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Item 1 – Cover Page
DISCLOSURE BROCHURE
419 Yale Avenue
Claremont, CA 91711
www.evermont.com
March 30, 2025
This brochure provides information about the qualifications and business
practices of Evermont Wealth. Being registered as a registered investment
adviser does not imply a certain level of skill or training. If you have any
questions about the contents of this brochure, please contact us at 909-296-7977.
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.
Office Address: 8885
Haven Avenue #170
Rancho Cucamonga,
CA 91730
Additional information about Evermont Wealth (CRD #168581) is available
on the
Item 2: Material Changes
Material Changes since the Last Update
There are no material changes to disclose since the last annual filing of this brochure on March 29, 2024.
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by
telephone at 909-296-7977 or by email at brent@evermont.com.
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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 ...................................................................................................................................4
Item 5: Fees and Compensation ........................................................................................................................10
Item 6: Performance-Based Fees and Side-by-Side Management .................................................................15
Item 7: Types of Clients .....................................................................................................................................15
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ..........................................................15
Item 9: Disciplinary Information ......................................................................................................................19
Item 10: Other Financial Industry Activities and Affiliations .......................................................................20
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............20
Item 12: Brokerage Practices ............................................................................................................................21
Item 13: Review of Accounts .............................................................................................................................22
Item 14: Client Referrals and Other Compensation .......................................................................................22
Item 15: Custody ................................................................................................................................................23
Item 16: Investment Discretion .........................................................................................................................23
Item 17: Voting Client Securities ......................................................................................................................23
Item 18: Financial Information .........................................................................................................................23
ADV 2B Individual Disclosure Brochure – Brent M. Pasqua……………………………...…………… 24
ADV 2B Individual Disclosure Brochure – Matthew R. Theal, CFP®……………………………….… 27
ADV 2B Individual Disclosure Brochure – Joshua R. Winterwysk, CFP® …………………………… 31
Privacy Policy ……………………………………………………………………………….…………… 35
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Item 4: Advisory Business
Firm Description
Evermont Wealth (“Advisor”) was founded in 2013. Brent Pasqua owns 95% of the firm and the
remaining 5% is owned by Matthew Theal. Advisor provides investment management to individuals and
pension and profit-sharing plans. Advice is provided through consultation with the Client and includes
such areas as:
• Retirement Planning
• Debt Management
• Financial Planning
• Insurance Review
• Investment Management
• Estate Planning
• Budget and Cash Flow Analysis
• Business Succession and Exit Planning
• Tax Planning
• Social Security Maximization
An evaluation of each Client's initial situation is provided to the Client, often in the form of a net worth
statement, risk analysis or similar document. Periodic reviews are also communicated to provide
reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not
necessarily communicated to the Client unless immediate changes are recommended.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) should be engaged directly by the
Client on an as-needed basis.
Types of Advisory Services
ASSET MANAGEMENT
Evermont Wealth offers discretionary direct asset management services to advisory Clients. Evermont
Wealth offers Clients ongoing portfolio management services through determining individual investment
goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset
allocation, portfolio monitoring and the overall investment program will be based on the above factors.
The Client will grant Evermont Wealth discretionary authority to execute selected investment program
transactions as stated within the Investment Advisory Agreement.
Advisor will utilize The Betterment Institutional (Betterment) platform. On this platform, Advisor has
the discretion to delegate the management of all or part of the Assets to one or more independent
investment managers or independent investment management programs (“Independent Managers”). To
the extent utilized, Independent Managers will have limited power-of- attorney and trading authority over
those assets Advisor directs to them for management. Advisor will supervise the Independent Managers
and monitor and review asset allocation and asset performance. Advisor may terminate or change
Independent Managers when, in Advisor’s sole discretion, Advisor believes such termination or changes
are in your best interest.
Charles Schwab & Company (CS&Co.) - Managed Account Platforms
Evermont Wealth is independent of and not owned by, affiliated with, or sponsored or supervised by
CS&Co., or their affiliates (together, "Schwab"). Evermont Wealth is the client's investment advisor and
responsible for determining the appropriateness of the Program for the client, choosing a suitable
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investment strategy and portfolio for the client's investment needs and goals, and managing that portfolio
on an ongoing basis.
Retirement Plan Rollovers
An employee generally has four (4) options for their retirement plan when they leave an employer:
1. Leave the money in his/her former employer’s plan, if permitted
2. Rollover the assets to his/her new employer’s plan if one is available and permitted
3. Rollover to an Individual Retirement Account (IRA), or
4. Cash out the account value, which has significant tax considerations
Each of these options has advantages and disadvantages and before making a change we encourage you to
speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an
IRA for us to manage here are a few points to consider before you do so:
• Determine whether the investment options in your employer's retirement plan address your needs
or whether you might want to consider other types of investments.
• Employer retirement plans generally have a more limited investment menu than IRAs.
• Employer retirement plans may have unique investment options not available to the public such as
employer securities, or previously closed funds.
• Your current plan may have lower fees than our fees.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-
based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of
interest because Investment Advisor Representatives have an incentive to recommend a rollover to you
for the purpose of generating fee-based compensation rather than solely based on your needs. You are
under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete
the rollover, you are under no obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change jobs.
In determining whether to complete the rollover to an IRA, and to the extent the following options are
available, you should consider the costs and benefits of each. An employee will typically be investing
only in mutual funds, you should understand the cost structure of the share classes, available in your
employer's retirement plan and how the costs of those share classes compare with those available in an
IRA. Clients should understand the various products and services they might take advantage of at an IRA
provider and the potential costs of those products and services.
• Our strategy may have higher risk than the option(s) provided to you in your plan.
• Your current plan may also offer financial advice.
•
If you keep your assets titled in a 401k or retirement account, participants could potentially delay
their required minimum distribution beyond age.
• A 401(k) may offer more liability protection than a rollover IRA; each state may vary.
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• Participants may be able to take out a loan on your 401k, but not from an IRA.
•
IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and
may also be subject to a 10% early distribution penalty unless they qualify for an exception such as
disability, higher education expenses or the purchase of a home.
•
If company stock is owned in a plan, participants may be able to liquidate those shares at a lower
capital gains tax rate.
• Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been
generally protected from creditors in bankruptcies. However, there can be some exceptions to the general
rules so you should consult with an attorney if you are concerned about protecting your retirement plan
assets from creditors.
It is important to understand the differences between these types of accounts and to decide whether a
rollover is the best option. Prior to proceeding, if you have questions contact your Investment Adviser
Representative, or call our main number as listed on the cover page of this brochure.
When Evermont Wealth provides 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 law s
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.
Evermont Wealth also provides educational services to retirement plan participants with assets that could
potentially be rolled-over to an IRA advisory account. Education is based on a particular Client’s financial
circumstances and best interests. Again, Advisor has an incentive to recommend such a rollover based on
the compensation received, which is mitigated by the fiduciary duty to act in a Client’s best interest and
acting accordingly.
Retirement Plan Consulting
Investment advisor representatives of Evermont Wealth may assist clients that are trustees or other
fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or advisory services.
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Investment advisor representatives may perform one or more of the following services:
• Investment Policy Statement. Advisor Representative will assist the Plan in the preparation or review
of an investment policy statement (“IPS”) for the plan based upon consultation with Client
• Ongoing Investment Recommendations. Advisor Representative will recommend, for consideration
and selection by Client, specific investments to be held by the Plan or, in the case of a participant-
directed defined contribution plan, to be made available as investment options under the Plan. Advisor
Representative will recommend for consideration and selection by Client, investment replacements if
an existing investment is determined by the Client to no longer be suitable as an investment option.
• Ongoing Investment Monitoring. Advisor Representative will perform ongoing monitoring of
investment options in relation to the criteria provided by the Client to the Advisor Representative.
• Qualified Default Investment Alternative Assistance. Advisor Representative may assist Client
with selecting investment products or managed accounts offered by third parties in connection with
the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA (for plans
subject to ERISA).
• Non-Discretionary Model Portfolios. Advisor Representative will recommend, for consideration and
approval by Client: 1. asset allocation target-date or risk-based model portfolios for the Plan to make
available to Plan participants and 2. funds from the line-up of investment options chosen by the Client
to include in such model portfolios.
• Performance Reports. Advisor Representative will prepare periodic reports reviewing the
performance of all Plan investment options, as well as comparing the performance thereof to
benchmarks with Client. The information used to generate the reports will be derived directly from
information such as statements provided by Client, investment providers and/or third parties.
• Service Provider Liaison. Advisor Representative shall assist the Plan by acting as a liaison between
the Plan and service providers, product sponsors or vendors. In such cases, Advisor Representative
shall act only in accordance with instructions from Client or Plan administration matters and shall not
exercise judgement or discretion on such matters.
• Education Services to Plan Committee. Advisors Representative will provide training for the
members of the Plan Committee with regard to their service on the Committee, including education
and consulting with respect to fiduciary responsibilities.
• Participant Education. Advisors Representative will design an education plan and that may include
information about the investment options under the Plan (e.g., investment objectives, risk/return
characteristics and historical performance, investment concepts *e.g. diversification, asset classes and
risk and return), the determination of investment time horizons and the assessment of risk tolerance.
Such information shall not include specific investment advice about investment options under the Plan
as being appropriate for a particular participant.
• Participant Enrollment. Advisors Representative will assist Client in enrolling participants in the
Plan, including conducting an agreed-upon number of enrollment meetings. As part of such meetings,
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Advisor Representative will provide participants with information about the Plan, which may include
information on the benefits of Plan participation, the benefits of increasing Plan contributions, the
impact of preretirement withdrawals on retirement income, the terms of the Plan and the operation of
the Plan.
• Plan Search Support/Vendor Analysis. Advisor Representatives will assist with the preparation,
distribution, and evaluation of Requests for Proposal, finalist interviews and conversion support.
• Benchmarking Services. Advisor Representative will provide Client with comparisons of Plan data
(e.g., regarding fees and services and participant enrollment and contributions) to data from the Plan’s
prior years and/or a benchmark group of similar plans.
• Assistance Identifying Plan Fees. Advisor Representative will assist Client in identifying the fees
and other costs borne by the Plan, as specified by Client, for investment management, recordkeeping,
participant education, participant communication and/or other services provided with respect to the
Plan.
As part of such meetings, Investment Advisor Representatives can provide participants with information about
the Plan, which includes information on the benefits of participation, the benefits of increasing contributions,
the impact of pre-retirement withdrawals on retirement income, the terms of the Plan and the operation of the
Plan. If the Plan makes available publicly traded employer stock (“company stock”) as an investment option
under the Plan, investment advisor representatives do not provide investment advice regarding company stock
and are not responsible for the decision to offer company stock as an investment option. In addition, if
participants in the Plan may invest the assets in their accounts through individual brokerage accounts, a mutual
fund window, or other similar arrangement, or may obtain participant loans, investment advisor representatives
do not provide any individualized advice or recommendations to the participants regarding these decisions.
Investment Advisor Representatives can provide individualized investment advice to Plan participants
regarding their Plan and/or other assets by separate agreement.
Artificial Intelligence
Artificial Intelligence (AI) is the simulation of human intelligence in machines designed to think and learn like
humans. AI encompasses a range of technologies that enable systems to perform tasks such as recognizing
speech, making decisions, and understanding complex ideas. AI tools can be used to enhance our services,
improve operational efficiency, and deliver overall better outcomes. By integrating AI into our processes, we
aim to stay at the forefront of technological innovation while maintaining a strong commitment to ethical
practices and data privacy. Advisor utilizes AI for real-time note-taking to enhance accuracy, efficiency, and
productivity. Our AI tool transcribes spoken content, generates summaries, and identifies key takeaways.
Participants are informed of AI usage and have the right to opt out of AI-generated note-taking. Should a client
have any questions or concerns, please contact us at our email address, phone number, or website. In addition
to real-time note-taking, Advisor uses AI to gather general insights and manage projects. By analyzing large
volumes of data and identifying patterns, AI helps us develop preliminary concepts, streamline research
processes, and enhance decision-making. This allows Advisor to focus on more complex and creative aspects
of our work, ultimately delivering more comprehensive and effective solutions for our clients. We ensure that
any use of AI is supervised and conducted with transparency, maintaining the highest standards of data privacy
and ethical practices.
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While artificial intelligence technologies aim to enhance efficiency, accuracy, and investment outcomes, their
use introduces specific risks that clients should consider. Using AI in decision-making can result in overreliance
on technology, potentially reducing human oversight. Unexpected system malfunctions, algorithmic errors, or
misinterpretations of AI-generated insights could adversely affect investment outcomes. Advisor requires
human oversight of AI tools. Clients are encouraged to discuss any concerns about AI-related risks.
FINANCIAL PLANNING AND CONSULTING
Advisor offers financial planning and consulting services to help Clients with most aspects of their
investments and financial condition. Consulting services will continue from year to year unless cancelled in
writing by either party. Client may terminate the Agreement within five (5) days without obligation.
Financial planning services are available as a one-time written plan where the engagement terminates upon
delivery of the plan or an as an on-going consulting relationship that can include one or more of the following
areas:
Ongoing access to newsletters, webinars, education and networking events
•
Initial meeting (in person or virtual) – up to two hours
• Follow up meeting to deliver and discuss initial recommendations – up to 90 minutes
• Written financial planning recommendations (paper and/or electronic) – updated annually
• Regular accountability check-in emails to help Client stay on track available upon request
• Phone or email access to answer questions
• Engagements are considered terminated upon plan delivery.
The scope of work and fee for an Advisory Service Agreement is provided to the Client in writing prior to the
start of the relationship.
The Client is under no obligation to act upon the investment advisor’s recommendation. If the Client elects to
act on any of the recommendations, the Client is under no obligation to effect the transaction through
Advisor. One time or initial consultations will be completed and delivered inside of thirty days. Clients may
terminate advisory services with thirty (30) days written notice.
VARIABLE AND FIXED ANNUITY AND VARIABLE LIFE MANAGEMENT
Advisor offers discretionary direct asset management services to advisory Clients on their annuities and
variable life products. Advisor will work with individuals to assemble an appropriate portfolio of
investment options as provided through the insurance company that services variable annuity investment.
The accounts will be monitored on an annual basis.
SUB-ADVISORY SERVICES
Advisor provides customized investment advisory solutions to third party unaffiliated investment
advisers. Advisor works with each third-party unaffiliated investment adviser to identify appropriate
investment mandates as well as risk tolerance in order to create a portfolio allocation or set of allocations
using investment strategies. Advisor will have responsibility for:
• Allocating Client assets consistent investment objective on a discretionary basis, and
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• Ensuring that any restrictions placed on an account are consistent with the Model before
allocating assets.
Advisor will provide a questionnaire or similar tools to third party unaffiliated investment advisers in
order to determine the Client’s risk profile, investment horizon, financial circumstances and investment
objectives.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment strategies are
created that reflect the stated goals and objective. Clients may impose restrictions on investing in certain
securities or types of securities.
Agreements may not be assigned without written Client consent.
Wrap Fee Programs
Advisor does not sponsor a wrap program.
Client Assets under Management
As December 31, 2024, Advisor had approximately $245,309,971 of Client assets under management on a
discretionary basis and $32,372,975 of Client assets under management on a non-discretionary basis.
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
Advisor offers discretionary asset management services to advisory Clients. The fees for these services will
be based on a percentage of assets under management and generally follow as below:
Assets Under Management
Maximum Annual Fee
Maximum Quarterly Fee
First $1,000,000
1.00%
Next $1,000,000
0.90%
Next $1,000,000
0.80%
Next $1,000,000
0.70%
.250
%
.225
%
.200
%
.175
%
.150
%
Next $1,000,000
Above $5,000,000
0.60%
Determined by circumstance
Determined by circumstance
Advisor will also charge an additional $10 fee per quarter, per account, to offset charges for performance
reports and other third-party software costs.
Accounts within the same household are generally combined for a reduced fee. Fees are billed quarterly in
arrears based on average daily balance of the previous quarter. Each time a fee is deducted the firm will
concurrently send the qualified custodian and Client an invoice itemizing the fee that includes the formula
used to calculate the fee, the amount of assets under managements the fee is based on, and the time period
covered by the fee.
Clients may terminate their account within five (5) business days of signing the Investment Advisory
Agreement for a full refund. Clients may terminate advisory services with thirty (30) days written notice.
Advisor will be entitled to a pro rata fee for the days service was provided in the final quarter. Client shall
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be given thirty (30) days prior written notice of any increase in fees, and Client will acknowledge, in
writing, any agreement of increase in said fees.
Evermont Wealth (Betterment)
MTG, LLC dba Betterment Securities (“Betterment Securities”), is an unaffiliated FINRA/SIPC
member broker/dealer. When utilizing the Betterment Investment platform, Advisor’s fee will be based on
a negotiable 1% annual fee in all accounts. In addition to Advisor’s annual fee, Betterment’s fee is .25%
annually.
• Betterment Securities does not charge separately for custody/brokerage services but is
compensated as part of the Betterment for Advisors platform fee charged as a percentage of assets
that includes custody, brokerage, and sub-advisory services.
• Betterment Securities serves as broker-dealer to Betterment for Advisors, an investment and advice
platform serving independent investment advisory firms like Evermont Wealth (“Betterment for
Advisors”).
• Betterment for Advisors makes available various support services which may not be available to
Betterment’s retail customers to help Evermont Wealth manage or administer accounts, while
others help us manage and grow our business.
• Betterment for Advisors’ support services are generally available on an unsolicited basis and at no
charge to Evermont Wealth, including:
o Access to a globally diversified, low-cost portfolio of ETFs, execution of securities
transactions, and custody of client assets through Betterment Securities.
o A series of model portfolios created by third-party providers are also available on the
platform.
o Betterment for Advisors provides service to Evermont Wealth to help the firm manage and
administer clients’ accounts, such as software and technology, back-office functions,
recordkeeping, and reporting, access to client account data as well as pricing and other
market data.
• Betterment for Advisors offers other services intended to help Evermont Wealth with business
development efforts and operational management.
o Technology Consulting
o Business Consulting
o Industry publications
o Practice management
o Business succession.
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The availability of these services from Betterment for Advisors benefits Evermont Wealth because
the firm does not have to produce or purchase them. These services may be contingent upon
committing a certain amount of business to Betterment Securities in assets in custody. The receipt
of such services creates a conflict of interest that is mitigated by the firm’s fiduciary duty to act in
a client’s best interest.
Fees will be automatically deducted from Client’s account. Betterment will make quarterly adjustments for
deposits and withdrawals in Client accounts. As part of this process, you understand and acknowledge the
following:
• Betterment Securities as the custodian, sends statements at least quarterly to Clients showing all
disbursements for their account, including the amount of the advisory fees paid to our firm;
• The Client has provided authorization permitting fees to be directly paid by these terms;
• Betterment calculates the advisory fees and deducts them from the Client’s account. The fees are
based on a Client’s average daily balance of their entire account. Client will see the total fee (to
include the Betterment Institutional platform fee of 25 basis points in addition to the annual
percentage of assets charged by Advisor of no more than1.00% annually.)
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets. The initial fee will be based on the
market value of the Plan assets as calculated by the custodian or record keeper of the Included Assets on the
last business day of the initial fee period.
ERISA Accounts
Assets Under Management
Maximum Annual Fee
Maximum Quarterly Fee
First $1,000,000
Next $1,000,000
Next $1,000,000
Next $1,000,000
Next $1,000,000
0.50
%
0.40
%
0.30
%
0.20
%
0.10
%
.125
%
.100
%
.075
%
.050
%
.025
%
Above $5,000,000
Determined by circumstance
Determined by circumstance
If the services provided start any time other than the first day of a quarter, the fee will be prorated based on
the number of days remaining in the initial fee period. Thereafter, the fee will be based on the market value
of the Plan assets on the last business day of the fee period (without adjustments for anticipated withdrawals
by Plan participants or other anticipated or scheduled transfers or distribution of assets) and will be due the
following business day. If this Agreement is terminated prior to the end of the fee period, the Advisor shall
be entitled to a prorated fee based on the number of days during the fee period services were provided. Any
unearned fees shall be refunded to the Plan or Plan Sponsor.
The compensation of Advisor for the services is described in detail in Schedule A of the ERISA Plan
Agreement. The Plan is obligated to pay the fees; however the Plan Sponsor may elect to pay the fees. The
Advisor does not reasonably expect to receive any additional compensation, directly or indirectly, for its
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services under this Agreement. If additional compensation is received, the Advisor will disclose this
compensation, the services rendered, and the payer of compensation. The Advisor will offset the compensation
against the fees agreed upon under this Agreement.
FINANCIAL PLANNING AND CONSULTING
Ongoing Consulting Services
This service is offered for a negotiable annual flat fee charged based on the scope of work as documented
on the financial planning agreement. Fees are based on the unique Client fees and complexity of the services
required. Prior to the planning process the Client will be provided an estimated fee. Client will pay the initial
fee upon engagement and the monthly fee within 10 days of the receipt of invoice or on the first of the
month depending on which method of payment the Client chooses. Client may cancel within five (5) business
days of signing Agreement with no obligation. If the Client cancels after five (5) business days, any unpaid
earned fees will be due to Advisor. Advisor reserves the right to waive all applicable financial planning and
consulting fees if the Client implements the recommendations with Advisor.
Fee Arrangement for Ongoing Consulting
Clients will select a payment method on the Financial Planning and Consulting Agreement.
• Check
• Credit Card
• Electronic Bank Draft
• Deducted from an Account Managed by Advisor
Written Financial Plan (One-Time)
This service is available within a range based on the scope and complexity of the planning as well as the level
of expertise and amount of time required. Fees can be negotiated outside of the general range as circumstances
warrant.
Under 50
Over 50
Quick Start
Hourly
Minimum of $3,500 Minimum of $4,500 Minimum of $1,850
$250 an Hour
• The minimum fee can be adjusted to account for the scope and complexity as well
as the amount of time and expertise required.
Clients will be provided an estimated fee prior to the Client engaging in services. Client will pay the fee due
upon delivery of the completed plan. Services are completed and delivered inside of thirty days. Client may
cancel within five (5) business days of signing Agreement with no obligation. If the Client cancels after five (5)
business days, any unpaid earned fees will be due to Advisor. Advisor reserves the right to waive all applicable
financial planning and consulting fees if the Client implements the recommendations with Advisor.
VARIABLE AND FIXED ANNUITY AND VARIABLE LIFE MANAGEMENT
Fees for portfolios managed by Advisor for Annuities are based on a percentage of Assets Under Management.
The fee is 1%.
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Advisor fees are billed quarterly in advance based on the amount of assets managed as of the close of business
on the last business day of the previous quarter. Quarterly advisory fees will be paid in the following ways:
• deducting from Client’s account For Clients under the age of 59 ½
• deducted from a Client’s account held with Advisor
• payable within 10 days of invoice presentation
SUBADVISORY SERVICES FEES
An annualized fee of 0.325% will be charged on the total assets under management that the third-party
unaffiliated investment adviser brings to Advisor. Advisor is compensated directly by the third-party
unaffiliated investment adviser with a portion of their investment management fee, as per the duly executed
Sub-Advisory services agreement. Third party unaffiliated investment adviser who engage Advisor as a Sub-
advisor shall be responsible for billing their Clients and collecting all fees.
Clients may terminate their account within five (5) business days of signing the Investment Advisory
Agreement with no obligation and without penalty. Clients may terminate advisory services with thirty (30)
days written notice. For accounts closed mid-billing period, Advisor will be entitled to a pro rata fee for the
days service was provided in the final period. Client shall be given thirty (30) days prior written notice of any
increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in
said fees occurs.
Client Payment of Fees
Investment management fees are billed quarterly in arrears, meaning we bill you at the end of the quarter.
Fees are usually deducted from a designated Client account to facilitate billing. The Client must consent in
advance to direct debiting of their investment account. Financial Planning Fees are due upon delivery of the
completed plan. Ongoing monthly fees are due at the beginning of each month.
Additional Client Fees Charged
Custodians charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-
traded funds. These charges may include Mutual Fund transactions fees, postage and handling and
miscellaneous fees (fee levied to recover costs associated with fees assessed by self- regulatory
organizations). The selection of the security is more important than the nominal fee that the custodian charges
to buy or sell the security.
Mutual Fund Share Class Disclosures
Certain mutual fund share classes charge a 12b-1 fee that generally amounts to an additional .25% expense ratio
or more. The purpose of 12b-1 fees, as approved by the SEC, are to cover marketing expenses and shareholder
services such as support services and “other expenses” such as legal, accounting and the administrative functions
of the custodian. When selecting a mutual fund, Investment Advisor Representatives have a fiduciary duty to
choose the share class that helps manage the overall fee structure of the account. The entire fee structure includes
such fees as the asset management fee, the expense ratio and ticket charges.
• Mutual funds typically offer multiple share classes, including lower-cost share classes that do not
charge 12b-1 fees and are therefore usually less expensive.
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•
Investment Advisor Representatives will consider investing client funds in 12b-1 fee-paying share
classes even when a lower-cost share class is available as appropriate to account for the overall fee
structure and tax considerations as well as attributes of a fund not available for lesser fees.
• Advisor, in its sole discretion, may waive its minimum fee and/or charge a lesser investment advisory
fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning
capacity, anticipated future additional assets, dollar amounts of assets to be managed, related
accounts, account composition, negotiations with Clients, etc.).
For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
Ongoing monthly fees are due either at the beginning of each month or within 10 days of invoice receipt
depending on the payment option the Client selects.
External Compensation for the Sale of Securities to Clients
Advisor does not receive any external compensation for the sale of securities to Clients, nor do any of the
investment advisor representatives of Advisor.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Evermont Wealth does not charge performance-based fees for its investment advisory services. The fees
charged by the firm are as described in “Item 5 – Fees and Compensation” above and are not based upon the
capital appreciation of the funds or securities held by any Client. Evermont Wealth does not manage any
proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund). It has no
financial incentive to recommend or implement any particular investment options to its Clients.
Item 7 – Types of Clients
Evermont Wealth offers investment advisory services primarily to individuals. The number of each type of
Client is provided on Form ADV Part 1A. These numbers change over time and are updated at least annually.
There is no minimum account balance required to open or maintain an account.
Account Minimums
Advisor does not require a minimum to open an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Advisor utilizes fundamental analysis when managing Client’s assets. Investing in securities involves risk of
loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns.
• Fundamental Analysis - Fundamental analysis utilizes economic and business indicators as investment
selection criteria. The criteria generally consist of ratios and trends that can indicate the overall strength
and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria
to show that they are a strong investment with a value discounted by the market. While this type of
analysis helps the firm in evaluating a potential investment, it does not guarantee that the investment will
15
increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose
value and may have negative investment performance. The firm monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate.
Risk of Loss
Investing in securities involves the risk of loss, including the entire principal amount. Securities fluctuate in
value and can lose value. Clients should be prepared to bear the potential risk of loss. The firm will assist
Clients in determining an appropriate strategy based on their tolerance for risk and other factors. However, there
is no guarantee that a Client will meet their investment goals. While the methods of analysis help the firm in
evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets
meeting the investment criteria utilized in these methods of analysis may lose value and may have negative
investment performance. The firm monitors these economic indicators to determine if adjustments to strategic
allocations are appropriate. The specific risks associated with a strategy are provided to each Client in advance
of investing. The firm will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Below is a list of risks that should be considered before investing that can apply to the
investment account. Additional unforeseen risks may affect, but clients are encouraged to at least consider the
following risks:
• Business Risk – The measure of risk associated with a particular security. It is also known as
unsystematic risk and refers to the risk associated with a specific issuer of a security. Generally
speaking, all businesses in the same industry have similar types of business risk. More specifically,
business risk refers to the possibility that the issuer of a particular company stock or a bond may go
bankrupt or be unable to pay the interest or principal in the case of bonds.
• Call Risk – The risk specific to bond issues and refers to the possibility that a debt security will be called
before maturity. Call risk usually goes hand in hand with reinvestment risk because the bondholder must
find an investment that provides the same level of income for equal risk. Call risk is most prevalent when
interest rates are falling, as companies trying to save money will usually redeem bond issues with higher
coupons and replace them on the bond market with issues with lower interest rates.
• Company-Specific Risk – A risk specific to a company’s operations, executive decisions and reputation,
which is difficult to quantify.
• Complex Products – Complex Products are complicated instruments that should only be used by
sophisticated investors who fully understand the terms, investment strategy and risks associated with
the funds. In particular, clients should be aware of certain specific risks involved in trading Complex
Products. These risks include, but are not limited to:
o Seek Daily Target Returns: Most Complex Products "reset" daily, meaning that they are
designed to achieve their stated objectives on a daily basis. Due to the effect of compounding,
the return for investors who invest for a period longer than one trading day can vary
significantly from the stated goal as well as the target benchmark's performance. This is
especially true in very volatile markets or if a Complex Product is tracking a very volatile
underlying index. Investments in any Complex Product must be actively monitored daily and
are typically not appropriate for a buy-and-hold strategy.
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o Higher Operating Expenses and Fees: Investors should be aware that these Complex
Products typically rebalance their portfolios frequently, often daily, to compensate for
anticipated changes in overall market conditions. For example, volatility-linked ETPs will
rebalance their exposure to futures of different maturities to maintain the targeted maturity.
This rebalancing can result in frequent trading and increased portfolio turnover. These
Complex Products will, therefore, generally have higher operating expenses and investment
management fees than other funds or products.
o Tax Treatment May Vary: In many cases, Complex Products may generate their returns
through the use of derivative instruments. Because derivatives are taxed differently from equity
or fixed-income securities, investors should be aware that these Complex Products may not
have the same tax efficiencies as other funds or products.
• Concentration Risk – Concentrated portfolios are an aggressive and highly volatile approach to
trading and investing and should be viewed as complementary to a stable, highly predictable
investment approach. Concentrated portfolios hold fewer different stocks than a diversified portfolio
and are much more likely to experience sudden dramatic price swings. Also, the rise or drop in price
of any given holding in the portfolio is expected to have a more significant impact on portfolio
performance, than a more broadly diversified portfolio.
• Credit Risk – The risk that an investor could lose money if the issuer or guarantor of a fixed income
security is unable or unwilling to meet its financial obligations.
• Currency/Exchange Rate Risk – The risk of a change in the price of one currency against another.
• Force Majeure – A natural and unavoidable catastrophe that interrupts the expected course of events,
market structure and access to funds.
• Interest Rate Risk – The risk that fixed-income securities will decline in value because of an increase in
interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in
interest rates than a bond or bond fund with a shorter duration.
• Inflationary Risk – The risk that future inflation will cause the purchasing power of cash flow from an
investment to decline.
• Inverse Funds – Inverse mutual funds and ETFs, which are sometimes referred to as "short" funds,
seek to provide the opposite of the single-day performance of the index or benchmark they track.
Inverse funds are often marketed as a way to profit from, or hedge exposure to, downward moving
markets. Some inverse funds also use leverage, such that they seek to achieve a return that is a
multiple of the opposite performance of the underlying index or benchmark (i.e., -200%, -300%). In
addition to leverage, these funds may also use derivative instruments to accomplish their objectives.
As such, inverse funds are volatile and provide the potential for significant losses.
• Legislative Risk – The risk of a legislative ruling resulting in adverse consequences.
• Liquidity Risk – The possibility that an investor may not be able to buy or sell an investment as and when
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desired or in sufficient quantities because opportunities are limited.
• Market Risk – The risk that the value of securities may go up or down, sometimes rapidly or
unpredictably, due to factors affecting securities markets generally or particular industries. Market
risk is a risk that will affect all securities in the same manner caused by some factor that cannot be
controlled by diversification.
• Pandemic Risk – Large-scale outbreaks of infectious disease that can greatly increase morbidity and
mortality over a wide geographic area, crossing international boundaries, and causing significant
economic, social, and political disruption.
• Reinvestment Risk – The risk that falling interest rates will lead to a decline in cash flow from an
investment when its principal and interest payments are reinvested at lower rates.
• Social/Political Risk – The possibility of nationalization, unfavorable government action or social changes
resulting in a loss of value.
• Taxability Risk – The risk that a security that was issued with tax-exempt status could potentially lose
that status before maturity. Since municipal bonds carry a lower interest rate than fully taxable bonds, the
bondholders would end up with a lower after-tax yield than initially planned.
• Terrorism Risk – An act of terror or calculated use of violence against the country, market structure
or individuals.
• Volatility-Linked Products – Volatility-linked ETPs are generally designed to track the Chicago
Board Options Exchange Volatility Index (VIX) futures. The VIX is a measure of the expected
volatility of the S&P 500 index as measured by the implied volatility of options on that index.
Volatility ETPs gain exposure to market volatility through futures or options contracts on the VIX.
Volatility-linked ETPs that seek to maintain a continuous, targeted maturity exposure to VIX futures
will either track or hold VIX futures contracts on a rolling basis. They will sell shorter-term contracts
or contracts about to expire with contracts that have more distant or deferred maturity dates to
maintain the desired exposure. The performance of volatility-linked ETPs can be significantly
different than the performance of the VIX and the actual realized volatility of the S&P 500 Index. VIX
futures contracts are among the most volatile segments of all futures markets. Volatility-linked ETPs
may be subject to extreme volatility and higher risk of loss than other traditional ETFs.
• Artificial Intelligence – Advisor utilizes Artificial Intelligence (AI) and/or Machine Learning (ML)
technologies in certain aspects of its advisory services. While these technologies aim to enhance
efficiency, accuracy, and investment outcomes, their use introduces specific risks that clients should
consider. The use of AI in decision-making can result in overreliance on technology, potentially
reducing human oversight. Unexpected system malfunctions, algorithmic errors, or misinterpretations
of AI-generated insights could adversely affect investment outcomes. Advisor requires human
oversight of AI tools. Clients are encouraged to discuss any concerns about AI-related risks.
The firm’s methods of analysis and investment strategies do not represent any significant or unusual risks;
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however, all strategies have inherent risks and performance limitations. When creating a financial plan, Advisor
utilizes fundamental analysis to provide review of insurance policies for economic value and income
replacement. Technical analysis is used to review mutual funds and individual stocks. The main sources of
information include y-charts, Client documents such as tax returns and insurance policies.
In developing a financial plan for a Client, Advisor’s analysis may include cash flow analysis, investment
planning, risk management, tax planning and estate planning. Based on the information gathered, a detailed
strategy is tailored to the Client’s specific situation. The main sources of information include financial
newspapers and magazines, annual reports, prospectuses, and filings with the Securities and Exchange
Commission.
Investment Strategy
The investment strategy for a specific Client is based upon the objectives stated by the Client during
consultations. The Client may change these objectives at any time. Each Client executes an Investment Policy
Statement or Risk Tolerance that documents their objectives and their desired investment strategy.
Investment Strategies
An investment strategy is what guides an investor's decisions based on goals, risk tolerance, and future needs
for capital. Some investment strategies seek rapid growth where an investor focuses on capital appreciation, or
they can follow a low-risk strategy where the focus is on wealth protection.
• Income with Capital Preservation. A conservative investment strategy with an objective of long-
term accumulation. Emphasis is placed on generating current income with minimal risk of capital
loss. A low-risk investment strategy generally results in reduced potential for overall return.
• Income with Moderate Growth. This investment objective emphasizes the generation of current
income with a secondary focus on moderate capital growth.
• Growth with Income. This investment objective emphasizes modest capital growth with some focus
on the generation of current income.
• Growth. This investment objective emphasizes achieving high long-term growth and capital
appreciation. There is little focus on the generation of current income.
• Aggressive Growth. This investment objective emphasizes aggressive growth and maximum capital
appreciation, with no focus on the generation of current income. This objective has a very high level of
risk and is for investors with a longer time horizon.
Other strategies may include long-term purchases, short-term purchases, trading, and option writing (including
covered options, uncovered options or spreading strategies).
Item 9: Disciplinary Information
Criminal or Civil Actions
The firm and its management have not been involved in any criminal or civil action required to be reported.
Administrative Enforcement Proceedings
The firm and its management have not been involved in administrative enforcement proceedings required to be
reported.
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Self-Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in legal or disciplinary events related to past or present
investment Clients required to be reported.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Advisor is not registered as a broker-dealer and no affiliates are registered representatives of a broker-dealer.
Futures or Commodity Registration
Neither Advisor nor its employees are registered or has an application pending to register as a futures
commission merchant, commodity pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Advisor does not have any material relationships or conflicts of interest to disclose.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
Advisor does not solicit the services of Third-Party Money Managers to manage Client accounts.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics Description
The employees of Advisor have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth
standards of conduct expected of Advisor employees and addresses conflicts that may arise. The Code defines
acceptable behavior for employees of Advisor. The Code reflects Advisor and its supervised persons’
responsibility to act in the best interest of their Client.
One area the Code addresses is when employees buy or sell securities for their personal accounts and how to
mitigate any conflict of interest with our Clients. We do not allow any employees to use non- public material
information for their personal profit or to use internal research for their personal benefit in conflict with the
benefit to our Clients.
Advisor’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information.
No advisory representative or other employee, officer or director of Advisor may recommend any transaction in
a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its
derivatives if the advisory representative possesses material, non-public information regarding the security.
Advisor’s Code is based on the guiding principle that the interests of the Client are our top priority. Advisor’s
officers, directors, advisors, and other employees have a fiduciary duty to our Clients and must diligently
perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our
obligation to put the Client’s interests over the interests of either employees or the company.
The Code applies to covered persons with additional requirements for “access” persons. “Access” persons are
covered persons who have access to non-public information regarding any Clients' purchase or sale of
securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved
in making securities recommendations to Clients, or who have access to such recommendations that are non-
public.
Advisor will provide a copy of the Code of Ethics to any Client or prospective Client upon request.
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Investment Recommendations Involving a Material Financial Interest and Conflict of Interest
Advisor and its employees do not recommend to Clients securities in which we have a material financial
interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
Advisor and its employees may buy or sell securities that are also held by Clients. In order to mitigate
conflicts of interest such as front running, employees are required to disclose all reportable securities
transactions as well as provide Advisor with copies of their brokerage statements.
The Chief Compliance Officer is Brent Pasqua. He reviews all employee trades each quarter. The personal
trading reviews helps mitigate that the personal trading of employees does not affect the markets and that
Clients of the firm have received preferential treatment over employee trades.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
Advisor recommend the use of a particular broker-dealer or may utilize a broker-dealer of the Client's choosing.
Advisor will select appropriate brokers based on a number of factors including but not limited to their relatively
low transaction fees and reporting ability. Advisor relies on its broker to provide its execution services at the
best prices available. Lower fees for comparable services may be available from other sources. Clients pay for
any and all custodial fees in addition to the advisory fee charged by Advisor.
Directed Brokerage
The firm does not accept directed brokerage arrangements (when a client requires that account
transactions be executed through a specific broker/dealer).
Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best
execution. The determination of what may constitute best execution and price in the execution of a
securities transaction by a broker involves a number of considerations and is subjective. Factors
affecting brokerage selection include the overall direct net economic result to the portfolios, the
efficiency with which the transaction is effected, the ability to effect the transaction where a large block
is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such
broker and the financial strength and stability of the broker. The firm does not receive any portion of the
trading fees.
Soft Dollar Arrangements
Advisor utilizes the services of custodial broker dealers. Economic benefits are received by Advisor
which would not be received if Advisor did not give investment advice to Clients. The benefits include:
A dedicated trading desk, a dedicated service group and an account services manager dedicated to
Advisor's accounts, ability to conduct "block" Client trades, electronic download of trades, balances and
positions, duplicate and batched Client statements, and the ability to have advisory fees directly
deducted from Client accounts.
A conflict of interest exists when Advisor receives soft dollars. This conflict is mitigated disclosures,
procedures, and the firm’s Fiduciary obligation to act in the best interest of his Clients and the services
received are beneficial to all Clients.
Aggregating Securities Transactions for Client Accounts
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Advisor aggregate purchases and sales and other transactions made for the account with purchases and
sales and transactions in the same securities for other Clients of Advisor. All Clients participating in the
aggregated order shall receive an average share price with all other transaction costs shared on a pro-
rated basis.
Cash Sweep Program
Investment portfolios often include a cash allocation to maintain liquidity, manage risk, and provide funds for
opportunistic investments. Cash allocations can serve as a buffer against market volatility and ensure funds are
readily available for future investment opportunities or withdrawals. Sweep programs automatically transfer
uninvested cash from a brokerage account into a money market fund or other short-term investment vehicle at
the custodian. This process is automated and occurs regularly, often at the end of each business day. While
the cash is held in the sweep account, it earns interest. This ensures that even idle cash generates some return,
albeit typically lower than other investment options. By automating cash movement, sweep programs reduce
the need for manual transfers, saving time and minimizing the risk of human error in managing cash balances.
Sweep accounts provide quick access to cash for reinvestment or withdrawals, enhancing liquidity
management within the portfolio. Minimizing manual cash management tasks reduces administrative burdens
for investors and advisors, allowing them to focus on strategic investment decisions. Sweep programs often
offer lower interest rates than short-term investments like high-yield savings accounts or CDs. This is due to
their liquidity and convenience. While convenient, the lower interest rates mean that investors can miss out on
higher returns if cash is kept in the sweep account for extended periods. The advisor uses sweep programs
strategically to manage cash flows within a portfolio, ensuring that cash is readily available for investment
opportunities without sacrificing significant returns. Sweep accounts can also be used to facilitate regular
transactions, such as automatic withdrawals for living expenses or periodic investments in other asset classes.
While sweep programs offer convenience and liquidity, they require careful consideration as part of an overall
investment strategy. Advisors and clients should weigh the benefits of liquidity and automation against the
potential for higher returns through alternative cash management strategies.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved
Account reviews are performed by Investment Advisor Representatives. Account reviews are performed more
frequently when market conditions dictate.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new
investment information, and changes in a Client's own situation.
Content of Client Provided Reports and Frequency
Clients receive account statements no less than monthly for managed accounts. Account statements are issued
by the Advisor’s custodian. Client receives confirmations of each transaction in account from Custodian and
an additional statement during any month in which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest
As disclosed under Item 12 above, Advisor may receive soft dollars from the custodian.
Advisory Firm Payments for Client Referrals
Advisor does not compensate for Client referrals.
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Item 15: Custody
Evermont Wealth does not have direct custody of client funds or securities. However, as a consequence of the
authority to make withdrawals from client accounts to pay advisory fees the firm provides the following
safeguards:
1. The firm obtains written authorization from the client to deduct advisory fees from the account held with
the qualified custodian. Advisor is deemed to have constructive custody solely because advisory fees are
directly deducted from Client’s account by the custodian on behalf of Advisor.
2. Each time a fee is directly deducted from a client account, the firm will concurrently send the qualified
custodian an invoice of the amount of the fee to be deducted from the client’s account and send the
client an invoice itemizing the fee. Itemization includes the formula used to calculate the fee, the
amount of assets under managements the fee is based on, and the time period covered by the fee.
Clients will receive statements directly from the qualified custodians at least quarterly. Clients are urged to
carefully review those statements.
Item 16: Investment Discretion
Discretionary Authority for Trading
Advisor accepts discretionary authority to manage securities accounts on behalf of Clients. Advisor has the
authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the
amount of the securities to be bought or sold. The Client will authorize Advisor discretionary authority to
execute selected investment program transactions as stated within the Investment Advisory Agreement. The
Client approves the custodian to be used and the commission rates paid to the custodian. Advisor does not
receive any portion of the transaction fees or commissions paid by the Client to the custodian on certain trades.
Item 17: Voting Client Securities
Evermont Wealth does not vote proxies on securities. Clients are expected to vote their own proxies. The Client
will receive their proxies directly from the custodian of their account or from a transfer agent.
When assistance on voting proxies is requested, Advisor will provide recommendations to the Client. If a
conflict of interest exists, it will be disclosed to the Client.
Item 18: Financial Information
Evermont Wealth LLC does not require or solicit prepayment of more than $1,200 in fees per client, six months
or more in advance. There are no financial conditions that are reasonably likely to impair the firm’s ability to
meet contractual commitments to clients.
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Item 1 – Cover Page
SUPERVISED PERSON BR OCHURE
F O R M A D V P A R T 2B
Brent Matthew Pasqua
March 30, 2025
This brochure supplement provides information about Brent Pasqua and supplements the
Evermont Wealth’s brochure. You should have received a copy of that brochure. Please contact
Brent Pasqua if you did not receive the brochure or if you have any questions about the contents
of this supplement. Additional information about Brent Pasqua (CRD #5880292) is available on
the SEC’s website at www.adviserinfo.sec.gov.
24
Office Address: 8885
Haven Avenue #170
Rancho Cucamonga,
CA 91730
Item 2 Educational Background and Business Experience
This section of the brochure supplement includes the Investment Advisor Representative’s name, age (or year
of birth), formal education after high school, and business background (including an identification of the
specific positions held) for the preceding five years.
Brent M. Pasqua
Year of Birth: 1981
Education
The following information details your Financial Advisor’s formal education. If a degree were attained, the
type of degree would be listed next to the name of the institution. If a degree is not listed, the Financial
Advisor attended the institution but did not attain a degree.
California State University, San Bernardino, CA; B.A. Business - 2004
Business Experience
The following information details your Financial Advisor’s business experience for at least the past five years.
Evermont Wealth
Managing Member / Chief Compliance Officer / Investment Advisor Representative; 07/2013 –Present
RPA Insurance Services
Insurance Agent; 12/2013 – 01/2018
Legacy Financial & Insurance Services
Insurance Agent; 03/2004 – 12/2013
Legacy Investment Services, LLC
Investment Advisor Representative; 1/2011 –12/2013
KDG Investments
Sports Management; 01/1997 – 11/2004
Item 3 Disciplinary Information
This section includes any legal or disciplinary events and material to a client's or prospective client's
evaluation of the supervised person.
There are no legal or disciplinary events required to be disclosed in response to this item. Any such
disciplinary information would be available at www.adviserinfo.sec.gov.
Item 4 Other Business Activities
This section includes any relationship between the advisory business and the supervised person’s other
financial industry activities that creates a material conflict of interest with clients and describes the nature of
the conflict and generally how it is addressed. If the supervised person is actively engaged in any investment-
related business or occupation; including if the supervised person is registered, or has an application pending
to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant
("FCM"), commodity pool operator ("CPO"), commodity trading advisor ("CTA"), or an associated person of
25
an FCM, CPO, or CTA, the business relationship, if any, between the advisory business and the other
business, is disclosed below.
Mr. Pasqua is licensed to sell insurance products for commission compensation. This represents a
conflict of interest that is mitigated by a fiduciary duty to act in a client’s best interest.
Mr. Pasqua is a 30% passive owner of Collaborative Tax Partners, LLC. Collaborative Tax Partners is a
separate legal entity that is independently managed by the majority owner who is also an Enrolled Agent
and not an Investment Advisor Representative. An enrolled agent is a person who has earned the
privilege of representing taxpayers before the Internal Revenue Service (IRS) by either passing a three-
part comprehensive IRS test covering individual and business tax returns, or through experience as a
former IRS employee. Enrolled agent status is the highest credential the IRS awards. Individuals who
obtain this elite status must adhere to ethical standards and complete 72 hours of continuing education
courses every three years.
Enrolled agents, like attorneys and certified public accountants (CPAs), have unlimited practice rights.
This means they are unrestricted as to which taxpayers they can represent, what types of tax matters they
can handle, and which IRS offices they can represent clients before.
Mr. Pasqua will introduce clients to Collaborative Tax Partners, LLC when their best interests would be
appropriately served. Mr. Pasqua is not compensated for such introductions and may introduce clients
to different companies providing similar services. While Mr. Pasqua does not receive compensation, as
an LLC member he is eligible for an equity distribution if declared, which creates a conflict of interest.
Item 5 Performance Based Fee Description
This section includes details regarding if someone who is not a client provides an economic benefit to the
supervised person for providing advisory services. For purposes of this Item, economic benefits include sales
awards and other prizes, but not the supervised person’s regular salary, if any.
Mr. Pasqua has no additional compensation to disclose for providing advisory services.
Item 6 Supervision
This section explains how Evermont Wealth supervises the supervised person, including how the advice the
supervised person provided to clients is monitored.
Since Mr. Pasqua is the 95% owner of Evermont Wealth and the Chief Compliance Officer. He is
solely responsible for all supervision and formulation and monitoring of investment advice offered to
Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual.
26
Item 1 – Cover Page
SUPERVISED PERSON BROCHURE
F O R M A D V P A R T 2B
Matthew R. Theal, CFP®
March 30, 2025
This brochure supplement provides information about Matthew Theal and supplements the
Evermont Wealth’s brochure. You should have received a copy of that brochure. Please contact
Brent Pasqua if you did not receive the brochure or if you have any questions about the contents
of this supplement. Additional information about Matthew R. Theal (CRD #6245173) is
available on the SEC’s website at www.adviserinfo.sec.gov.
27
Office Address: 8885
Haven Avenue #170
Rancho Cucamonga,
CA 91730
Item 2 Educational Background and Business Experience
This section of the brochure supplement includes the Investment Advisor Representative’s name, age (or year
of birth), formal education after high school, and business background (including an identification of the
specific positions held) for the preceding five years.
Matthew Theal
Year of Birth: 1986
Education
The following information details your Financial Advisor’s formal education. If a degree were attained, the
type of degree would be listed next to the name of the institution. If a degree is not listed, the Financial
Advisor attended the institution but did not attain a degree.
California State University Polytechnic-Pomona; Bachelor of Science - Finance; 2008
Professional Designations
The following provides information on professional designation(s) that Matthew Theal earned.
Certified Financial Planner™ - CFP®
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States
by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a
voluntary certification; no federal or state law or regulation requires financial planners to hold CFP®
certification. It is recognized in the United States and a number of other countries for its:
(1) high standard of professional education;
(2) stringent code of conduct and standards of practice; and,
(3) ethical requirements that govern professional engagements with clients.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and professional
delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited
United States college or university (or its equivalent from a foreign university). CFP Board’s financial
planning subject areas include insurance planning and risk management, employee benefits planning,
investment planning, income tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in two 3-hour sessions, includes case studies and client scenarios designed to test one’s
ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning
to real world circumstances;
Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
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Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning field;
and,
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services at a
fiduciary standard of care. This means CFP® professionals must provide financial planning
services in the best interests of their clients. CFP® professionals who fail to comply with the
above standards and requirements may be subject to CFP® Board’s enforcement process, which
could result in suspension or permanent revocation of their CFP® certification.
Business Experience
The following information details your Financial Advisor’s business experience for at least the past five years.
Evermont Wealth
Investment Advisor Representative; 08/2013 – Present
RPA Insurance Services
Insurance Agent; 04/2015 – 01/2018
Legacy Investments
Investment Analyst; 11/2012 - 08/2013
Item 3 Disciplinary Information
This section includes any legal or disciplinary events and material to a client's or prospective client's
evaluation of the supervised person.
There are no legal or disciplinary events required to be disclosed in response to this item. Any such
disciplinary information would be available at www.adviserinfo.sec.gov.
Item 4 Other Business Activities
This section includes any relationship between the advisory business and the supervised person’s other
financial industry activities that creates a material conflict of interest with clients and describes the nature of
the conflict and generally how it is addressed. If the supervised person is actively engaged in any investment-
related business or occupation; including if the supervised person is registered, or has an application pending
to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant
("FCM"), commodity pool operator ("CPO"), commodity trading advisor ("CTA"), or an associated person of
an FCM, CPO, or CTA, the business relationship, if any, between the advisory business and the other
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business, is disclosed below.
Mr. Theal is a 15% passive owner of Collaborative Tax Partners, LLC. Collaborative Tax Partners is a
separate legal entity that is independently managed by the majority owner who is also an Enrolled Agent
and not an Investment Advisor Representative. An enrolled agent is a person who has earned the
privilege of representing taxpayers before the Internal Revenue Service (IRS) by either passing a three-
part comprehensive IRS test covering individual and business tax returns, or through experience as a
former IRS employee. Enrolled agent status is the highest credential the IRS awards. Individuals who
obtain this elite status must adhere to ethical standards and complete 72 hours of continuing education
courses every three years.
Enrolled agents, like attorneys and certified public accountants (CPAs), have unlimited practice rights.
This means they are unrestricted as to which taxpayers they can represent, what types of tax matters they
can handle, and which IRS offices they can represent clients before.
Mr. Theal will introduce clients to Collaborative Tax Partners, LLC when their best interests would be
appropriately served. Mr. Theal is not compensated for such introductions and may introduce clients to
different companies providing similar services. While Mr. Theal does not receive compensation, as an
LLC member he is eligible for an equity distribution if declared, which creates a conflict of interest.
Item 5 Performance Based Fee Description
This section includes details regarding if someone who is not a client provides an economic benefit to the
supervised person for providing advisory services. For purposes of this Item, economic benefits include sales
awards and other prizes, but not the supervised person’s regular salary, if any.
Mr. Theal has no additional compensation to disclose for providing advisory services.
Item 6 Supervision
This section explains how Evermont Wealth supervises the supervised person, including how the advice the
supervised person provided to clients is monitored.
Mr. Theal is supervised by Brent Pasqua, Chief Compliance Officer. He reviews Matthew’s work
through client account reviews, quarterly personal transaction reports as well as face-to-face and phone
interactions.
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Item 1 – Cover Page
SUPERVISED PERSON BROCHURE
F O R M A D V P A R T 2B
Joshua R. Winterswyk
March 30, 2025
This brochure supplement provides information about Joshua Winterswyk and supplements the
Evermont Wealth’s brochure. You should have received a copy of that brochure. Please contact
Brent Pasqua if you did not receive the brochure or if you have any questions about the contents
of this supplement. Additional information about Joshua R. Winterswyk (CRD #6573201)is
available on the SEC’s website at www.adviserinfo.sec.gov.
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Office Address: 8885
Haven Avenue #170
Rancho Cucamonga,
CA 91730
Item 2 Educational Background and Business Experience
This section of the brochure supplement includes the Investment Advisor Representative’s name, age (or year
of birth), formal education after high school, and business background (including an identification of the
specific positions held) for the preceding five years.
Joshua R. Winterswyk
Year of Birth: 1987
Education
The following information details your Financial Advisor’s formal education. If a degree were attained, the
type of degree would be listed next to the name of the institution. If a degree is not listed, the Financial
Advisor attended the institution but did not attain a degree.
California State University-San Bernardino; Bachelor of Arts - Finance; 2010
Chaffey College; Associate of Arts - University Studies; 2008
Professional Designations
The following provides information on professional designation(s) that Joshua Winterswyk earned.
Certified Financial Planner™ - CFP®
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States
by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a
voluntary certification; no federal or state law or regulation requires financial planners to hold CFP®
certification. It is recognized in the United States and a number of other countries for its:
(2) high standard of professional education;
(2) stringent code of conduct and standards of practice; and,
(3) ethical requirements that govern professional engagements with clients.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and professional
delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited
United States college or university (or its equivalent from a foreign university). CFP Board’s financial
planning subject areas include insurance planning and risk management, employee benefits planning,
investment planning, income tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination. The examination,
administered in two 3-hour sessions, includes case studies and client scenarios designed to test one’s
ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning
to real world circumstances;
Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
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Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements in order to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional
Conduct, to maintain competence and keep up with developments in the financial planning field;
and,
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning services at a
fiduciary standard of care. This means CFP® professionals must provide financial planning
services in the best interests of their clients. CFP® professionals who fail to comply with the
above standards and requirements may be subject to CFP® Board’s enforcement process, which
could result in suspension or permanent revocation of their CFP® certification.
Business Experience
The following information details your Financial Advisor’s business experience for at least the past five years.
Evermont Wealth
Investment Advisor Representative; 10/2015 - Present
RPA Insurance Services
Insurance Agent; 09/2015 – 01/2018
Citibank
Personal Banker; 11/2009 – 09/2015
P.F. Chang
Server; 05/2008 – 07/2010
Item 3 Disciplinary Information
This section includes any legal or disciplinary events and material to a client's or prospective client's
evaluation of the supervised person.
There are no legal or disciplinary events required to be disclosed in response to this item. Any such
disciplinary information would be available at www.adviserinfo.sec.gov.
Item 4 Other Business Activities
This section includes any relationship between the advisory business and the supervised person’s other
financial industry activities that creates a material conflict of interest with clients and describes the nature of
the conflict and generally how it is addressed. If the supervised person is actively engaged in any investment-
33
related business or occupation; including if the supervised person is registered, or has an application pending
to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant
("FCM"), commodity pool operator ("CPO"), commodity trading advisor ("CTA"), or an associated person of
an FCM, CPO, or CTA, the business relationship, if any, between the advisory business and the other
business, is disclosed below.
Mr. Winterswyk is a 15% passive owner of Collaborative Tax Partners, LLC. Collaborative Tax
Partners is a separate legal entity that is independently managed by the majority owner who is also an
Enrolled Agent and not an Investment Advisor Representative. An enrolled agent is a person who has
earned the privilege of representing taxpayers before the Internal Revenue Service (IRS) by either
passing a three-part comprehensive IRS test covering individual and business tax returns, or through
experience as a former IRS employee. Enrolled agent status is the highest credential the IRS awards.
Individuals who obtain this elite status must adhere to ethical standards and complete 72 hours of
continuing education courses every three years.
Enrolled agents, like attorneys and certified public accountants (CPAs), have unlimited practice rights.
This means they are unrestricted as to which taxpayers they can represent, what types of tax matters they
can handle, and which IRS offices they can represent clients before.
Mr. Winterswyk will introduce clients to Collaborative Tax Partners, LLC when their best interests
would be appropriately served. Mr. Winterswyk is not compensated for such introductions and may
introduce clients to different companies providing similar services. While Mr. Winterswyk does not
receive compensation, as an LLC member he is eligible for an equity distribution if declared, which
creates a conflict of interest.
Item 5 Performance Based Fee Description
This section includes details regarding if someone who is not a client provides an economic benefit to the
supervised person for providing advisory services. For purposes of this Item, economic benefits include sales
awards and other prizes, but not the supervised person’s regular salary, if any.
Mr. Winterswyk has no additional compensation to disclose for providing advisory services.
Item 6 Supervision
This section explains how Evermont Wealth supervises the supervised person, including how the advice the
supervised person provided to clients is monitored.
Mr. Winterswyk is supervised by Brent Pasqua, Chief Compliance Officer. He reviews Matthew’s work
through client account reviews, quarterly personal transaction reports as well as face-to-face and phone
interactions.
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Privacy Policy
Our Commitment to You
Evermont Wealth (“the firm”) is committed to safeguarding the use of personal information of our Clients (also
referred to as “you” and “your”) that we obtain as your Investment Advisor, as described herein our Privacy
Policy ("Policy"). Our relationship with you is our most important asset. We understand that you have entrusted
us with your private information, and we do everything that we can to maintain that trust. The firm (also referred
to as "we", "our" and "us") protects the security and confidentiality of personal information. Additionally, the
firm has implemented controls to ensure that such information is used for proper business purposes in connection
with the management or servicing of our relationship with you. Evermont Wealth does not sell your non-public
personal information to anyone. Nor do we provide such information to others except for discrete and reasonable
business purposes in connection with the servicing and management of our relationship with you, as discussed
below. Details of our approach to privacy and how your personal non-public information is collected and used is
outlined in this Policy.
What you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer-identification number
Assets and liabilities
Name, address and phone number(s)
Income and expenses
E-mail address(es)
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Account applications and forms
Other advisory agreements and legal documents
Investment suitability questionnaires
Transactional information with us or others
Additional information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect the
Client's personal information. We require third parties that assist in providing our services to you to protect the
personal information they receive from us.
How do we share your information?
An Registered Investment Advisor shares Client personal information to implement its services effectively. In
the section below, we list some reasons we may share your personal information.
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Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
We share information with technology vendors and third-party service
providers to manage and support operations and regulatory compliance
(such as administrators, brokers, custodians, regulators, credit agencies,
consultants and other financial institutions) as necessary to provide
agreed-upon services, consistent with applicable law, including but not
limited to processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
No
Not Shared
Marketing Purposes
Evermont Wealth does not disclose and does not intend to disclose,
personal information with non-affiliated third parties to offer you
services. Specific laws may give us the right to share your personal
information with financial institutions where you are a customer and
where Evermont Wealth or the client has a formal agreement with the
financial institution. We will only share information for purposes of
servicing your accounts, not for marketing purposes.
Yes
Yes
that we believe
Authorized Users
Your non-public personal information may be disclosed to you and
persons
to be your authorized agent(s) or
representative(s).
No
Not Shared
Information About Former Clients
The firm does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties concerning persons
who are no longer our Clients.
Other Important Information
California, North Dakota, and Vermont. In response to applicable state law, if the mailing address provided for your account
is in California, North Dakota, or Vermont, we will automatically treat your account as if you do not want us to disclose your
personal information to non-affiliated third parties for purposes of them marketing to you, except as permitted by the applicable
state law.
Massachusetts. In response to a Massachusetts law, clients must “opt-in” to share non-public personal information with non-
affiliated third parties before any personal information is disclosed. We may disclose non-public personal information to other
financial institutions with whom we have joint business arrangements for proper business purposes in connection with the
management or servicing of your account.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter
the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at (909) 296-7977 or brent@evermont.com.
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