Overview
Assets Under Management: $470 million
Headquarters: DALLAS, TX
High-Net-Worth Clients: 163
Average Client Assets: $3 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Fee Structure
Primary Fee Schedule (PART 2A BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $75,000 | 1.50% |
| $10 million | $150,000 | 1.50% |
| $50 million | $750,000 | 1.50% |
| $100 million | $1,500,000 | 1.50% |
Clients
Number of High-Net-Worth Clients: 163
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 86.25
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 786
Discretionary Accounts: 786
Regulatory Filings
CRD Number: 322294
Last Filing Date: 2024-05-13 00:00:00
Website: https://eqwealthadv.com
Form ADV Documents
Primary Brochure: PART 2A BROCHURE (2025-03-26)
View Document Text
ITEM 1 – COVER PAGE
EQ WEALTH ADVISORS, LLC
10000 NORTH CENTRAL EXPRESS WAY, SUITE 1350
DALLAS, TEXAS 75231
PHONE: 214-389-6750
WEBSITE: WWW.EQWEALTHADV.COM
PART 2A – FIRM BROCHURE
March 15, 2025
This brochure provides information about the qualifications and business practices of EQ Wealth
Advisors, LLC (“EQWA” or “EQ Wealth Advisors”). If you have any questions about the contents of
this brochure, please contact us at 214-389-6750. 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. EQWA is a Registered Investment Adviser. Registration as an Investment
Adviser with the United States Securities and Exchange Commission or any state securities
authority does not imply a certain level of skill or training.
Additional information about EQWA is available on the SEC’s website at www.adviserinfo.sec.gov.
You can search this site by a unique identifying number, known as an IARD number. The IARD
number for EQWA is #322294.
ITEM 2 – MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
This section of the Brochure will address only those “material changes” that have been
incorporated since our last delivery or posting of this document on the SEC’s public disclosure
website (IAPD) www.adviserinfo.sec.gov.
Since our most recent annual amendment update on February 16, 2024, the following material
changes have occurred.
•
Item 7: The firm has removed the required minimum on investable assets.
A free copy of our Brochure may be requested by contacting Patricia Harris, Chief Compliance
Officer of EQWA at 214-389-6750. The Brochure
is also available on our website,
www.eqwealthadv.com.
We encourage you to read this document in its entirety.
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 1
ITEM 3 – TABLE OF CONTENTS
ITEM 1 – COVER PAGE ............................................................................................................................. 0
ITEM 2 – MATERIAL CHANGES ................................................................................................................ 1
ITEM 3 – TABLE OF CONTENTS ................................................................................................................ 2
ITEM 4 – ADVISORY BUSINESS ................................................................................................................ 3
ITEM 5 – FEES AND COMPENSATION ....................................................................................................... 6
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................ 7
ITEM 7 - TYPES OF CLIENTS ..................................................................................................................... 8
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ..................................... 8
ITEM 9 - DISCIPLINARY INFORMATION .................................................................................................. 16
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................. 16
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING .............................................................................................................................................. 17
ITEM 12 - BROKERAGE PRACTICES ......................................................................................................... 18
ITEM 13 - REVIEW OF ACCOUNTS .......................................................................................................... 22
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................. 22
ITEM 15 – CUSTODY .............................................................................................................................. 23
ITEM 16 – INVESTMENT DISCRETION .................................................................................................... 24
ITEM 17 – VOTING CLIENT SECURITIES .................................................................................................. 24
ITEM 18 – FINANCIAL INFORMATION .................................................................................................... 24
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 2
ITEM 4 – ADVISORY BUSINESS
This Disclosure document is being offered to you by EQ Wealth Advisors, LLC (“EQWA”, “EQ
Wealth Advisors”, “EQ Wealth”, or “Firm”) about the investment advisory services we provide. It
discloses information about our services and the way those services are made available to you,
the client.
Our Firm applied for SEC registration in October 2022. Toby S. Harris is the primary Managing
Member of EQ Wealth, and Patricia Harris is the Chief Compliance Officer.
We are committed to helping clients build, manage, and preserve wealth. Our Firm provides
services that help clients to achieve their stated financial goals. We will offer an initial
complimentary meeting at our discretion; however, investment advisory services are initiated
only after you and EQWA execute an Investment Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary and non-discretionary basis.
During personal discussions with clients, we determine the client’s objectives, time horizons, risk
tolerance, and liquidity needs. To develop a complete picture of a client’s investment objectives,
our investment adviser representatives work one-on-one with the advisory client through the
initial and ongoing planning process to create an investment plan that fits the client’s risk
tolerance and investment objectives. Based on this information, we understand the client’s
investment objectives, goals, and the amount of risk the client will tolerate. To further fine-tune
our understanding of a client’s financial needs, our Firm will utilize third-party vendor tools, such
as Black Diamond, FP Alpha, Morningstar, and E-Money, to assist in identifying the client’s cash
flow needs, risk tolerance, and associated objectives.
For discretionary accounts, once we have determined a profile and investment plan with a client,
we will execute the day-to-day transactions without seeking prior client consent but within the
expected investment guidelines.
If a non-discretionary relationship is in place, calls will be placed presenting the recommendation
made, and only upon your authorization will any action be taken on your behalf.
In both discretionary and non-discretionary accounts, we primarily allocate client assets among
cash, individual stocks, bonds, exchange-traded funds (“ETFs”), no-load and load-waived mutual
funds, equities, options, alternative investments, and other public and private securities or
investments in accordance with their stated investment objectives.
Alternative Investments represent asset classes outside the realm of traditional stocks, bonds,
mutual funds, ETFs, and cash equivalents and include, among other things, private equity, venture
capital, and funds of private funds. Where determined suitable for a client, EQWA will utilize or
otherwise recommend alternative investments, which may include but are not limited to, private
funds.
As mentioned above, we trade these portfolios based on the combination of our market views
and client objectives using our investment process. We tailor our advisory services to meet the
needs of our clients and seek to ensure that your portfolio is managed in a manner consistent
with those needs and objectives. Clients have the ability to leave standing instructions with us to
refrain from investing in particular industries or invest in limited amounts of securities.
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 3
Client portfolios are continuously and regularly monitored and, if necessary, rebalanced based
upon the client’s individual needs and objectives. The client must notify us immediately if
circumstances have changed with respect to their goals.
In all cases, clients have a direct and beneficial interest in their securities rather than an undivided
interest in a pool of securities. We have limited authority to direct the Custodian to deduct our
investment advisory fees from your accounts, but only with clients' written authorization.
Where appropriate, we provide advice about any type of legacy position held in client portfolios.
Typically, these are ineligible assets to be custodied at our primary custodian. Clients will engage
us to advise on certain investment products not maintained at their primary custodian, such as
variable life insurance, annuity contracts, and assets held in employer-sponsored retirement plans
and qualified tuition plans (i.e., 529 plans).
You are advised and expected to understand that our past performance does not guarantee future
results. Certain market and economic risks exist that adversely affect an account’s performance.
This could result in capital losses in your account.
ADMINISTRATIVE SERVICES
EQ utilizes Black Diamond rebalancing software to model and allocate securities to client
accounts. BDR determines position sizing and allocates block trades to individual
accounts. BDR provides the number of shares or amount of dollars of a given security to
purchase based on the size of the account and the percentage allocation of that security
for the relevant model. The BDR software ensures necessary cash is available and
prevents accounts from being overbought. Members of the EQ Portfolio Management
team review BDR orders before execution. EQ utilizes block trading in BDR to facilitate
the best execution and ensure all clients receive similar pricing when allocated the same
security on the same day.
FINANCIAL PLANNING & CONSULTING SERVICES
Through the financial planning process, our team strives to engage our clients in conversations
around their goals, objectives, priorities, vision, and legacy – both for the near term as well as for
future generations. With each client's unique goals and circumstances in mind, our team will offer
financial planning ideas and strategies to address the client’s holistic financial picture, including
estate, income tax, charitable, cash flow, wealth transfer, and client legacy objectives. Our team
may partner with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance
Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals. Such
services include reports on specific goals and objectives, general investment and/or planning
recommendations, guidance to outside assets, and periodic updates.
Our specific services in preparing your plan may include:
• Review and clarification of your financial goals
• Assessment of your overall financial position, including cash flow, balance sheet,
investment strategy, risk management, and estate planning
• Creation of a unique plan for each goal you have, including personal and business real
estate, education, retirement or financial independence, charitable giving, estate
planning, business succession, and other personal goals
• Development of a goal-oriented investment plan, with input from various advisors to our
clients around tax suggestions, asset allocation, expenses, risk, and liquidity factors for
each goal. This includes IRA and qualified plans, taxable, and trust accounts that require
special attention
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 4
• Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and
transfer, including liquidity as well as various insurance and possible company benefits;
and
• Crafting and implementation of, in conjunction with your estate and/or corporate
attorneys as a tax adviser, an estate plan to provide for you and/or your heirs in the event
of incapacity or death
A written evaluation of each client's initial situation or Financial Plan is provided to the client. The
Adviser will provide an annual review if indicated and agreed to by the Client and Adviser per the
Agreement. More frequent reviews occur but are not necessarily communicated to the client
unless immediate changes are recommended.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in the
former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or
(iv) cash out the account value (which could, depending upon the client’s age, result in adverse
tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which
our Firm provides investment advisory services. As a result, our Firm and its representatives may
earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave
their plan assets with their previous employer or roll over the assets to a plan sponsored by a new
employer will generally result in no compensation to our Firm. Our Firm, therefore, has an
economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various factors
that our Firm will consider before recommending a rollover, including but not limited to: (i) the
investment options available in the plan versus the investment options available in an IRA, (ii) fees
and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and
responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of
assets from creditors and legal judgments, (v) required minimum distributions and age
considerations, and (vi) employer stock tax consequences, if any. All rollover recommendations
are reviewed by our Firm’s Chief Compliance Officer and remains available to address any
questions that a client or prospective client has regarding the oversight.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests.
WRAP FEE PROGRAM
Our Firm does not sponsor a Wrap Fee Program.
ASSETS
As of December 31, 2024, our firm manages $558,837,067 in discretionary assets, with no non-
discretionary accounts to report at this time.
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 5
ITEM 5 – FEES AND COMPENSATION
INVESTMENT MANAGEMENT FEES AND COMPENSATION
Our Firm charges a fee as compensation for providing Investment Management services on your
account. These services include advisory services, trade entry, investment supervision, and other
account maintenance activities. Our recommended Custodian charges transaction costs, custodial
fees, redemption fees, retirement plan and administrative fees or commissions. See Additional
Fees and Expenses below for details.
A monthly investment management fee is billed in arrears, calculated based on the average daily
balance of your account during the previous calendar month. Our maximum annual advisory fee
is 1.5%. The relevant fee and billing method is defined and agreed to by the firm and the client in
the executed Investment Advisory Agreement. This fee will be debited directly from your
investment account. Additional fees and expenses you may incur are brokerage commissions,
principal markups and discounts, SEC fees, mutual fund/ETF expense ratios, mutual fund 12B-1
fees, tax withholding on certain foreign securities, postage fees, wire fees, bank charges, and
other administration fees as authorized by you. Please refer to Section 12 for information on
brokerage fees and services.
Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in
the account, or other reasons agreed upon by our Firm and you as the client. In certain
circumstances, our fees and the timing of the fee payments may be negotiated. Fees may vary
based on the extent and complexity of your individual or family circumstances and the amount of
your assets under our management. Our employees and their family-related accounts are charged
a reduced fee for our services.
Unless otherwise instructed by the Client, we will aggregate related client accounts to determine
the account size and annualized fee. The common practice is often referred to as “house-holding”
portfolios for fee purposes and may result in lower fees than if fees were calculated on portfolios
separately. Our method of house-holding accounts for fee purposes looks at the overall family
dynamic and relationship. When applicable and noted in the Appendix of the Investment
Management Agreement, legacy positions will also be excluded from the fee calculation.
The independent and qualified custodian holding your funds and securities will debit your account
directly for the advisory fee and pay that fee to us. When establishing a relationship with EQWA,
you provide written authorization permitting the fees to be paid directly from your account held
by the qualified custodian. Further, the qualified Custodian agrees to deliver an account
statement to you monthly indicating all the amounts deducted from the account including our
advisory fees.
Either EQWA or you may terminate the management agreement immediately upon written notice
to the other party. The management fee will be pro-rated to the date of termination, for the
month in which the cancellation notice was given and any earned fee will be billed to you by our
Firm.
Upon termination, you are responsible for monitoring the securities in your account, and we will
have no further obligation to act or advise with respect to those assets. In the event of client’s
death or disability, we will continue management of the account until we are notified of client’s
death or disability and given alternative instructions by an authorized party.
In no case are EQWA fees based on, or related to, the performance of your funds or investments.
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 6
FINANCIAL PLANNING & CONSULTING SERVICE FEES
Financial planning and consulting services are included in the investment management fees
outlined above for our investment management clients. No additional fees apply.
RETIREMENT PLAN SERVICES FEES
For Retirement Plan Advisory Services compensation, we charge an advisory fee as negotiated
with the Plan Sponsor and as disclosed in the Employer-Sponsored Retirement Plans Consulting
Agreement (“Plan Sponsor Agreement”).
Typically, the billing period for these fees are paid quarterly in arrears. This fee is generally
negotiable, but terms and advisory fee is agreed to in advance and acknowledged by the Plan
Sponsor through the Plan Sponsor Agreement and/or Plan Provider’s account agreement. Fee
billing methods vary depending on the Plan Provider.
Our Firm or the Plan Sponsor may terminate the Agreement upon 30 days written notice to the
other party. The Plan Sponsor is responsible for paying for services rendered until the termination
of the Agreement.
ADMINISTRATIVE SERVICES FEE
EQWA and Black Diamond are non-affiliated companies. Black Diamond charges our Firm
an annual fee for each account administered by its software. Please note that the fee
charged to the client will not increase due to the annual fee EQWA pays to Black Diamond.
The annual fee is paid from the portion of the management fee retained by EQWA.
ADDITIONAL FEES AND EXPENSES:
In addition to the advisory fees paid to our Firm, you also incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, banks, and other financial
institutions (collectively “Financial Institutions”). These additional charges include custodial fees,
charges imposed by a mutual fund or ETF in a client’s account, as disclosed in the fund’s
prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-
lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes
on brokerage accounts and securities transactions. Our brokerage practices are described at
length in Item 12, below.
When selecting investments for our clients’ portfolios, we might choose mutual funds on your
account custodian’s Non-Transaction Fee (NTF) list. This means that your account custodian will
not charge a transaction fee or commission associated with the purchase or sale of the mutual
fund.
The mutual fund companies that choose to participate in your custodian’s NTF fund program pay
a fee to be included in the NTF program. The fee that a mutual fund company pays to participate
in the program is ultimately borne by the mutual fund owners, including our Firm's clients. When
we decide whether to choose a fund from your custodian’s NTF list, we consider our expected
holding period, the position size, and the fund's expense ratio versus alternative funds. Depending
on our analysis and future events, NTF funds might not always be in your best interest.
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not charge advisory fees on a share of the capital appreciation of the funds or securities in
a client account (so-called performance-based fees), nor engage side-by-side management.
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 7
ITEM 7 - TYPES OF CLIENTS
We provide investment advice to individuals with high net worth, foundations, employer-
sponsored retirement plans, institutions, trusts, and estates.
Our firm does not impose a minimum requirement for investable assets. However, certain private
investments may have their own minimum investable asset requirements for participation.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
We take an active approach in managing our client’s assets. Each account is rebalanced on either
a quarterly, semi-annual, or annual basis. The frequency of rebalancing is based on the account’s
time horizon, investment objective, current economic climate, and tax situation. While there may
be some similarities in the portfolios created by EQWA, we understand that every client has
unique planning needs. We have the ability and flexibility to create portfolios to help our client
achieve their goals. With our approach:
• we advise from a global investment approach, managing portfolios with a coordinated
strategy that also includes the client's various assets, such as 401(k) assets for working
clients, and those direct assets managed by the client or a third party. When crafting
financial plans, we assess the need for income, the time horizon for distributions, and the
client's risk tolerance, allocating funds in a tax-efficient manner.
• our portfolio construction involves a mix of ETFs, mutual funds, Berkshire Hathaway, and,
in specific cases, private investments. We allocate guided by Morningstar equity and bond
categories using a tactical approach, maintaining a balanced portfolio. For instance, if a
historical market valuation suggests a 15% allocation to large-cap value and 15% to large-
cap growth, we may adjust based on current valuations, deviating to 10% growth and 20%
value if necessary.
• we incorporate alternative asset class ETFs to reduce correlation with stocks and bonds.
We favor managers with low fees, minimal turnover, and a personal investment stake in
their funds. Our preference is for longer-term compensation structures over short-term
performance-based bonuses.
• we assess drift, asset class valuations, and other factors to rebalance portfolios on a
regular basis. Tax loss harvesting opportunities and potential events discussed in planning
meetings guide our trading decisions.
• we utilize Morningstar Research to compare our managers to their respective indices,
receiving updated lists weekly. While not making changes weekly, this process provides
us with information for our client discussions and investment considerations. We consider
Morningstar’s ratings, including the 0 to 5-star rating and gold, silver, and bronze
designations. Advisers execute trades, and assistants confirm these trades the following
day.
There is no guarantee that our strategy will meet its investment goals. The investment strategies
we use will vary over time depending on various factors. Our Firm may give advice and act for
clients, which differs from advice given or the timing or nature of action taken for other clients
with different objectives. Our Firm is not obligated to initiate transactions for clients in any
security that its principals, affiliates, or employees may purchase or sell for their accounts or other
clients.
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 8
Clients should be aware that ETFs and mutual funds have unique characteristics, and their cost
structures differ, sometimes significantly.
RISK OF LOSS
A client’s investment portfolio is affected by general economic and market conditions, such as
interest rates, availability of credit, inflation rates, economic conditions, changes in laws and
national and international political circumstances.
Investing in securities involve certain investment risks. Securities may fluctuate in value or lose
value. Clients should be prepared to bear the potential risk of loss. EQWA will assist Clients in
determining an appropriate strategy based on their tolerance for risk.
While we are alert to indications that data may be incorrect, there is always a risk that our analysis
may be compromised by inaccurate or misleading information.
Risks that apply to both fixed income and equity strategies include, but are not limited to, the
following:
• Active Management Risk: Due to its active management, a portfolio could underperform
other portfolios with similar investment objectives and/or strategies.
• Allocation Risk: A portfolio may use an asset allocation strategy in pursuit of its
investment objective. There is a risk that a portfolio’s allocation among asset classes or
investments will cause a portfolio to lose value or cause it to underperform other
portfolios with a similar investment objective and/or strategy, or that the investments
themselves will not produce the returns expected.
• Cybersecurity Risk. Cybersecurity risks include both intentional and unintentional events
at EQWA or one of its third-party counterparties or service providers, that may result in a
loss or corruption of data, result in the unauthorized release or other misuse of
confidential information, and generally compromise our Firm’s ability to conduct its
business. A cybersecurity breach may also result in a third-party obtaining unauthorized
access to our clients’ information, including social security numbers, home addresses,
account numbers, account balances, and account holdings. Our Firm has established
business continuity plans and risk management systems designed to reduce the risks
associated with cybersecurity breaches. However, there are inherent limitations in these
plans and systems, including that certain risks may not have been identified, in large part
because different or unknown threats may emerge in the future. As such, there is no
guarantee that such efforts will succeed, especially because our Firm does not directly
control the cybersecurity systems of our third-party service providers. There is also a risk
that cybersecurity breaches may not be detected.
•
Liquidity Risk: The risk that exists when a security’s limited marketability prevents it from
being bought or sold quickly enough to avoid or minimize a loss. This risk is particularly
relevant in the bond market, although it can also be a risk when transacting in small cap
securities and certain other stocks.
• Market and Timing Risk: Prices of securities may become more volatile due to general
market conditions that are not specifically related to a particular company, such as
adverse economic conditions or outlooks, adverse investor sentiment, changes in the
outlook for corporate earnings, or changes in interest rates.
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 9
• Sector/Region Risk: The risk that the strategy’s concentration in equities or bonds in a
specific sector or industry will cause the strategy to be more exposed to the price
movements in and developments affecting that sector.
• Event Risk: The possibility that an unforeseen event will negatively affect a company or
industry, and thus, increase the volatility of the security.
Risks associated with our fixed income strategies include, but are not limited to, the following:
• Asset-Backed Securities Risk: Payment of principal and interest on asset-backed
securities is dependent largely on the cash flows generated by the assets backing the
securities. Further, some asset backed securities may not have the benefit of any security
interest in the related assets. There is also the possibility that recoveries in the underlying
collateral may not be available to support the payments on these securities. Downturns
in the economy could cause the value of asset backed securities to fall, thus, negatively
impacting account performance.
• Call Risk: Some bonds give the issuer the option to redeem the bond before its maturity
date. If an issuer exercises this option during a time of declining interest rates, the
proceeds from the bond may have to be reinvested in an investment offering a lower yield
and may not benefit from an increase in value as a result of declining rates. Callable bonds
also are subject to increased price fluctuations during periods of market illiquidity or rising
interest rates. Finally, the capital appreciation potential of a bond will be reduced because
the price of a callable bond may not rise much above the price at which the issuer may
call the bond.
• Corporate Debt Risk: The rate of interest on a corporate debt security may be fixed,
floating, variable, or may vary inversely with respect to a reference rate. Corporate debt
securities are subject to the risk of the issuer’s inability to meet principal and interest
payments on the obligation. They also may be subject to price volatility due to interest
rate sensitivity, market perception of the creditworthiness of the issuer and general
market liquidity. When interest rates rise, the value of a corporate debt security can be
expected to decline. Debt securities with longer maturities tend to be more sensitive to
interest rate movements than those with shorter maturities. A company default can
reduce income and capital value of a corporate debt security. Moreover, market
expectations regarding economic conditions and the likely number of corporate defaults
may impact the value of these securities.
• Credit Default Risk: The risk of loss of principal due to the borrower’s failure to repay the
loan or risk of liquidity from the decline in the borrower’s financial strength.
• Duration Risk: The risk associated with the sensitivity of a bond’s price to a change in
interest rates. The higher a bond’s (or portfolio’s) duration, the greater its sensitivity to
interest rate changes.
• Government Securities Risk: Not all U.S. government securities are backed by the full
faith and credit of the U.S. government. It is possible that the U.S. government would not
provide financial support to certain of its agencies or instrumentalities if it is not required
to do so by law. If a U.S. government agency or instrumentality defaults and the U.S.
government does not stand behind the obligation, returns could be negatively impacted.
EQ WEALTH ADVISORS, LLC
MARCH 2025 | PAGE 10
The U.S. government guarantees payment of principal and timely payment of interest on
certain U.S. government securities.
•
Interest Rate Risk: Prices of fixed income securities tend to move inversely with changes
in interest rates. As interest rates rise, bond prices typically fall and vice versa. The longer
the effective maturity and duration of a strategy’s portfolio, the more the performance
of the investment is likely to react to interest rates.
• Municipal Bond Risk: Investments in municipal bonds are affected by the municipal
market as a whole and the various factors in the particular cities, states, or regions in
which the strategy invests. Issues such as legislative changes, litigation, business, and
political conditions relating to a particular municipal project, municipality, state or
territory, and fiscal challenges can impact the value of municipal bonds. These matters
can also impact the ability of the issuer to make payments. Also, the amount of public
information available about municipal bonds is generally less than that for corporate
equities or bonds. Additionally, supply and demand imbalances in the municipal bond
market can cause deterioration in liquidity and lack of price transparency.
• Performance of Underlying Managers: We select the mutual funds and ETFs in the
portfolios. However, we depend on the manager of such funds to select individual
investments in accordance with their stated investment strategy.
• Prepayment Risk: Similar to call risk, this risk is associated with the early unscheduled
repayment of principal on a fixed income security. When principal is returned early, future
interest payments will not be paid. The proceeds from the repayment may be reinvested
in securities at a lower, prevailing rate.
• Reinvestment Risk: The risk that future cash flows, either coupons or the final return of
principal, will need to be reinvested in lower-yielding securities.
• State Risk: Portfolios with state or region-specific customizations will be more sensitive
to the events that affect that state’s economy and stability. Portfolios with a higher
concentration of bonds in a state or region may have higher credit risk exposure,
especially if the percentage of assets dedicated to the state is invested in fewer issuers.
• Tax Liability Risk: The risk that the distributions of municipal securities become taxable
to the investor due to noncompliant conduct by the municipal bond issuer or changes to
federal and state laws. These adverse actions would likely negatively impact the prices of
the securities.
• Valuation Risk: The lack of an active trading market and/or volatile market conditions can
make it difficult to obtain an accurate price for a fixed income security. There are
uncertainties associated with pricing a security without a reliable market quotation, and
the resulting value may be very different than the value of what the security would have
been if readily available market quotations had been available. Risks associated with our
equity strategies include, but are not limited to, the following:
• Capitalization Risk: Small-cap and mid-cap companies may be hindered as a result of
limited resources or less diverse products or services Their stocks have historically been
more volatile than the stocks of larger, more established companies.
• Exchange-Traded Fund (“ETF”) and Mutual Fund Risk: Investments in ETFs and mutual
funds have unique characteristics, including, but not limited to, the ETF or mutual fund’s
expense structure. Investors of ETFs and mutual funds held within EQWA client accounts
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bear both their EQWA portfolio’s advisory expenses and, indirectly, the ETF’s or mutual
fund’s expenses. Because the expenses and costs of an underlying ETF or mutual fund are
shared by its investors, redemptions by other investors in the ETF or mutual fund could
result in decreased economies of scale and increased operating expenses for such ETF or
mutual fund. Additionally, the ETF or mutual fund may not achieve its investment
objective. Actively managed ETFs or mutual funds may experience significant drift from
their stated benchmark.
• Foreign Securities Risk: Investments in or exposure to foreign securities involve certain
risks not associated with investments in or exposure to securities of U.S. companies.
Foreign securities subject a portfolio to the risks associated with investing in the particular
country of an issuer, including the political, regulatory, economic, social, diplomatic, and
other conditions or events (including, for example, military confrontations, war, and
terrorism), occurring in the country or region, as well as risks associated with less
developed custody and settlement practices. Foreign securities may be more volatile and
less liquid than securities of U.S. companies and are subject to the risks associated with
potential imposition of economic and other sanctions against a particular foreign country,
its nationals or industries or businesses within the country. In addition, foreign
governments may impose withholding or other taxes on income, capital gains or proceeds
from the disposition of foreign securities, which could reduce a portfolio’s return on such
securities.
• Frequent Trading Risk: A portfolio manager may actively and frequently trade
investments in a portfolio to carry out its investment strategies. Frequent trading of
investments increases the possibility that a portfolio, as relevant, will realize taxable
capital gains (including short-term capital gains, which are generally taxable at higher
rates than long-term capital gains for U.S. federal income tax purposes), which could
reduce a portfolio's after-tax return. Frequent trading can also mean higher brokerage
and other transaction costs, which could reduce a portfolio's return. The trading costs and
tax effects associated with portfolio turnover can adversely affect its performance.
• Option Risk: Variable degree of risk. Transactions in options carry a high degree of risk.
Purchasers and sellers of options should familiarize themselves with the type of option
(i.e., put or call) which they contemplate trading and the associated risks. Traders of
options should calculate the extent to which the value of the options must increase for
the position to become profitable, taking into account the premium and all transaction
costs.
o The purchaser of options may offset or exercise the options or allow the options
to expire. The exercise of an option results either in a cash settlement or in the
purchaser acquiring or delivering the underlying interest. If the option is on a
future, the purchaser will acquire a futures position with associated liabilities for
margin (see the section on Futures below). If the purchased options expire
worthless, the purchaser will suffer a total loss of the investment. In purchasing
deep out-of-the-money options, the purchaser should be aware that the chance
of such options becoming profitable ordinarily is remote.
o Selling ("writing" or "granting") an option generally entails considerably greater
risk than purchasing options. Although the premium received by the seller is
fixed, the seller may sustain a loss well in excess of that amount. The seller will
be liable for additional margin to maintain the position if the market moves
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unfavorably. The seller will also be exposed to the risk of the purchaser exercising
the option and the seller being obligated to either settle the option in cash or to
acquire or deliver the underlying interest. If the option is on a future, the seller
will acquire a position in a future with associated liabilities for margin (see the
section on Futures below). If the option is "covered" by the seller holding a
corresponding position in the underlying interest or a future or another option,
the risk may be reduced. If the option is not covered, the risk of loss can be
unlimited.
o Certain exchanges in some jurisdictions permit deferred payment of the option
premium, exposing the purchaser to liability for margin payments not exceeding
the amount of the premium. The purchaser is still subject to the risk of losing the
premium and transaction costs. When the option is exercised or expires, the
purchaser is responsible for any unpaid premium outstanding at that time.
•
Issuer Risk: The risk that an issuer of a security may perform poorly, and therefore, the
value of its securities may decline. Poor performance may be caused by poor
management decisions, competitive pressures, breakthroughs in technology, reliance on
suppliers, labor problems or shortages, corporate restructurings, fraudulent disclosures,
natural disasters or other events, conditions, or factors.
• Market Risk: When the stock market strongly favors a particular style of equity investing,
some or all of EQWA ’s equity strategies could underperform. The performance of clients’
accounts could suffer when EQWA ’s particular investment strategies are out of favor. For
example, EQWA ’s large cap equity strategies could underperform when the market
favors smaller capitalization stocks. EQWA ’s strategies with exposure to small/mid cap
stocks could underperform when the market favors larger cap stocks. Additionally,
growth securities could underperform when the market favors value securities.
• Sector Risk: At times, a portfolio may have a significant portion of its assets invested in
securities of companies conducting business in a related group of industries within an
economic sector. Companies in the same economic sector may be similarly affected by
economic, regulatory, political or market events or conditions, which make a portfolio
more vulnerable to unfavorable developments in that economic sector than portfolios
that invest more broadly. Generally, the more a portfolio diversifies its investments, the
more it spreads risk and potentially reduces the risks of loss and volatility.
• Alternative Investments: Our Firm’s use of alternative assets is limited to the investments
approved on our recommended Custodian(s) Alternative Investments platform in
addition to publicly traded ETFs or ‘40 Act’ funds with specific exposure in commodities,
long/short strategies, real estate, and covered call writing. Investments classified as
"alternative investments" may include a broad range of underlying assets including, but
not limited to, hedge funds, private equity, venture capital, and registered, publicly
traded securities. Alternative investments are speculative, not suitable for all clients and
intended for only experienced and sophisticated investors who are willing to bear the
high risk of the investment, which can include: loss of all or a substantial portion of the
investment due to leveraging, short-selling, or other speculative investment practices;
lack of liquidity in that there may be no secondary market for the fund and none expected
to develop; volatility of returns; potential for restrictions on transferring interest in the
fund; potential lack of diversification and resulting higher risk due to concentration of
trading authority with a single advisor; absence of information regarding valuations and
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pricing; potential for delays in tax reporting; less regulation and typically higher fees than
other investment options such as mutual funds. The SEC requires investors be accredited
to invest in these more speculative alternative investments. Investing in a fund that
concentrates its investments in a few holdings may involve heightened risk and result in
greater price volatility.
• Non-Liquid Alternative Investments - From time to time, our Firm will recommend to
certain qualifying clients that a portion of such clients’ assets be invested in private funds,
private fund-of-funds and/or other alternative investments (collectively, “Nonliquid
Alternative Investments”). Nonliquid Alternative Investments are not suitable for all of
our Firm’s clients and are offered only to those qualifying clients for whom our Firm
believes such an investment is suitable and in line with their overall investment strategy.
Nonliquid Alternative Investments typically are available to only a limited number of
sophisticated investors who meet the definition of “accredited investor” under
Regulation D of the Securities Act of 1933, as amended (the “Securities Act”), or “qualified
client” under the Investment Advisers Act of 1940, or “qualified purchaser” under the
Investment Company Act of 1940. Nonliquid Alternative Investments present special risks
for our Firm’s clients, including without limitation, limited liquidity, higher fees and
expenses, volatile performance, no assurance of investment returns, heightened risk of
loss, limited transparency, additional reliance on underlying management of the
investment, special tax considerations, subjective valuations, use of leverage and limited
regulatory oversight. When a Nonliquid Alternative Investment invests part or all of its
assets in real estate properties, there are additional risks that are unique to real estate
investing, including but not limited to: limitations of the appraisal value; the borrower’s
financial conditions (if the underlying property has been obtained by a loan), including
the risk of foreclosures on the property; neighborhood values; the supply of and demand
for properties of like kind; and certain city, state and/or federal regulations. Additionally,
real estate investing is also subject to possible loss due to uninsured losses from natural
and man-made disasters. The above list is not exhaustive of all risks related to an
investment in Nonliquid Alternative Investments. A more comprehensive discussion of
the risks associated with a particular Nonliquid Investment is set forth in that fund’s
offering documents, which will be provided to each client subscribing to a Nonliquid
Alternative Investment, for review and consideration. It is important that each potential,
qualified investor carefully read each offering or private placement memorandum prior
to investing.
• Digital Assets. Digital asset prices have been subject to periods of excessive volatility in
the past, and such periods can be expected to recur. Price volatility is influenced by many
unpredictable factors, such as market perception, the development of competing digital
assets, changes in government regulation, the occurrence of an adverse incident relating
to one or more digital assets (including digital assets not held by Accounts), inflation rates,
interest rate movements, and general economic and political conditions. Changes in the
governance of a digital asset network may not receive sufficient support from users and
miners, which may negatively affect that digital asset network’s ability to grow and
respond to challenges. Further, digital asset networks face significant scaling challenges,
and efforts to increase the volume and speed of transactions may not be successful. If the
digital asset award for mining blocks and transaction fees for recording transactions on
the Bitcoin Network are not sufficiently high to incentivize miners, miners may cease
expanding processing power or demand high transaction fees, which could negatively
impact the value of Bitcoin. OTC platforms may impose minimum trade size or other
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requirements that an Account is unable to satisfy. Exchanges on which digital assets trade
generally are relatively new and largely unregulated, and may therefore be more exposed
to fraud, mismanagement and failure than established, regulated exchanges for other
products. The SEC, CFTC, certain state regulators and other U.S. and non-U.S. government
or quasigovernmental agencies have asserted authority over digital assets. Those entities
and other U.S. and non-U.S. government or quasi-governmental agencies have recently
and may, in the future, adopt laws, regulations, directives or other guidance that affect
digital assets. The effect of any future U.S. federal or state or non-U.S. legal or regulatory
changes is impossible to predict, but such change could be substantial and adverse to the
value of an Account’s digital asset investments. Furthermore, the taxation of digital
currencies is uncertain in many jurisdictions and continuously evolving in others. Venues
through which digital assets trade are new and, in many cases, largely unregulated.
Furthermore, many such digital asset trading venues, including digital asset exchanges
and over the counter trading venues, do not provide the public with significant
information regarding their ownership structure, management teams, corporate
practices, or regulatory compliance. As a result, the marketplace may lose confidence in,
or may experience problems relating to, digital asset trading venues. Digital asset trading
venues may impose daily, weekly, monthly, or customer-specific transaction or
distribution limits or suspend withdrawals entirely, rendering the exchange of digital
assets for fiat currency difficult or impossible.
• ESG (Environmental–Social–Governance) Investing Risk. The analysis of ESG issues is
integrated in our investment process for our ESG strategies. This means that we consider
the risk/return implications of ESG issues when making or evaluating our investments. We
manage our strategies with ESG constraints determined by our Firm. We utilize data and
screens from third-party service providers in connection with applying the constraints.
Our Firm’s strategies are subject to ESG guidelines and restrictions and could
underperform accounts invested in a similar strategy without the same restrictions
because the ESG guidelines can force a portfolio manager to avoid or liquidate a well-
performing security because it does not meet the ESG criteria.
• Spot Bitcoin Virtual Currency-Based Risk (“SPBC”). Our Firm may invest Client accounts
in SPBC products. The investment characteristics of SPBC assets differ from those of
traditional currencies, commodities, or securities. Importantly, SPBC assets are not
backed by a central bank, a national, supranational, quasi-national organization, hard
assets, human capital, or other forms of credit. Rather, SPBCs are market-based: the value
is determined by, and often dramatically fluctuates, according to supply and demand
factors, the number of merchants that accept it, or the value that various market
participants place on it through their mutual agreement, barter, or transactions.
The value of the Client's portfolios relates in part to the value of the SPBC assets held in
the Client's portfolio; fluctuations in price could adversely affect the value of the Client’s
portfolio. The price of SPBC assets achieved by a Client may be affected typically by a wide
variety of complex and difficult-to-predict factors such as supply and demand and the
risks associated due to bitcoin being primarily a speculative and highly volatile asset that
is also used for illicit activity including ransomware, money laundering, sanction evasion,
and terrorist financing.
• Responsible Investing and ESG Risk. Clients utilizing responsible investing strategies and
environment, social responsibility, and corporate governance (ESG) factors may
investing and ESG
underperform strategies which do not utilize responsible
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considerations. Responsible investing and ESG strategies may operate by either excluding
the investments of certain issuers or by selecting investments based on their compliance
with factors such as ESG. This strategy may exclude certain sectors or industries from a
client’s portfolio, potentially negatively affecting the client’s investment performance if
the excluded sector or industry outperforms. Responsible investing and ESG are
subjective by nature, and our Firm may rely on analysis and ‘scores’ provided by third
parties in determining whether an issuer meets our Firm’s standards for inclusion or
exclusion. A client’s perception may differ from our Firm or a third parties on how to judge
an issuers adherence to responsible investing principles.
ITEM 9 - DISCIPLINARY INFORMATION
We do not have any legal, financial, or other “disciplinary” item to report.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
INSURANCE
Some of our Investment Adviser Representatives (“IARs”) of the Firm are licensed Insurance
agents registered with various State Insurance Departments. IARs receives compensation
(commissions, trails, or other compensation from the respective insurance products) as a result
effecting insurance transactions for mutual client(s) of EQWA. Commissions generated by
insurance sales do not offset regular advisory fees. Our firm has an incentive to recommend
insurance products, and this incentive creates a conflict of interest between your interests and
our Firm. We mitigate this conflict by disclosing to clients they have the right to decide whether
to engage the Insurance services offered through our IARs. Further, clients should note they have
the right to decide whether to act on the recommendations and the right to choose any
professional to execute the advice for any insurance products through any licensed insurance
agent not affiliated with our Firm. We recognize the fiduciary responsibility to place the client’s
interests first and have established policies in this regard to avoid any conflicts of interest.
BROKER DEALER
EQWA is not a broker/dealer, but some of our Investment Advisor Representatives (“IAR”) are
registered representatives and/or Investment Advisor Representatives of PKS (“PKS”), a full-
service broker-dealer, member FINRA/SIPC, which compensates them for effecting securities
transactions. When placing securities transactions through PKS in their capacity as registered
representatives, they will earn sales commissions. Because some of the IARs are dually registered
representatives and agents of PKS and EQWA, PKS has certain supervisory and administrative
duties pursuant to the requirements of FINRA Conduct Rule 3280. PKS and EQWA are not affiliated
companies. Some of the IARs of EQWA spend a portion their time in connection with
broker/dealer activities.
As a broker-dealer, PKS engages in a broad range of activities normally associated with securities
brokerage firms. Pursuant to the investment advice given by EQWA or its IARs, investments in
securities may be recommended for clients. If PKS is selected as the broker-dealer, PKS and its
registered representatives, including some of the IARs of EQWA, may individually receive
commissions for executing securities transactions.
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You are advised that if PKS is selected as the broker-dealer, the transaction charges may be higher
or lower than the charges you may pay if the transactions were executed at other broker/dealers.
You should note, however, that you are under no obligation to purchase securities through IARs
of EQWA or PKS.
Moreover, you should note that under the rules and regulations of FINRA, PKS has an obligation
to maintain certain client records and perform other functions regarding certain aspects of the
investment advisory activities of its registered representatives. These obligations require PKS to
coordinate with and have the cooperation of its registered representatives that operate as, or are
otherwise associated with, investment advisors other than PKS. Accordingly, PKS may limit the
use of certain custodial and brokerage arrangements available to clients of EQWA and PKS may
collect, as paying agent of EQWA, the investment advisory fee remitted to EQWA by the account
custodian. PKS may retain a portion of the investment advisory fee you pay, as a charge for the
functions it performs, and such portion may be further re-allowed to other registered
representatives of PKS. The charge will not increase the advisory fee you have agreed to pay
EQWA.
Some of the IARs of EQWA, in their capacity as registered representatives of PKS, or as agents
appointed with various life, disability or other insurance companies, receive insurance
commissions, fee trails, or other compensation from the respective product sponsors and/or as a
result of effecting securities transactions for clients. However, clients should note that they are
under no obligation to purchase any investment products through EQWA’s representatives.
As a result of the relationship with PKS, they may have access to certain confidential information
(e.g., financial information, investment objectives, transactions, and holdings) about EQWA
clients, even if client does not establish any account through PKS. If you would like a copy of the
PKS privacy policy, please contact our firm’s CCO. The contact information for EQWA can be found
on the Cover Page of this Brochure.
OTHER FINANCIAL INDUSTRY ACTIVITIES
Our Firm does not have an application pending to register, as a futures commission merchant,
commodity pool operator, a commodity trading adviser, or an associated person of the foregoing
entities.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
Our Firm and persons associated with us are allowed to invest for their own accounts or to have
a financial investment in the same securities or other investments that we recommend or acquire
for your account and may engage in transactions that are the same as or different than
transactions recommended to or made for your account. This creates a conflict of interest. We
recognize the fiduciary responsibility to act in your best interest and have established policies to
mitigate conflicts of interest.
We have developed and implemented a Code of Ethics that sets forth standards of conduct
expected of our advisory personnel to mitigate this conflict of interest. The Code of Ethics
addresses, among other things, personal trading, gifts, and the prohibition against the use of
inside information.
The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate
personnel regarding the Firm’s expectations and laws governing their conduct, remind personnel
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that they are in a position of trust and must act with complete propriety at all times, protect the
reputation of EQWA, safeguard against the violation of the securities laws, and establish
procedures for personnel to follow so that we may determine whether their personnel are
complying with the Firm’s ethical principles.
We have established the following restrictions in order to ensure our Firm’s fiduciary
responsibilities:
• A director, officer, or employee of EQWA shall not buy or sell any securities for their
personal portfolio(s) where their decision is substantially derived, in whole or in part, by
reason of his or her employment unless the information is also available to the investing
public on reasonable inquiry No supervised employee of EQWA shall prefer his or her own
interest to that of the advisory client. Trades for supervised employees are traded
alongside client accounts
• We maintain a list of all securities holdings of anyone associated with this advisory
practice with access to advisory recommendations. These holdings are reviewed on a
regular basis by an appropriate officer/individual of EQWA
• We emphasize the unrestricted right of the client to decline implementation of any advice
rendered, except in situations where we are granted discretionary authority of the client’s
account
• We require that all supervised employees must act in accordance with all applicable
Federal and State regulations governing registered investment advisory practices
• Any supervised employee not in observance of the above may be subject to termination
None of our associated persons may affect for himself/herself or for accounts in which he/she
holds a beneficial interest, any transactions in a security which is being actively recommended to
any of our clients, unless in accordance with the Firm’s procedures.
You may request a complete copy of our Code by contacting us at the address, telephone, or email
on the cover page of this Part 2; ATTN: Patricia Harris, Chief Compliance Officer.
ITEM 12 - BROKERAGE PRACTICES
INVESTMENT MANAGEMENT SERVICES
Clients must maintain assets in an account at a “qualified custodian,” generally a broker-dealer or
bank. We recommend that our clients use Charles Schwab & Co., Inc. Advisor Services (“Schwab”),
a registered broker-dealer, member SIPC, as the qualified custodian. We are independently
owned and operated, and unaffiliated with Schwab. Schwab will hold client assets in a brokerage
account titled to the client and buy and sell securities when we instruct them to.
While we recommend that clients use Schwab as Custodian, client must decide whether to do so
and open accounts with Schwab by entering into account agreements directly with them. The
Client opens the accounts with Schwab. The accounts will always be held in the name of the client
and never in EQWA’s name.
HOW WE SELECT CUSTODIANS
We seek to recommend a custodian who will hold client assets and execute transactions on terms
that are, overall, most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others:
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• Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for client accounts)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds (ETFs), etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, other fees, etc.) and
willingness to negotiate the prices
• Reputation, financial strength, and stability
• Prior service to EQWA and our other clients
• Availability of other products and services that benefit us, as discussed below (see
Products and Services Available to Us from Schwab)
CLIENT BROKERAGE AND CUSTODY COSTS
For our clients’ accounts that Schwab maintains, Schwab generally does not charge separately for
custody services. However, Schwab receives compensation by charging ticket charges or other
fees on trades that it executes or that settle into clients’ Schwab accounts. We have determined
that having Schwab execute most trades is consistent with our duty to seek “best execution” of
client trades. Best execution means the most favorable terms for a transaction based on all
relevant factors, including those listed above (see How We Select Custodians).
PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB
Schwab provides EQWA 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 do not have to
request them) and at no charge to us. These are considered economic benefits because there is
an incentive to do business with Schwab. This creates a conflict of interest. We recognize the
fiduciary responsibility to always act in best interest of our clients and have established policies
in this regard to mitigate any conflicts of interest.
Following is a more detailed description of Schwab’s support services:
SERVICES THAT BENEFIT OUR CLIENTS
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
our clients and their accounts.
SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS
Schwab also makes available to us other products and services that benefit us but may
not directly benefit our clients or their accounts. These products and services assist us in
managing and administering our clients’ accounts. They include investment research,
both Schwab’s own and that of third parties. We may use this research to service all or a
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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:
• Provide access to client account data (such as duplicate trade confirmations and
account statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
SERVICES THAT GENERALLY BENEFIT ONLY US
Schwab also offers other services intended to help us manage and further develop our
business enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance
providers
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 of 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. These services are not contingent upon us committing any
specific amount of business to Schwab in trading commissions. We believe that our
recommendation of Schwab as custodian is in the best interests of our clients.
Some of the products, services and other benefits provided by Schwab benefit EQWA and
may not benefit our client accounts. Our recommendation or requirement that you place
assets in Schwab's custody may be based in part on benefits Schwab provides to us, or
our agreement to maintain certain Assets Under Management at Schwab, and not solely
on the nature, cost or quality of custody and execution services provided by Schwab.
We place trades for our clients' accounts subject to its duty to seek best execution and its
other fiduciary duties. Schwab's execution quality may be different than other custodians.
AGGREGATION AND ALLOCATION OF TRANSACTIONS
Our Firm does not typically aggregate transactions; however, we may aggregate transactions if
we believe that aggregation is consistent with the duty to seek the best execution for our clients
and is consistent with the disclosures made to clients and terms defined in the client Investment
Advisory Agreement. If we do aggregate trades for ourselves or our associated persons with your
trades, we will ensure that the following conditions are met:
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• Our policy for the aggregation of transactions shall be fully disclosed separately to our
existing clients (if any) and the broker/dealer(s) through which such transactions will be
placed;
• We will not aggregate transactions unless we believe that aggregation is consistent with
our duty to seek the best execution (which includes the duty to seek best price) for you
and is consistent with the terms of our Investment Advisory Agreement with you for
which trades are being aggregated.
• No advisory client will be favored over any other client; each client that participates in an
aggregated order will participate at the average share price for all our transactions in a
given security on a given business day, with transaction costs based on each client’s
participation in the transaction;
• We will prepare an internal allocation statement specifying the participating client
•
accounts and how to allocate the order among those clients;
If the aggregated order is filled in its entirety, it will be allocated among clients in
accordance with the allocation statement; if the order is partially filled, the accounts that
did not receive the previous trade’s positions should be “first in line” to receive the next
allocation.
• Notwithstanding the foregoing, the order may be allocated on a basis different from that
specified in the allocation statement if all client accounts receive fair and equitable
treatment and the reason for the difference in allocation is explained in writing and is
reviewed by our compliance officer. Our books and records will separately reflect, for
each client account, the orders that are aggregated, and the securities held by and bought
for that account.
• We will receive no additional compensation or remuneration of any kind as a result of the
•
proposed aggregation; and
Individual advice and treatment will be accorded to each advisory client.
BROKERAGE FOR CLIENT REFERRALS
Our Firm does not receive client referrals from any Custodian or third party in exchange for using
that broker-dealer or third party.
TRADE ERRORS
We have implemented procedures designed to prevent trade errors; however, trade errors in
client accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to
correct trade errors in a manner that is in the best interest of the client. In cases where the client
causes the trade error, the client will be responsible for any loss resulting from the correction.
Depending on the specific circumstances of the trade error, the client may not be able to receive
any gains generated as a result of the error correction. In all situations where the client does not
cause the trade error, the client will be made whole, and we will absorb any loss resulting from
the trade error if the error was caused by the firm. If the error is caused by the Custodian, the
Custodian will be responsible for covering all trade error costs. If an investment gain results from
the correcting trade, the gain will be donated to charity. We will never benefit or profit from trade
errors.
DIRECTED BROKERAGE
We do not routinely recommend, request, or require that you direct us to execute transactions
through a specified broker-dealer. Additionally, we typically do not permit you to direct
brokerage. We place trades for your account subject to our duty to seek best execution and other
fiduciary duties.
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ITEM 13 - REVIEW OF ACCOUNTS
ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES
Investment Adviser Representatives will monitor client accounts on a regular basis and perform
annual reviews with each client. All accounts are reviewed for consistency with client investment
strategy, asset allocation, risk tolerance, and performance relative to the appropriate benchmark.
More frequent reviews may be triggered by changes in an account holder’s personal, tax, or
financial status or at the Investment Advisor Representative’s discretion. Geopolitical and
macroeconomic-specific events may also trigger reviews.
STATEMENTS AND REPORTS
The custodian for the individual client’s account will provide clients with a written account
statement at least monthly. Upon request, clients can receive a prepared written report detailing
their current positions, asset allocation, and year-to-date performance provided by our Firm.
You are urged to compare the reports provided by EQWA against the account statements you
receive directly from your account custodian.
• Financial Planning Services – Your review will be conducted by your assigned Investment
Advisor. We realize that events and circumstances could change dramatically in between
normal reviews. Therefore, if you experience an event in your life that might necessitate
an early review of your Financial Plan, please let us know and we will be happy to schedule
a more frequent review. Such an event might include a marriage, divorce, birth of a child,
death or disability of an immediate family member, impending retirement, employment
status, or you bought or sold a business. We also encourage you to ask us if you have any
questions about your Financial Plan or the reports that we generate.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Our firm neither accepts nor pay fees for client referrals. Further, we do not have any
compensation arrangements other than what is disclosed in this Brochure.
As disclosed under Item 12 Brokerage Practices, we participate in the various Custodian’s
institutional customer programs, and we may recommend a Custodian to you for custody and
brokerage services. There is no direct link between our participation in the program and the
investment advice we give to our clients, although we receive economic benefits through our
participation in the program that are typically not available to any other independent Investment
Advisors participating in the program. These benefits include the following products and services
(provided without cost or at a discount):
receipt of duplicate Client statements and confirmations;
research related products and tools;
consulting services;
•
•
•
• access to a trading desk serving adviser participants;
• access to block trading (which provides the ability to aggregate securities transactions for
execution and then allocate the appropriate shares to Client accounts);
the ability to have advisory fees deducted directly from Client accounts;
•
• access to an electronic communications network for Client order entry and account
information;
• access to mutual funds with no transaction fees and to certain institutional money
managers;
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• and discounts on compliance, marketing, research, technology, and practice management
products or services provided to us by third party vendors.
Custodians may also have paid for business consulting and professional services received by some
of our related persons. Some of the products and services made available by Custodians through
the program may benefit us but may not benefit your account. These products or services may
assist us in managing and administering your account, including accounts not maintained at
Custodian. Other services made available by Custodian are intended to help us manage and
further develop our business enterprise. The benefits received by our Firm or our personnel
through participation in the program do not depend on the amount of brokerage transactions
directed to Custodian. You do not pay more for assets maintained at Schwab as a result of these
arrangements. As part of our fiduciary duties to clients, we endeavor at all times to put the
interests of our clients first. You should be aware, however, that the receipt of economic benefits
by our Firm or our related persons in and of itself creates a conflict of interest because the cost
of these services would otherwise be borne directly by us. These arrangements could indirectly
influence our choice of Custodian for custody and brokerage services. You should consider these
conflicts of interest when selecting a custodian. The products and services provided by Schwab,
how they benefit us, and the related conflicts of interest are described above.
ITEM 15 – CUSTODY
We do not have physical custody, as it applies to investment advisors. Custody has been defined
by regulators as having access or control over client funds and/or securities.
DEDUCTION OF ADVISORY FEES
For all accounts, our Firm has the authority to have fees deducted directly from client accounts.
Our Firm has established procedures to ensure all client funds and securities are held at a qualified
custodian in a separate account for each client under that client’s name. Clients, or an
independent representative of the client, will direct, in writing, the establishment of all accounts
and therefore are aware of the qualified custodian’s name, address, and the way the funds or
securities are maintained. Finally, account statements are delivered directly from the qualified
custodian to each client, or the client’s independent representative, at least quarterly. You should
carefully review those statements and are urged to compare the statements against reports
received from EQWA. When you have questions about your account statements, you should
contact EQWA or the qualified custodian preparing the statement.
Please refer to Item 5 for more information about the deduction of adviser fees.
STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Our Firm is deemed to have custody of clients’ funds or securities when you have standing
authorizations with their custodian to move money from your account to a third-party (“SLOA”)
and, under that SLOA, it authorizes us to designate the amount or timing of transfers with the
custodian. The SEC has set forth a set of standards intended to protect your assets in such
situations, which we follow. We do not have a beneficial interest on any of the accounts we are
deemed to have Custody where SLOAs are on file. In addition, account statements reflecting all
activity on the account(s), are delivered directly from the qualified custodian to each client or the
client’s independent representative, at least monthly. You should carefully review those
statements and are urged to compare the statements against reports received from us. When you
have questions about your account statements, you should contact us, your Adviser or the
qualified custodian preparing the statement.
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ITEM 16 – INVESTMENT DISCRETION
For discretionary accounts, prior to engaging EQWA to provide investment advisory services, you
will enter a written Agreement with us granting the Firm the authority to supervise and direct, on
an on-going basis, investments in accordance with the client’s investment objective and
guidelines. In addition, you will need to execute additional documents required by the Custodian
to authorize and enable EQWA, in its sole discretion, without prior consultation with or ratification
by you, to purchase, sell, or exchange securities in and for your accounts. We are authorized, in
our discretion and without prior consultation with you to: (1) buy, sell, exchange, and trade any
stocks, bonds or other securities or assets and (2) determine the amount of securities to be bought
or sold, and (3) place orders with the custodian. Any limitations to such discretionary authority
will be communicated to our Firm in writing by you, the client.
The limitations on investment and brokerage discretion held by EQWA for you are:
• For discretionary accounts, we require that we be provided with authority to determine
which securities and the amounts of securities to be bought or sold.
• Any limitations on this discretionary authority shall in writing as indicated on the
investment advisory Agreement, Appendix B. You may change/amend these limitations
as required.
In some instances, we may not have discretion. We will discuss all transactions with you prior to
execution or you will be required to make the trades if in an employer sponsored account.
ITEM 17 – VOTING CLIENT SECURITIES
We will not vote proxies on your behalf. You are welcome to vote proxies or designate an
independent third-party at your own discretion. You designate proxy voting authority in the
custodial account documents. You must ensure that proxy materials are sent directly to you or
your assigned third party. We do not take action with respect to any securities or other
investments that become the subject of any legal proceedings, including bankruptcies. You can
contact our office with questions about a particular solicitation by phone at 214-389-6750.
ITEM 18 – FINANCIAL INFORMATION
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or
more in advance. Therefore, we are not required to include a balance sheet for our most recent
fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability
to meet contractual commitments to clients.
Finally, we have not been the subject of a bankruptcy petition at any time.
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