give us an incentive to recommend that
you maintain your account with Schwab, based on our interest in receiving Schwab’s services
that benefit our business rather than based on your interest in receiving the best value in custody
services and the most favorable execution of your transactions. This is a potential conflict of
interest. We believe, however, that our selection of Schwab is primarily supported by the scope,
quality, and price of Schwab’s services (see How We Select Brokers/Custodians, above) and not
Schwab’s services that benefit only us.
Directed Brokerage Transactions
Enspire will not allow clients to direct us to use a specific broker-dealer to execute transactions.
Clients must use the broker-dealer that Enspire recommends. Not all investment advisers require
their clients to trade through specific brokerage firms.
Since we require most of our clients to maintain their accounts with Schwab, it is also important
for clients to consider and compare the significant differences between having assets custodied at
another broker-dealer, bank, or other custodian prior to opening an account with us. Some of
these differences include but are not limited to; total account costs, trading freedom, transaction
fees/commission rates, and security and technology services. By requiring clients to use Schwab,
Enspire believes we may be able to more effectively manage the client’s portfolio, achieve
favorable execution of client transactions, and overall lower the costs to the portfolio.
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Clients with 401(k) or 529 Plan accounts that we agree to manage are not required to use Schwab
and may appoint a custodian of their choosing.
Aggregation and Allocation of Transactions
Mutual Funds
Enspire primarily uses mutual funds to manage client accounts. Mutual funds are priced once
daily. As the daily price is the same for each investor, we have no opportunity to obtain better
pricing through aggregating. Additionally, the broker-dealer/custodians charge each account an
individual transaction fee regardless of whether we aggregate or not, so we are unable to lower
trading costs through aggregation.
Exchange-Traded Funds (ETFs)
Enspire generally aggregates transactions in ETFs if we believe that aggregation is consistent
with the duty to seek best execution for our clients and is consistent with the disclosures made to
clients and terms defined in the client investment advisory agreement. No advisory client will be
favored over any other client, and each account that participates in an aggregated order will
participate at the average share price (per custodian) for all transactions in that security on a
given business day. Aggregating trades in like securities among client accounts as well as with
accounts of Enspire and our personnel presents a potential conflict of interest as it could create
an incentive to allocate more favorable executions to our own accounts or the accounts of our
personnel.
Our policies to address this conflict are as follows:
1. We disclose our aggregation policies in this brochure;
2. We will not aggregate transactions unless we believe that aggregation is consistent with
our duty to seek best execution (which includes the duty to seek best price) for our
clients. The trade also needs to be consistent with the terms of our investment advisory
agreement with each client that has an account included in the aggregation;
3. We will not favor any account over any other account. This includes accounts of Enspire
and our personnel. Each account in the aggregated order will participate at the average
share price for all of our transactions in a given security on a given business day (per
custodian). All accounts will pay their individual transaction costs;
4. Before entering an aggregated order, we will prepare a written statement (the “Allocation
Statement”) specifying the participating accounts and how we intend to allocate the order
among those accounts;
5. If the aggregated order is filled entirely, we will allocate shares among clients according
to the Allocation Statement; if the order is partially filled, we will allocate it pro-rata
according to the Allocation Statement.
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6. Notwithstanding the foregoing, the order may be allocated on a basis different from that
specified in the Allocation Statement if all client accounts receive fair and equitable
treatment and the reasons for different allocation is explained in writing and is approved
by the CCO;
7. If an aggregated order is partially filled and we allocate it differently than the Allocation
Statement specifies, no participating account may purchase or sell the security for a
reasonable period following the execution of the block trade. This only applies when the
participating account sells or receives more shares than it would have if the aggregated
order had been completely filled;
8. Our books and records will separately reflect each aggregated order and the securities
held by, bought, and sold for each client account;
9. Funds and securities of clients participating in an aggregated order will be deposited with
one or more qualified custodians. Clients’ cash and securities will not be held collectively
any longer than is necessary to settle the trade on a delivery versus payment basis.
Following settlement, cash or securities held collectively for clients will be delivered out
to the qualified custodian as soon as practical;
10. We do not receive additional compensation or remuneration of any kind as a result of
aggregating orders; and
11. We will provide individual investment advice and treatment to each client’s account.
ITEM 13 - REVIEW OF ACCOUNTS
Managed Account Reviews
Enspire seeks to meet client objectives by monitoring clients’ investment portfolios on a regular
basis. Each individual client and Enspire determines the frequency of review, which may be at
any chosen interval. Enspire may request more immediate reviews if we determine that special
circumstances or material factors warrant additional attention. Clients may also request
additional reviews at their discretion. Reviews may also be triggered by political, economic, and
market circumstances and/or a change in the client’s individual circumstances. Mark Leavitt,
Principal, conducts all account reviews.
Account Reporting
Investment Management Services
Each client receives a written statement from the custodian that includes an accounting of all
holdings and transactions in the account for the reporting period. In addition, Enspire provides
written reports detailing performance on a quarterly basis. We may also provide additional
reporting as agreed upon by Enspire and the client on a case-by-case basis.
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Financial Planning Services
Financial planning clients do not receive reports in addition to the initial financial plan.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Schwab Support Products and Services
We receive an economic benefit from Schwab in the form of the support products and services
they make available to us and other independent investment advisors whose clients maintain
their accounts at Schwab. These products and services, how they benefit us, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices). We do not base
particular investment advice, such as buying particular securities for our clients, on the
availability of Schwab’s products and services to us.
Outside Referrals
As described above in Unaffiliated Accounting Firm in Item 10, there are times when Enspire
refers clients in need of accounting, income tax and other business advisory services to Mark G.
Leavitt, CPA. Additionally, Enspire may refer clients to unaffiliated professionals for specific
needs, such as insurance, mortgage brokerage, real estate sales, estate planning, legal, and/or
tax/accounting. In turn, these professionals may refer clients to Enspire for investment
management/financial planning needs. Enspire will not refer clients to financial planners and
other investment advisers unless they are licensed, registered, or exempt from registration as an
investment adviser. We do not have any arrangements with individuals or companies that we
refer clients to, and we do not receive any compensation for these referrals. However, it could be
concluded that Enspire is receiving an indirect economic benefit from this practice, as the
relationships are mutually beneficial. For example, there could be an incentive for us to
recommend services of firms who refer clients to Enspire.
Enspire only refers clients to professionals we believe are competent and qualified in their field,
but it is ultimately the client’s responsibility to evaluate the provider, and it is solely the client’s
decision whether to engage a recommended firm. Clients are under no obligation to purchase any
products or services through these professionals, and Enspire has no control over the services
provided by another firm. Clients who choose to engage these professionals will sign a separate
agreement with the other firm. Fees charged by the other firm are separate from and in addition
to fees charged by Enspire.
If the client desires, Enspire will work with these professionals or the client’s other advisors
(such as an accountant or attorney) to help ensure that the provider understands the client’s
financial plan/investments and to coordinate services for the client. Enspire does not share
information with an unaffiliated professional unless first authorized by the client.
ITEM 15 - CUSTODY
Enspire has limited custody of some of our clients’ funds or securities when the clients authorize
us to deduct our management fees directly from the client’s account. A qualified custodian
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(generally a broker-dealer, bank, trust company, or other financial institution) holds clients’
funds and securities. Clients will receive statements directly from their qualified custodian at
least quarterly. The statements will reflect the client’s funds and securities held with the qualified
custodian as well as any transactions that occurred in the account, including the deduction of our
fee.
Clients should carefully review the account statements they receive from the qualified custodian.
When clients receive statements from Enspire as well as from the qualified custodian, they
should compare these two reports carefully. Clients with any questions about their statements
should contact us at the address or phone number on the cover of this brochure. Clients who do
not receive a statement from their qualified custodian at least quarterly should also notify us.
Enspire is also deemed to have custody of clients’ funds or securities when clients have standing
authorizations with their custodian to move money from a client’s account to a third-party
(“SLOA”) and under that SLOA authorize us to designate the amount or timing of transfers with
the custodian. The SEC has set forth a set of standards intended to protect client assets in such
situations, which we follow.
ITEM 16 - INVESTMENT DISCRETION
Discretionary Management
Enspire generally has full discretion to decide the specific security to trade, the quantity, and the
timing of transactions for client accounts. Enspire will not contact clients before placing trades in
their account, but clients will receive confirmations directly from the custodian/broker for any
trades placed unless they have chosen to disable trade alerts in their account. Clients grant us
discretionary authority in the contracts they sign with us. Clients also give us trading authority
over their accounts when they sign the custodian paperwork.
However, certain client-imposed conditions may limit our discretionary authority, such as where
the client prohibits transactions in specific security types. See also Tailored Services and Client
Imposed Restrictions under Item 4, above.
Non-Discretionary Management
For non-discretionary investment advisory services provided to participant-directed retirement
plans, Enspire assists the retirement plan client in making decisions about the selection,
retention, removal, and addition of plan investment options to be made available under the plan.
The retirement plan client retains and exercises final decision-making authority and
responsibility for the implementation (or rejection) of Enspire’s recommendations and advice,
and the plan client and/or individual plan participant makes the ultimate decision regarding the
purchase or sale of investments.
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ITEM 17 - VOTING CLIENT SECURITIES
Proxy Voting
Enspire does not accept or have the authority to vote client securities. However, clients may call
us if they have questions about a particular solicitation. Enspire will not be deemed to have
proxy voting authority solely as a result of providing advice or information about a particular
proxy vote to a client. Clients will receive their proxies or other solicitations directly from their
custodian or a transfer agent.
ERISA
For accounts subject to ERISA, an authorized plan fiduciary other than Enspire will retain proxy
voting authority. Our investment advisory agreement and/or the plan’s written documents will
evidence and outline this authority.
Mutual Funds
The investment adviser that manages the assets of a registered investment company (i.e., mutual
fund) generally votes proxies issued on securities held by the mutual fund.
Class Actions
Enspire does not instruct or give advice to clients on whether or not to participate as a member of
class action lawsuits and will not automatically file claims on the client’s behalf. However, if a
client notifies us that they wish to participate in a class action, we will provide the client with
any transaction information pertaining to the client’s account needed for the client to file a proof
of claim in a class action.
ITEM 18 - FINANCIAL INFORMATION
Registered investment advisers are required in this item to provide clients with certain financial
information or disclosures about the firm’s financial condition. Enspire does not require the
prepayment of more than $1,200 in fees per client six months or more in advance, does not have
or foresee any financial condition that is reasonably likely to impair our ability to meet
contractual commitments to clients, and has not been the subject of a bankruptcy proceeding.
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Part 2A Brochure
Form ADV, Part 2B Brochure Supplement
ITEM 1 - COVER PAGE
Mark G. Leavitt
Kaden Wootton, CFP®
Enspire Wealth Management, LLC
90 South E Street
Suite 300
Santa Rosa, CA 95404
Tel: (707) 525-1099
www.enspirewealth.com
September 29, 2026
This brochure supplement provides information about Mark G. Leavitt and Kaden Wootton
that supplements the Enspire Wealth Management, LLC brochure. You should have already
received a copy of that brochure. Please contact Mark Leavitt at mark@enspirewealth.com
or (707) 525-1099 if you did not receive our brochure or if you have any questions about the
contents of this supplement. Additional information about the above named individuals is
available on the SEC’s website at www.adviserinfo.sec.gov.
Mark G. Leavitt, CPA
Year of birth: 1968
Item 2 - Educational Background and Business Experience
Educational Background
• BS in Business Administration; San Jose State University, 1992
• Certified Public Accountant, State of California Department of Consumer Affairs State
Board of Accountancy, 1997
Business Experience
• Enspire Wealth Management, LLC, Principal/Managing Member, 03/2023 to present
• Mark G. Leavitt, CPA, Certified Public Accountant, 08/2001 to present
• Meritas Wealth Management, LLC, Principal/Sr. Financial Planner, 11/2018 to 09/2023
• Leavitt Wealth Management LLC, Managing Member/Chief Compliance Officer,
01/2009 to 02/2019
Certifications: CPA
Certified Public Accountant (CPA) - CPAs are licensed and regulated by their state boards of
accountancy. While state laws and regulations vary, the education, experience and testing
requirements for licensure as a CPA generally include minimum college education (typically 150
credit hours with at least a baccalaureate degree and a concentration in accounting), minimum
experience levels (most states require at least one year of experience providing services that
involve the use of accounting, attest, compilation, management advisory, financial advisory, tax
or consulting skills, all of which must be achieved under the supervision of or verification by a
CPA), and successful passage of the Uniform CPA Examination.
In order to maintain a CPA license, states generally require the completion of 40 hours of
continuing professional education (CPE) each year (or 80 hours over a two year period or 120
hours over a three year period). Additionally, all American Institute of Certified Public
Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct
which requires that they act with integrity, objectivity, due care, competence, fully disclose any
conflicts of interest (and obtain client consent if a conflict exists), maintain client confidentiality,
disclose to the client any commission or referral fees, and serve the public interest when
providing financial services. The vast majority of state boards of accountancy have adopted the
AICPA's Code of Professional Conduct within their state accountancy laws or have created their
own.
Enspire Wealth Management is not an accounting firm, does not hold itself out as an accounting
firm, and is not a licensee of the California Board of Accountancy.
Item 3 - Disciplinary Information
Mark G. Leavitt has no disciplinary history to disclose.
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Item 4 - Other Business Activities
In addition to providing investment advice through Enspire, Mark G. Leavitt provides CPA-
related services through Mark G. Leavitt, CPA. Mr. Leavitt currently spends less than 5% of his
time on CPA-related activities.
Item 5 - Additional Compensation
Mark Leavitt’s primary compensation comes from his regular salary and ownership of Enspire.
Item 6 - Supervision
Mark Leavitt, Principal, is responsible for supervising all employees. He can be reached by
calling (707) 525-1099.
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Kaden Wootton, CFP®
Year of birth: 1996
Item 2 - Educational Background and Business Experience
Educational Background
• BS in Personal Financial Planning; Texas Tech University, 2019
• Attended Northumbria University, 2017-2018
• CFP® Certification, 2022
Business Experience
• Enspire Wealth Management, LLC, Financial Planner, 07/2023 to present
• Meritas Wealth Management, LLC, Financial Planner, 07/2020 to 09/2023
• Fidelity Investments, Fund Account Analyst, 02/2020 to 06/2020
• Student through 12/2019
Professional Designations
Kaden Wooton holds the following professional designation:
• CERTIFIED FINANCIAL PLANNER™
CERTIFIED FINANCIAL PLANNER™ professional
I am certified for financial planning services in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED
FINANCIAL PLANNER™ professional or a CFP® professional, and I may use these and CFP
Board’s other certification marks (the “CFP Board Certification Marks”). The CFP® certification
is voluntary. No federal or state law or regulation requires financial planners to hold the CFP®
certification. You may find more information about the CFP® certification at www.CFP.net.
CFP® professionals have met CFP Board’s high standards for education, examination,
experience, and ethics. To become a CFP® professional, an individual must fulfill the following
requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university
and complete CFP Board-approved coursework at a college or university through a CFP
Board Registered Program. The coursework covers the financial planning subject areas
CFP Board has determined are necessary for the competent and professional delivery of
financial planning services, as well as a comprehensive financial plan development
capstone course. A candidate may satisfy some of the coursework requirement through
other qualifying credentials. CFP Board implemented the bachelor’s degree or higher
requirement in 2007 and the financial planning development capstone course requirement
in March 2012. Therefore, a CFP® professional who first became certified before those
dates may not have earned a bachelor’s or higher degree or completed a financial
planning development capstone course.
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination is designed to assess an individual’s ability to integrate and apply a broad
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base of financial planning knowledge in the context of real-life financial planning
situations.
• Experience – Complete 6,000 hours of professional experience related to the personal
financial planning process, or 4,000 hours of apprenticeship experience that meets
additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former
CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code
of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical
and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board
Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore,
act in the best interests of the client, at all times when providing financial advice and
financial planning. CFP Board may sanction a CFP® professional who does not abide by
this commitment, but CFP Board does not guarantee a CFP® professional's services. A
client who seeks a similar commitment should obtain a written engagement that includes
a fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and
keep up with developments in financial planning. Two of the hours must address the
Code and Standards.
Item 3 - Disciplinary Information
Kaden Wooton has no disciplinary history to disclose.
Item 4 - Other Business Activities
Kaden Wooton's only business is providing planning and investment advice through Enspire.
Item 5 - Additional Compensation
Kaden Wooton's only compensation comes from his regular salary at Enspire.
Item 6 - Supervision
Mark Leavitt, Principal, is responsible for supervising all employees. He can be reached by
calling (707) 525-1099.
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Part 2B Supplements
Privacy Policy
September 2026
FACTS
WHAT DOES ENSPIRE WEALTH MANAGEMENT, LLC (“ENSPIRE”) DO
WITH YOUR PERSONAL INFORMATION?
Why?
Financial companies choose how they share your personal information.
Federal law gives consumers the right to limit some but not all sharing.
Federal law also requires us to tell you how we collect, share, and protect
your personal information. Please read this notice carefully to understand
what we do.
What?
The types of personal information we collect and share depend on the
product or service you have with us. This information can include:
Social Security number and income
•
• account balances and transaction history
• assets and risk tolerance
When you are no longer our customer, we continue to share your
information as described in this notice.
How?
All financial companies need to share customers’ personal information to
run their everyday business. In the section below, we list the reasons
financial companies can share their customers’ personal information; the
reasons Enspire chooses to share; and whether you can limit this sharing.
Reasons we can share your personal
information
Does Enspire
share?
Can you limit
this sharing?
YES
NO
For our everyday business purposes -
as permitted by law
NO
We Don’t Share
For our marketing purposes - to offer our products and
services to you
For joint marketing with other financial companies
NO
We Don’t Share
NO
We Don’t Share
For our affiliates’ everyday business purposes -
information about your transactions and experiences
NO
We Don’t Share
For our affiliates’ everyday business purposes -
information about your creditworthiness
For affiliates to market to you
NO
We Don’t Share
For nonaffiliates to market to you
NO
We Don’t Share
Questions? Call (707) 525-1099 or go to www.enspirewealth.com
Page 2
WHO WE ARE
Who is providing this notice?
Enspire Wealth Management, LLC (“Enspire”)
WHAT WE DO
How does Enspire protect my
personal information?
To protect your personal information from unauthorized
access and use, we use security measures that comply with
federal law. These measures include computer safeguards
and secured files and buildings.
We collect your personal information, for example, when you
How does Enspire collect my
personal information?
seek advice about your investments
tell us about your investment or retirement portfolio
tell us about your investment or retirement earnings
•
• enter into an investment advisory contract
•
•
• give us your contact information
We also collect your personal information from other
companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only:
•
sharing for affiliates’ everyday business purposes -
information about your creditworthiness
sharing for nonaffiliates to market to you
• affiliates from using your information to market to you
•
State laws and individual companies may give you additional
rights to limit sharing.
DEFINITIONS
Affiliates
Companies related by common ownership or control. They
can be financial and nonfinancial companies.
• Enspire has no affiliates.
Nonaffiliates
Companies not related by common ownership or control.
They can be financial and non-financial companies.
• Enspire does not share with nonaffiliates so they can
market to you.
Joint Marketing
A formal agreement between nonaffiliated financial
companies that together market financial products or
services to you.
• Enspire doesn’t jointly market.