Overview
- Headquarters
- Birmingham, AL
- Total Firm Assets
- $5.1 billion
- Average High-Net-Worth Client Portfolio Size
- $1.9 million
Fee Disclosure
EVERSOURCE PART 2A
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $3,000,000 | 2.00% |
| $3,000,001 | and above | Negotiable |
Estimated Annual Advisory Fees
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $20,000 | 2.00% |
| $5 million | Negotiable | Negotiable |
| $10 million | Negotiable | Negotiable |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Actual fees may vary; other investment costs may apply.
Clients
- High-Net-Worth Share of Firm Assets
- 58.63%
- Number of High-Net-Worth Clients
- 1,540
- Total Client Accounts
- 13,689
- Discretionary Accounts
- 13,506
- Non-Discretionary Accounts
- 183
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 286340
Additional Brochure: EVERSOURCE PART 2A (2026-09-25)
View Document Text
EverSource Wealth Advisors, LLC
3500 Colonnade Parkway, Suite 150
Birmingham, Alabama 35243
(205) 982-5515 | www.eversourcewealthadvisors.com
Form ADV Part 2A
Firm Brochure
September 23, 2026
This firm brochure (“Brochure”) provides information about the qualifications and business
practices of EverSource Wealth Advisors, LLC. If you have any questions about the contents of this
Brochure call us at (205) 982-5515 or send an email to compliance@eversourcewa.com. The
information in this Brochure has not been approved or verified by the United States Securities and
Exchange Commission (the “SEC“) or by any state securities authority.
information about this
firm
Additional
is also available on the SEC’s website at
www.adviserinfo.sec.gov. EverSource Wealth Advisors, LLC is registered as an investment advisor
with the SEC. Registration with the SEC or a state securities authority does not imply a certain level
of skill or training.
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page i
Item 2 Material Changes
This is an update to EverSource Wealth Advisors, LLC’s Form ADV Part 2A, also known as the firm
brochure. There have been no material changes since our last Form ADV Part 2A annual updating
amendment dated March 17, 2026.
SEC rules require investment advisors, such as EverSource Wealth Advisors to disclose certain
information to clients and prospective clients in a direct and concise manner, written in plain
English.
Each year, within 120 days of the end of our fiscal year, we will provide client with either:
an updated copy of this Brochure, with a summary of material changes; or
a summary of material changes to the contents of our Brochure and an offer to send you
a copy of our updated Brochure with an explanation of how you can obtain a copy of the
updated Brochure.
Since our fiscal year ends on December 31st, each year you should receive a summary of material
changes (if any) no later than April 30th. In addition, we will provide you more frequent updates
about material changes to certain information (e.g., disciplinary information) or matters that
could materially affect our advisory relationship with you, as necessary.
Throughout this Brochure, we use terms that are capitalized (e.g., Brochure). Often, this means
that we provided a specific definition for that term. When we are defining a term, we underline
that term and enclose it within parentheses and quotation marks. For example, if you turn to the
Cover Page, you will find that we defined the term “Brochure” to mean this firm brochure (i.e.,
Part 2A of Form ADV).
If you have any questions about this Brochure or EverSource Wealth Advisors, LLC please give us
a call at (205) 982-5515 or send an email to compliance@eversourcewa.com.
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page ii
Item 3 Table of Contents
Item 1
Cover Page ................................................................................................................... i
Item 2
Material Changes ........................................................................................................ ii
Item 3
Table of Contents ....................................................................................................... iii
Item 4
Advisory Business ........................................................................................................ 4
Item 5
Fees and Compensation ............................................................................................ 11
Item 6
Performance-Based Fees and Side-by-Side Management ....................................... 17
Item 7
Types of Clients ......................................................................................................... 17
Item 8
Methods of Analysis, Investment Strategies, and Risk of Loss ................................. 17
Item 9
Disciplinary Information ........................................................................................... 22
Item 10
Other Financial Industry Activities and Affiliations .................................................. 23
Item 11
Code of Ethics, Participation or Interest in Client Transactions,
and Personal Trading ................................................................................................ 25
Item 12
Brokerage Practices .................................................................................................. 27
Item 13
Review of Accounts ................................................................................................... 28
Item 14
Client Referrals and Other Compensation ................................................................ 29
Item 15
Custody ..................................................................................................................... 31
Item 16
Investment Discretion ............................................................................................... 32
Item 17
Voting of Client Securities ......................................................................................... 33
Item 18
Financial Information ................................................................................................ 33
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page iii
Item 4 Advisory Business
A. General Description of EverSource Wealth Advisors, LLC
EverSource Wealth Advisors, LLC (“EverSource,” “firm,” “we” or “us”) is a privately-owned, SEC-
registered investment advisor, with its principal offices located in Birmingham, Alabama. Formed
as a Delaware limited liability company on January 18, 2017, the two principal owners of
EverSource are FHG Ventures - EverSource, LLC and BMSS EverSource, LLC. FHG Ventures –
EverSource, LLC is wholly owned by Mark Wesson.
EverSource’s day-to-day operations are managed by its officers, including Mark Wesson, our
Chief Executive Officer. While EverSource’s executive officers and staff primarily operate from
our offices in Birmingham, Alabama, our business model entails a large network of EverSource
investment advisor representatives (“IARs” or “Advisors”) and other registered investment
advisor (“RIA”) firms located throughout the United States which are under contract with
EverSource for back office and/or sub-advisory services. Although all of the IARs are registered
with and subject to oversight and supervision by EverSource, some of the IARs, or teams of IARs
operate under a separate team name disclosed on each team’s Form ADV Part 2B,. This allows
IARs flexibility in providing tailored individualized investment advice to the firm’s clients.
EverSource’s home office in Birmingham provides its IARs with investment programs, technology,
operations support, marketing, back-office functions, and compliance supervision and, by
contract, a selection of these services to independent RIAs.
Through our network of IARs and RIA firms which rely upon EverSource’s services, EverSource
offers a wide range of investment advisory, wealth management, consulting, and financial
planning services to meet the needs of clients, who include individuals, families, estates and
trusts, charitable foundations and funds, and institutions.
B. Description of EverSource’s Services
EverSource provides wealth management services, including investment advisory, financial
planning, and consulting services to its investor clients, and provides back-office support services
and serves as an investment subadvisor to RIAs. As fiduciaries, Everource IARs seek to
understand their clients and to deliver planning and investment solutions according to each
client’s particular goals, needs, values and passions.
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page 4
1. Investment Advisory Services
Investment advisory services are provided to EverSource’s investor clients by our IARs through
EverSource’s Investment Programs:
EverSource Firm as Portfolio Manager
EverSource Advisor as Portfolio Manager
SMA Direct
UMA Platform
Private Markets
Held Away Assets
EverSource OCIO
When entering a new client engagement, EverSource IARs interview their client and review
relevant documents to understand the client’s investment experience, time horizon, portfolio
withdrawal needs, risk tolerance, tax sensitivity, personal values, and unique circumstances. The
clients’ objectives and preferences are typically documented in the client file, an Investor Profile
Form, and/or an Investment Policy Statement and implemented via the Investment Programs
detailed below. Because EverSource earns more when a client places more assets with the firm
to manage, we have an incentive to recommend that the client place more assets with us. Also,
Investment Program Fees and certain third-party fees or costs vary depending on the Investment Program
selected. Depending on the arrangement with the client, the applicable Investment Program Fee may be
paid by the client or covered by the IAR. These differences can create conflicts of interest and incentives
in selecting among Investment Programs. We address these conflicts of interest through disclosure,
by seeking always to put the client’s interest ahead of our own and by setting the Investment
Program Fees at a level commensurate with the services required to operate the associated
program.
EverSource Firm as Portfolio Manager
EverSource’s Firm as Portfolio Manager program provides centralized discretionary portfolio
management and trading using EverSource’s model portfolios or third-party fund strategist
models. At the request of the Advisor, the EverSource Investment Department will manage the
clients’ accounts using a selected model portfolio approved by the EverSource Investment
Committee. Among the approved model portfolios are several “values-based” models provided
for clients who express interest in aligning their investments with their beliefs, including
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page 5
portfolios developed and maintained by the Brightlight team of EverSource. This approach and
underlying assumptions are described in Item 8.
Additional fees attributable to third-party fund strategists may apply.
EverSource Advisor as Portfolio Manager
EverSource’s Advisor as Portfolio Manager program gives IARs the flexibility to manage client
accounts using their own models or customizing portfolios to individual clients’ needs and
preferences. Oversight is provided by the EverSource Investment Department, but IARs are
responsible for executing day-to-day investment management decisions. Clients may elect for
accounts to be managed on a discretionary basis (client consent not required before trading) or
a non-discretionary basis (client consent required before trading).
SMA Direct
EverSource Through the SMA Direct Program, IARs may delegate investment authority for client
accounts to approved third-party sub-advisors for select investment strategies. EverSource
conducts due diligence on the applicable asset managers and investment strategies before
making them available to IARs.
UMA Platform
EverSource provides access to third-party Unified Managed Account (“UMA”) platforms that
permit client accounts to be allocated across fund strategist portfolio models, separately
managed account strategies, and advisor-managed models. Third-party platform fees and
manager fees apply and vary depending on the platform and strategy selected.
Private Markets
EverSource provides investment and operational due diligence on private equity funds, private
credit funds, real asset funds, hedge funds, and direct real estate investment. IARs are enabled
to present eligible clients with appropriate private market investments approved by EverSource’s
Investment Committee and to facilitate the client subscription commitments with the EverSource
Investment Department. This includes private market investments developed by the Brightlight
team of EverSource which are focused on values-driven and impact strategies. Private market
investments accessed through EverSource’s private markets platform are subject to the
applicable Investment Program Fee. An additional 0.25% due diligence fee applies to Brightlight
Impact Investments (“BII”) IARs may learn of private market investment opportunities which
have not been and will not be reviewed, recommended or supervised by EverSource, but which
the IAR knows are of interest to specific eligible clients. In those situations, the IAR is permitted
to assist the client as requested in making those investments, but makes it clear to the client that
neither EverSource nor the IAR is reviewing, recommending, or supervising the investment and
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page 6
that no advisory or other fee will be charged to the client by EverSource related to such non-
recommended investment.
EverSource formed and manages EverSource Capital Access Fund I, LLC (“Fund”), a pooled closed-
end real estate investment fund which allowed eligible clients to pool their funds and have access
to a single private market fund. This Fund was closed to new investors in May 2022. The offering
documents, including private placement memorandums, contain a complete discussion about
the Fund. Each investor was required to complete a Subscription Agreement, through which the
client established eligibility and accepted the various risks associated with this type of
investment. EverSource clients were not obligated to invest in the Fund.
One member of the EverSource board of managers is a part owner of the Firm and the CEO of a
private real estate firm which sponsors real estate investment funds, including ones that
EverSource recommends. EverSource addresses this conflict of interest by disclosing these
relationships and subjecting these funds to the same due diligence process as any other private
fund it recommends. The board member does not have any involvement in the due diligence or
recommendation process and clients are not obligated to invest in any fund.
Held Away Assets
Held-away assets are those that are not held at EverSource’s primary qualified custodians and
may be aggregated through the Black Diamond Wealth Platform for reporting and billing.. This
includes fee-only insurance and annuity products, 529 plans, donor-advised funds, and defined
contribution plan participant (e.g., retirement) accounts. EverSource IARs provide investment
advisory, financial planning, and consulting services related to fee-based annuity and insurance
products a.
Third-party technology costs may apply in addition to the applicable Investment Program Fee.
EverSource uses a third-party platform to facilitate management of retirement plan participant
accounts where the client has granted EverSource investment discretion. Because EverSource
does not have access to or use client log-in credentials to effect trades on this platform,
EverSource doesnot have custody of these client funds. In those cases, clients receive a link from
the platform provider which allows them to connect their account to the platform and to give
the EverSource advisor access for the limited purpose of managing the investments in the
account. The advisor will review the account allocations and, when deemed necessary, rebalance
the account in light of the client’s investment goals. Because it is usually not possible for
EverSource to directly debit its fees from ERISA plan accounts, fees are assigned to another client
account or billed directly to the client. EverSource is not affiliated with this platform provider in
any way and receives no compensation for recommending or using the platform.
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
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EverSource OCIO
EverSource’s Outsourced Chief Investment Officer (“OCIO”) Program provides qualified clients,
generally those with more than $5 million in assets under management, with portfolio design,
manager selection, due diligence, implementation, and oversight by the EverSource Investment
Department. The program may include investments across public and private markets. The OCIO
fee is negotiated separately for each client. The OCIO fee is in lieu of the Investment Program
fees for all other investment programs.
Retirement Plan Services
For certain retirement plans, EverSource provides services to the plan sponsor, including
investment oversight, plan participant education, and ongoing administrative support. These
services are offered in collaboration with third-party administrators (“TPAs”), recordkeepers, and
other plan fiduciaries. EverSource typically serves in a non-discretionary ERISA 3(21) fiduciary
capacity.
Rollover Recommendations
For clients who are participants in a retirement plan, we will evaluate whether it is in their best
interest to “roll over” their plan account to an individual retirement account (“IRA”), move their
assets to a different retirement plan, leave the plan as is, or reallocate the assets in the plan
account. EverSource will generally earn a fee if the client elects to rollover the plan account or to
contract with EverSource for the provision of investment advice on the plan account assets. This
creates a conflict of interest and an incentive for EverSource to recommend a rollover rather than
leaving the account as is. EverSource discloses this conflict, advises the client of its fiduciary
status, and documents the rationale for any rollover recommendation. Though this typically
involves a 401(k) account rolling over to an IRA, any change in retirement account type triggers
the need for a rollover justification and rationale.
2. Services to Independent RIAs
Turnkey Asset Management Program Services
For certain RIA firms, EverSource provides Turnkey Asset Management Program (“TAMP”)
services. EverSource’s TAMP services provide back-office investment services including, model
management, trading and rebalancing, advisor and client portal access, billing, quarterly
reporting, and providing access to marketing resources. EverSource utilizes the Investment
Programs described above to deliver these services and may use third-party strategists as well to
deliver model portfolios through its TAMP sub-advisory service. For some clients, EverSource also
provides due diligence and back-office support regarding private markets funds.
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
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Back Office Services
EverSource also provides to independent RIAs various “back office” services in such areas as
marketing, compliance, administration, technology, and practice development. The specifics of
each engagement are covered in the written agreement between each RIA and EverSource.
3. Planning Services
Financial Planning Services
EverSource’s IARs deliver Financial Planning Services based on either a comprehensive or limited
scope project engagement. In each case, Advisors seek to understand client’s current and
projected financial situation and circumstances. Depending on the type of engagement, financial
planning advice and ongoing guidance may address individual and family financial data
organization, cash flow planning, tax planning, risk identification and mitigation strategies,
insurance policy review, investment asset allocation review, retirement projections and planning,
business succession, life impact stewardship planning and an estate plan review.
Standard practice is for IARs to deliver the financial planning process over the course of multiple
meetings and to present analysis, options, and recommendations via financial planning software
and follow-up written recommendations. While some clients want a “one-time” financial plan,
financial planning is generally an iterative process that requires regular realignment based on
updated client needs, objectives, opportunities, risks, and available options that arise from
clients’ evolving life circumstances.
Life Impact® Stewardship Planning Services
Life Impact® Stewardship Planning is a service provided in addition to financial planning services
which focuses on the other aspects of a person or family’s life. The process is used to assist
clients with aligning their purpose, calling and values with all aspects of their life. We engage
subject-matter experts on a contract basis to assist where we believe that would be helpful.
4. Consulting Services
EverSource Advisors’ Consulting Services complement Financial Planning Services and leverage
EverSource’s network of internal and external subject matter experts. Advisors assist clients with
unique projects and analysis to help them achieve specific objectives related to other financial
and life planning needs. Examples include business succession planning, resource stewardship,
estate planning, charitable and philanthropic planning, asset protection planning, family
dynamics and conflict resolution, and business and executive compensation. Certain IAR teams
with qualified personnel offer tax advice, tax planning, and tax return preparation and filing as a
part of the team’s overall service offering.
EverSource has relationships with Mutual Securities, Inc. (“MSI”), DPL Financial Partners (“DPL”),
and Halo Securities, LLC (“Halo”), which each in turn has relationships with unaffiliated broker-
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page 9
dealers and insurance carriers. These relationships provide EverSource the opportunity to
provide non-discretionary investment advisory and consulting services to certain of MSI’s, DPL’s,
or Halo’s clients who have requested that EverSource provide those services, typically along with
investment advisory services on separate assets managed by EverSource.
C. Customized Services
EverSource IARs tailor the financial planning process and recommended solutions for each client
based on personal life and family circumstances. IARs are also able to tailor investment
portfolios for clients, including establishing restrictions and limitations on investing in certain
securities or security-types based on the client’s unique objectives and values.
D. Wrap Fee Programs
A team of EverSource IARs in Birmingham, Alabama previously offered a Wrap Fee Program,
under which
investment advisory fees, transaction fees, and custodial broker-dealer
commissions are bundled into a single “Wrap Fee”. While that team does not offer that program
to new clients, existing wrap fee program participants are permitted to remain in the program.
The objective of that Wrap Fee program is for EverSource to cover commissions resulting from
trades in client accounts without increasing the fee clients would otherwise pay.
Please refer to EverSource’s Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”)
for a full disclosure of the existing grandfathered wrap fee program, including conflicts of
interest.
Assets Under Management
E.
As of June 30, 2026, EverSource’s assets under management were as follows:
Assets Managed on Discretionary Basis
$5,345,464,764
Assets Managed on Non-Discretionary Basis
$110,458,810
Total Assets Under Management
$5,455,923,574
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page 10
Item 5 Fees and Compensation
A. Advisory Fees and Compensation
Fees in General
Our fees will be set forth in each client’s engagement agreement with EverSource (“Client
Agreement”). Fee schedules for investment advisory, financial planning, and consulting services
will vary among EverSource Advisors depending on varying service models, client needs,
complexity, and areas of particular expertise, and are subject to negotiation. Thus, fees often
vary between and among clients.
For some accounts, EverSource may propose to charge a recurring fixed fee for investment
advisory services instead of charging a fee based upon a percentage of the value of assets under
management, or a combination of a fixed fee and an asset management fee. If the client agrees,
the specific fee will be set forth in the client agreement, charged quarterly or monthly, and
deducted directly from the client’s investment account or paid directly by the client. Additional
information on the fees we charge for certain types of services (including default billing methods)
is provided below.
Investment Advisory Fee Schedule
Fees for investment advisory service fees are specified in Exhibit A to the Client Agreement,
including billing frequency, fee calculation method, and the fee rate type.
Fees are either billed monthly or quarterly, and the fee calculation is either: (i) in advance, based
upon the balance of the client’s account(s) on the last day of the previous billing period; or (ii) in
arrears, based upon the average daily balance of the client’s account(s) over the preceding billing
period.
The applicable billing rate is usually based on a percentage of the value of assets in a client’s
account(s) (“Account Asset Value”) within certain asset value ranges (or “tiers”). In some cases,
clients within the same immediate family can group accounts together where that allows them
to reach higher tiers and lower applicable fees. We will apply one of the following billing rate
types:
- Floating Rate: a single fee rate (percentage) is applied to the Client’s entire Account Asset
Value where the rate is dictated by the asset threshold (or tier) in which that Account
Asset Value falls. This creates a billing structure which applies a single rate that adjusts
as the AUM crosses defined asset thresholds, whether up or down.
- Tiered Rate: different fee rates apply to different segments of the Client’s Account Asset
Value, where each tier rate applies only to that portion of the Account Asset Value falling
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
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within that tier's range, and the total fee is the sum of the amounts calculated for each
tier. This billing structure provides incremental fee reductions as assets grow.
- Flat Rate: client is billed a set or fixed percentage of Account Asset Value.
- Flat Fee: client is billed a set fee independent of Account Asset Value.
Investment Advisory Service fees are generally billed within ten (10) days following the close of
the applicable billing period. The valuation dates and billing method are subject to negotiation
and may vary between our clients. The following example shows the application of quarterly
billing in arrears using a Tiered Rate.
Monthly Fee, if clients
billed monthly
Tier
Account Asset Value
Annualized
Fee
Quarterly Fee,
if clients
billed
quarterly
Up to 0.17%
Up to 0.50%
Up to 2.00%
Up to $3,000,000.00
1
Over $3,000,000.00
2
Separately negotiated with
each client
Example: Assume (on an account that is billed quarterly in arrears based upon the average daily
balance over the immediately preceding calendar quarter) that on January 1st, a client engages
EverSource to provide Investment Advisory Services, opening an account by depositing $1,500,000
of cash and securities. Further assume that as of March 31st, the average daily balance of the
preceding calendar quarter was $1,600,000, and the annualized fee the client has agreed to pay is
1.0%. Based on these facts, the client’s Investment Advisory and Wealth Management Services fee
for the quarter ending March 31 would be computed as follows:
Full Tier 1 Quarterly Fee = $1,600,000 x 0.25% = $4,000.00
= Total Quarterly Fee = $4,000.00
Depending on the contractual arrangement with each client, we will either invoice clients or
directly debit their custodial accounts for portfolio management fees. Specific fee arrangements
and calculation methods are set forth in the client’s advisory agreement with EverSource.
Investment Program Fees
In addition to Investment Advisory Services fees, EverSource typically charges the client an
investment program fee based upon a percent of assets under management on accounts
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page 12
managed through one or more of the EverSource Investment Programs, described above.
Depending on the arrangement reflected in the client agreement, the Investment Program Fee may
be paid by the client or covered by the IAR. This fee is billed consistently with the billing method
used to calculate the investment advisory fee. This fee is dependent upon the Investment
Program(s) utilized by the IAR managing the client’s assets a and ranges from 0.05% (5 bps) to
0.50% (50 bps) annualized. In the case of the OCIO program, the fee is negotiated and is in lieu
of all other program fees. The applicable Investment Program Fee and whether it is paid by the
client or covered by the IAR are disclosed in the client agreement. Where the client is responsible
for the fee, it may be paid by direct debit from the client’s custodial account or by invoice, as
applicable.
The Investment Program Fee compensates EverSource for services and costs associatedwith the
applicable investment program, which may include due diligence, portfolio management,
platform management and integration, monitoring and any third-party platform costs. Certain
programs may also involve additional third-party fees or costs, as described below. For the
Private Markets Program, this fee also compensates EverSource for fund investment due
diligence, operational due diligence, subscription management, and the unique reporting needs
of private market funds. An additional 0.25% due diligence fee applies to Brightlight Impact
Investments (“BII”).
For the SMA Direct Program, EverSource provides access to approved sub-advisors for select
strategies. For the UMA Platform, third-party platform fees and manager fees apply and vary based
on the strategy selected.
For Held Away Assets, the Investment Program Fee is 0.05% annually, and third-party technology
costs may apply in addition to the Investment Program Fee.
Sub-Advisory Services
EverSource is compensated for its Turnkey Asset Management Program (“TAMP”) sub-advisory
services, described in Item 4, based upon a percentage of the assets which other RIA firms place
with EverSource for management. Our fee for these services is established by agreement
between EverSource and the other RIA and is generally deducted directly from the client’s
account pursuant to authority delegated to us from the other RIA. It is the responsibility of the
other RIA to disclose to the client whether and, if so, how payment of this fee to EverSource
affects the overall investment advisory fee paid by the client. EverSource’s fee for back-office
support services to RIAs other than TAMP services is also established by agreement with the
other RIA and is not charged by EverSource to the client.
EverSource also has relationships with DPL and Halo under which EverSource is paid for providing
ongoing portfolio management and investment advisory services to the client and DPL or Halo
relative to certain insurance and annuities owned by a client. DPL or Halo pays EverSource an
advisory fee for this work and the arrangement places no financial burden on the client.
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Planning and Consulting Services Fees
Fee-for-Service Financial Planning and Consulting engagements can be billed on either a fixed-
fee basis (generally ranging from $2,500 to $25,000), a flat annual fee billed in monthly or
quarterly installments, or a time-worked basis (generally, at rates ranging from $150 to $400 per
hour). The fee for Life Impact® Stewardship Planning will be negotiated separately with each client.
As described in Item 4.B.4., EverSource has relationships with MSI, Halo, and DPL, which provide
EverSource with the opportunity to provide investment advisory consulting services to certain
clients who have requested that EverSource provide those services. The consulting fee paid to
EverSource is calculated based upon the value of the client’s assets at MSI, Halo, or DPL for which
EverSource is providing investment consulting. The fee is negotiable, but generally ranges from
0.5% to 1.0%, (annualized), is paid quarterly or monthly, and is debited by MSI, Halo or DPL
directly from the client’s assets.
Other Consulting Services
• Family Dynamics and Conflict Resolution Consulting. EverSource works with families and
family-owned businesses to resolve conflicts, improve communication, and develop
strategic and succession plans. Fees for this service are typically billed at an hourly rate
of $400 per hour, a daily rate of $1,500, or a negotiated total fee per project.
•
• Compensation Consulting. EverSource serves business owners and management
through providing advice and assistance in the design and delivery of compensation
programs. Fees are generally established through negotiation and are charged per
project as a one-time charge or monthly consulting fee.
Investment Consulting. EverSource consults with other RIAs regarding their investment
office, due diligence, alternative assets and similar matters. Fees are generally
established through negotiation and are charged per project.
B.
Payment of Fees
Depending on the circumstances and needs of our clients and the type of services provided, our
fees are either directly debited from our clients’ accounts or separately invoiced quarterly or
monthly for investment advisory and monthly or quarterly for financial planning and consulting
services. We will endeavor to meet the billing needs and requests of our clients at the time of
entering into the Client Agreement.
C.
Additional Fees and Expenses
With the exception of the small number of accounts managed under a Wrap Fee Program, our
Investment Advisory fees are exclusive of transaction fees, broker commissions, and other
related expenses incurred in connection with providing services to our clients or otherwise with
respect to transacting business for or on behalf of our clients. In some circumstances, we will
EverSource Wealth Advisors | Form ADV Part 2A | September 23, 2026
Page 14
engage a third-party manager (co-advisor or subadvisor) to manage a defined portion of a client’s
portfolio for a fee. The manager’s fee will be passed along to the client and may be debited
directly from the client’s account by the third-party manager. Our clients typically incur costs in
addition to EverSource’s fees, such as charges imposed by third parties like custodians, brokers,
and separate account managers. For an explanation of our brokerage practices, please see Item
12.
Mutual Fund and ETF Fees and Expenses
We generally include mutual funds and ETFs in our investment strategies. Mutual funds and ETFs
charge internal expense ratios. These charges are in addition to our fees, and we do not receive
any portion of these charges. In addition to advisory fees paid to our firm, clients will also be
responsible for all transaction, brokerage, and custodial fees incurred as part of their account
management, with the exception of the handful of accounts managed under the Wrap Fee
Program. Any client invested with a third-party manager is also responsible for all advisory fees
charged by that manager. These third-party manager fees are charged in addition to EverSource’s
advisory fees. Any client invested in a private market investment is also responsible for paying
all fees incurred as part of that investment commitment.
Pooled Investment Fund Costs
For clients invested in the EverSource Capital Access Fund 1, LLC (“Fund”), EverSource charges its
typical investment advisor fee and the Private Markets Program fee. EverSource does not charge
a separate fee for managing the Fund, but the client’s investment in the Fund does cover
projected expenses which EverSource pays as manager of the Fund. This includes such costs as
the required annual audit, accounting and bookkeeping, legal, and governmental registrations.
D.
Prepaid Fee Disclosure; Termination of Investment Advisory Relationship; Refunds
Prepaid Fees
In situations where EverSource is providing financial planning or consulting services, the Client
may be required to pre-pay some fees, though not more than $1,200 in fees per client, six months
or more in advance. Depending on the specifics of each Client Agreement and the services
provided, we will either directly debit the client’s account by agreement with the client or invoice
the client.
Termination of the Investment Advisory or Financial Planning Relationship
Termination and refund terms and conditions are disclosed and outlined in each client’s Client
Agreement with EverSource. In addition, third party investment managers and service providers
often have their own terms and conditions applicable to termination, to which the client will be
subject.
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A client or EverSource may cancel the Advisory or Financial Planning agreement at any time for
any reason upon our receipt of thirty (30) days’ written notice.
Refunds
In the event that either EverSource or the client terminates EverSource’s engagement in
accordance with the Client Agreement, the client will be promptly billed the fee due in arrears
for the wealth management services performed quarter to the effective date of termination or
refunded the prorated fee billed in advance for the time remaining in the quarter after the
effective date of termination. The applicable fee due to EverSource will be determined as of and
prorated through the effective date of termination of the Client Agreement based on the client’s
fee schedule. Any pre-paid fees which EverSource has not earned as of the effective date of
termination shall be refunded to the Client.
E.
Additional Compensation Received by Us
Some of the IARs at EverSource are licensed insurance brokers or agents who work with various
insurance companies unaffiliated with EverSource. In these capacities, these individuals may
recommend insurance products and receive additional compensation from the sale of those
products through the insurance companies with which these individuals are appointed. Thus, a
potential conflict of interest exists between the interests of these individuals and those of the
advisory clients, possibly creating an incentive for them to recommend insurance products based
on the compensation received, rather than on a client’s needs. These individuals who are IARs
do not limit their recommendations to products or services offered by the insurance company
with whom they are appointed and ensure that all recommendations are appropriate for a
client’s specific needs. Clients have the option to purchase insurance products recommended
through any insurance companies. EverSource does not receive any part of the commissions
generated through the sale of insurance products but does supervise the insurance activities of
its IARs as outside business activities.
EverSource receives income through a referral relationship with Flourish Cash which provides an
independent FDIC-insured cash program. Flourish Cash accounts allocate cash across multiple
FDIC-member banks to increase FDIC coverage ($5 million for individual accounts and $10 million
for joint accounts) and enhance income yields. Depending on aggregate cash balances,
EverSource can earn 0.00% to 0.05% on cash balances introduced to the Flourish Cash program.
Income paid to EverSource comes out of Flourish’s spread and does not reduce clients’ eligible
APY rates. There are no Flourish fees or cash account minimums and no limitations on transfers
to a client’s primary bank account.
Our firm may also receive compensation in the form of referral fees for recommending certain
registered investment advisors to our advisory clients. Please refer to Item 14 of this Brochure
for a detailed description of conflicts of interests that are inherent in such referral arrangements.
Neither our firm nor its IARs receive any referral or similar fee for recommending any third-party
asset manager or private market investment.
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Item 6 Performance-Based Fees and Side-by-Side Management
A. Performance-Based Fees
Performance-based fees are fees that are based on a share of a capital gain or capital
appreciation of a client's account. EverSource does not charge or accept performance-based
fees.
B. Side-by-Side Management and Conflicts of Interest
Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged
performance-based fees. Except as described above, EverSource does not charge or accept
performance-based fees and does not engage in side-by-side management of accounts.
Item 7 Types of Clients
EverSource serves individuals, families, estates and trusts, charitable foundations, institutions,
broker/dealers, retirement plans, IARs and other Registered Investment Advisor firms. Each
EverSource IAR team is allowed to set his or her minimum account size for opening an account
with that IAR.
For an asset-based fee, EverSource contracts directly or indirectly with third-party broker-
dealers and insurance carriers to provide ongoing analysis and investment advice for client
accounts held by DPL, MSI, or Halo or at the broker-dealer or insurance carrier. (See Item
4.B.4.).
Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss
A. Methods of Analysis and Investment Strategies
EverSource enables its IARs to manage client portfolios across multiple investment programs, as
discussed in Item 4. While EverSource enables its IARs to deliver portfolios of mutual funds, ETFs,
and third-party managed accounts across multiple investment styles (index, factor, tax-aware,
values-based, and active strategies based on fundamental research), the core elements of the
portfolio management process remain consistent. Series of risk-based asset allocation models
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are developed that allocate incrementally to diversified equity, alternative, and fixed income
strategies. Diversification does not guarantee against risk of loss and all portfolios are subject to
market risk. IARs are responsible for understanding and documenting clients’ time horizon,
portfolio withdrawal needs, risk tolerance, tax sensitivity, values, and other unique
considerations, forming the basis for a strategic asset allocation recommendation.
Investment Strategies
EverSource Firm as Portfolio Manager Program
EverSource develops diversified strategic asset allocation models as defined above and makes
available similar models from third-party asset managers on its platform that have been reviewed
and approved by the EverSource Investment Committee. Among those models are values-based
strategies, discussed below.
EverSource Advisor as Portfolio Manager Program
EverSource oversees its IARs in the development of their own customized models. IARs may also
customize strategies used within a strategic asset allocation portfolio based on clients’ unique
needs and preferences. Significant deviations in asset allocation from broadly diversified, global
equity and bond indexes can expose investors to significantly different return and risk outcomes
in a portfolio.
SMA Direct Program
EverSource’s Investment Committee reviews and approves access to asset managers and
strategies that IARs can use through separately managed accounts. Through the SMA Direct
Program, investment authority may be delegated to approved sub-advisors for select investment
strategies. An asset managers investment style, depending on the amount of active risk versus
its primary benchmark, can expose investors to significantly different return and risk outcomes
in a portfolio.
UMA Platform
EverSource provides access to third-party Unified Managed Account (“UMA”) platforms that
allow client accounts to be allocated across fund strategist portfolio models, separately managed
account strategies, and advisor-managed models. The investment managers and strategies
available through these platforms may vary by platform and strategy selected.
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Private Markets Program
EverSource’s Investment Committee reviews and approves access to private equity funds, private
credit funds, private real asset funds, and direct real estate investments that advisors can access
to provide as alternative investment strategies to eligible clients. Private market investments
expose investors to a significantly more types and degrees of risks than traditional asset classes,
including significantly higher illiquidity risk, credit risk, leverage risk, concentration risk, manager
risks, operational risks, and due diligence risks. IARs may introduce eligible clients to private
market investment opportunities where the IAR knows the client has an interest but which
EverSource’s Investment Committee has not reviewed or approved. In those situations, the IAR
will make it clear to the client that neither EverSource nor the IAR is recommending the
investment and that no advisory or other fee will be charged to the client by EverSource related
to such non-recommended investment.
Methods of Analysis
EverSource methods, focus, and depth of analysis vary based on investment program and are
applied based on the risk type and level of the investment strategy.
EverSource Firm as Portfolio Manager Program
EverSource Models: Series of risk-based models are developed based on a long-term, top-down
strategic asset allocation. EverSource selects managers to fill asset class sleeves through
quantitative and qualitative screens and in-depth asset manager and strategy due diligence.
Model performance and asset manager strategies are monitored with a particular focus on
relative return/risk to primary benchmarks and peer groups.
Third-Party Strategist Models: EverSource conducts due diligence on third-party strategists,
analyzes the investment style of models and historical asset allocation decisions, and reviews
track record of models vs. blended benchmarks. After third-party strategist models are added to
EverSource’s investment platform, EverSource regularly reviews manager selection and model
updates, manages trading, and monitors model performance.
Values-Based Analysis: Values-based (sometimes referred to as faith-based or faith-integrated)
investing seeks to integrate a values-based framework into the investment selection process to
screen, engage with, or align a portfolio with a values or faith driven investment philosophy. We
base this framework on a Judeo-Christian worldview. EverSource utilizes and relies on third party
asset managers to provide research and screening data for this analysis on a best-efforts basis.
Associated with this type of investing, there are additional risk factors that include, but are not
limited to the following:
• Potentially higher costs associated with screened investments.
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• Screening restricts the universe of available investments which may result in a more
restricted investment universe, leading to investment underperformance.
• Potential for decreased diversification in different asset classes and across a portfolio due
to the limited universe of investable companies across the investment universe and the
limited number of managers willing to manage these values or faith integrated mandates.
• Asset managers may fail to appropriately apply values-based screens consistently due to
data inaccuracies and limitations, resulting in unintended exposures to prohibited
business activities in the product’s offering documents.
If a client desires specific screening restrictions and has sufficient assets, EverSource partners
with multiple custom direct indexing asset managers that can tailor portfolios to each client’s
specific preferences.
EverSource Advisor as Portfolio Manager Program
EverSource provides oversight of IAR’s manager selection. The EverSource Investment
Department oversees approved lists of securities and model management on behalf of advisors
in the Black Diamond Wealth Platform. The primary objective of this program is to provide IARs
the ability to customize their own portfolios, while continuously monitoring investment strategy
performance and overseeing model construction.
SMA Direct Program
EverSource conducts qualitative and quantitative due diligence on the asset manager and
investment strategy and may supplement its review with similar due diligence from a third-party.
EverSource may also outsource due diligence for managers on Unified Managed Account
platforms to a third-party sponsor of the program.
UMA Platform
For investment managers and strategies available through third-party UMA Platforms,
EverSource may conduct its own due diligence and/or rely on or supplement its review with due
third parties.
diligence conducted by
the
third-party platform sponsor or other
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Private Markets Program
EverSource conducts operational due diligence and investment due diligence before approving a
new private equity fund, private credit fund, private real estate fund, and direct real estate
investment and may supplement our review with similar due diligence from a third-party.
B. Material, Significant or Unusual Risks of Investment Strategies
Material risks vary based on investment program and are summarized below.
EverSource Firm as Portfolio Manager Program
Because EverSource manages or selects a series of highly diversified, multi-asset class models for
the EverSource Firm as Portfolio Manager program, the primary risks are economic and market
risks, investment style risk, and asset manager unique risks. An investment strategy’s strategic
asset allocation that manages market risk is the most significant variable. See above for
additional risk factors related to values-based investing.
EverSource Advisor as Portfolio Manager Program
This program presents the same list of primary and significant risks as the EverSource Firm as
Portfolio Manager program. However, individual IAR decisions about manager and fund
concentrations within their models and portfolios may lead to more significant investment style
and asset manager unique risks.
SMA Direct Program
Material and significant risks are economic and market risks, investment style risk, and asset
manager unique risks. Given that investment accounts may substantially beinvested in a single
asset manager’s strategy, manager concentration risk, including key person, investment, and
operational risk, is a significant consideration.
UMA Platform
Assets managed through a UMA Platform are subject to the risks associated with the underlying
investment managers and strategies, including economic and market risk, investment style risk,
asset manager risk, and operational risk. Where multiple managers or strategies are used within a
UMA, differences in investment approach, portfolio allocation, trading, or manager performance
may affect the overall risk and return of the account.
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Private Markets Program
Private market investments expose investors to significantly more types and degrees of risks than
traditional asset classes, including significantly higher illiquidity risk, credit risk, leverage risk,
asset concentration risk, manager risks, key person risks, and operational risks (including absence
of internal controls). In addition, due to the difficulty with assessing these risks, there is the
additional risk that the due diligence process may miss a material risk relevant to the decision to
invest.
C. Risks Associated with Particular Types of Securities
As a general practice, EverSource does not recommend concentrated investment in individual
securities and recommends diversification to protect against risk of loss. However, EverSource
does accommodate client requests to invest in or hold individual securities.
One exception to this general practice is that EverSource will conduct due diligence on and
recommend direct investments in real estate. These investments come with unique private
market asset risks, including development or redevelopment risks, leverage risks, local
submarket risks, entitlement or zoning risks, environmental risks, and other unique risks that
cannot be diversified through a larger fund. Pooled Investment Funds, such as EverSource Capital
Access Fund I, LLC, are illiquid, have no readily available market or sales price, and are
concentrated in a particular fund invested only in a particular private market sector. Pooled
Investment Funds may only produce a return on invested capital when the underlying
investments make distributions or liquidate. Investors must be careful to evaluate these risks
against their investment objectives, liquidity needs and risk tolerance before making a decision
to invest.
Item 9 Disciplinary Information
We are required to disclose to our clients any legal, regulatory, or disciplinary events that are
material to a client’s or prospective client’s evaluation of EverSource’s advisory business or the
reputation and integrity of its management. (A “management person” is any of the firm’s
principal executive officers and members of the firm’s investment committee.)
Neither EverSource nor its management personnel have been involved in any arbitration claim
or found liable in any civil, self-regulatory organization or administrative proceeding that would
require disclosure under applicable SEC rules. Individual investment advisor representatives
include any required disciplinary disclosures in the Form ADV Part 2B provided to their clients.
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Item 10 Other Financial Industry Activities and Affiliations
A. Broker-Dealer Registration
Neither EverSource nor any of our management persons (including investment advisor
representatives) are registered, or have an application pending to register, as a broker-dealer or
a registered representative of a broker-dealer.
B. Futures Commission or, Commodity Pool Operator or Trading Advisor Registration
EverSource is not registered, and does not have an application pending to register, as a futures
commission merchant, commodity pool operator, a commodity trading advisor, or an associated
person of the foregoing entities.
C. Material Relationships or Arrangements with Related Persons
BMSS Wesson Wealth Solutions, LLC (“BWWS”), an SEC-registered investment advisor firm, is
under common control with EverSource in that Mark Wesson is the CEO of both firms. BWWS
and EverSource share office space, personnel and other critical functions including management,
and EverSource provides certain back office and sub-advisory services to BWWS.
BMSS, LLC (“BMSS”) is a regional certified public accounting firm that is the sole owner of BWWS.
Some of the members of BMSS are also members of BMSS EverSource, LLC, which is one of the
owners of EverSource Wealth Advisors, LLC. EverSource CEO Mark Wesson is a member of BMSS,
which subleases office space from EverSource for a handful of BMSS’s employees. Several of the
owners and supervised persons of EverSource are also clients of BMSS, BWWS or both. Because
of these relationships, EverSource has an interest in recommending that clients engage BMSS for
accounting and related services. EverSource addresses this conflict of interest through
disclosure.
EverSource is the 100% owner of EverSource CID, LLC (“CID” or “Consider It Done!”), a virtual
assistant company serving financial advisors around the nation, including BWWS and EverSource.
CID discloses to its clients that it is owned by EverSource and the agreement between CID and its
financial advisor clients provides that EverSource will not use the information obtained through
CID except as necessary to facilitate ordinary business transactions and to supervise the
operations of CID. Because CID is a wholly-owned subsidiary, EverSource has a self-interest in
recommending that clients use CID’s services.
EverSource has a minority ownership interest in Harvest App LLC (“Harvest”), a digital wealth
management platform and RIA that serves investment advisors and individual consumers. We
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refer clients to Harvest who we believe would benefit from the services provided by Harvest and
typically do not meet the account minimums established by our investment advisors. We do not
receive a referral fee or any other financial remuneration for that referral. However, we do have
a conflict of interest in making such a referral because of our ownership interest in Harvest. The
Firm addresses this conflict through disclosure and by periodically evaluating Harvest’s services
and fees to determine whether they are and remain reasonable and competitive.
EverSource is the manager of EverSource Capital Access Fund I, LLC, a pooled investment fund
created in 2022 and now closed to new investors, which allowed s eligible clients to pool their
funds and invest in a single private market real estate fund. The fees associated with the Fund
are disclosed in Item 4 and the Fund details are described in its offering documents.
One member of the EverSource Board of Managers is a part owner of the Firm and the CEO of a
private real estate firm which sponsors real estate investment funds, including ones that
EverSource also recommends. EverSource addresses this conflict of interest by disclosing these
relationships and subjecting these funds to the same due diligence process as any other private
fund it recommends. Further, the board member does not have any involvement in the due
diligence or recommendation process and clients are not required to invest in any fund.
See Item 4.B.4 above regarding the relationships EverSource has with MSI, DPL, and Halo, and
Item 5 for an explanation of the associated fees. Clients have the opportunity to execute a broker
of record change in favor of one of these firms for client-owned investment products, such as a
variable annuity or insurance policy. Those firms will, with the client’s consent, engage
EverSource to provide investment advice on those investment products to the firm and to the
client, generally alongside the financial planning and/or investment advisory services EverSource
is already providing to the client. EverSource consequently has an incentive to recommend MSI,
DPL, and Halo which it mitigates through disclosure and helping the client to understand the pros
and cons of the transfer.
As described in Item 5, some of the IARs which join EverSource are licensed insurance brokers or
agents who work with various insurance companies unaffiliated with EverSource. In these
capacities, these individuals may recommend insurance products and receive additional
compensation from the sale of those products through the insurance companies with which
these individuals are appointed. Thus, a potential conflict of interest exists between the interests
of these individuals and those of the advisory clients, possibly creating an incentive for them to
recommend insurance products based on the compensation received, rather than on a client’s
needs. These individuals who are IARs do not limit their recommendations to products or services
offered by the insurance company which appointed them and ensure that all recommendations
are appropriate for a client’s specific needs. EverSource does not receive any part of the
commissions generated through the sale of insurance products but does supervise the insurance
activities of its IARs as outside business activities.
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As described in Item 5, EverSource has a relationship with Flourish Cash that allows the firm to
earn referral fees for recommending the Flourish Cash FDIC-member insured program, which
creates an incentive to recommend Flourish Cash with the potential to create conflicts of interest
relative to recommending other FDIC-insured cash account programs. Flourish Cash is a cash
account and is not considered a security.
D. Material Conflicts of Interest Relating to Other Investment Advisors
EverSource will occasionally assist a client by recommending another investment advisor for such
client from whom we may receive compensation. In addition, EverSource does receive client
referrals from other investment advisors, including the related firm BWWS, for which EverSource
pays a referral fee. See Item 14 for an explanation of this practice and of how EverSource
addresses the attendant conflict of interest.
Item 11 Code of Ethics, Participation or Interest in Client Transactions,
and Personal Trading
A. Code of Ethics
We have adopted a Code of Ethics (“Code of Ethics”) pursuant to Rule 204A-1 under the Advisors
Act. Our Code of Ethics requires our IARs, employees and other associated persons to comply
with all applicable federal and state securities laws and establishes a high ethical standard of
business conduct to which we hold each of them. Certain other matters addressed in our Code
of Ethics include policies or procedures that address: (1) personal trading of securities by our
IARs, employees and access persons; (2) oversight of our IARs, employees and clients’ accounts;
(3) document and recordkeeping requirements; and (4) enforcement and the consequences of
noncompliance or violation of the Code of Ethics.
A copy of our Code of Ethics is available to our current and prospective clients. To request a copy,
contact us at (205) 982-5515 or compliance@eversourcewa.com.
As is disclosed in Item 5 of this Brochure, certain EverSource IARs may be appointed insurance
agents with various insurance companies. Please refer to Item 5 and Item 10 of this Brochure for
an explanation of these relationships and important conflict of interest disclosures.
B. Investing Personal Money in the Same Securities as Clients
EverSource has adopted a Personal Securities Transactions and Insider Trading Policy (“Personal
Securities Policy”) within its Code of Ethics. The Personal Securities Policy is designed to detect
and prevent conflicts of interest when persons covered by the policy trade securities which may
be traded for our clients.
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The Personal Securities Policy covers any account where persons covered by the policy has direct
or indirect ownership, influence, or control. We require preapproval for investing in private
placements and IPOs.
Investment Adviser Representatives and employees of EverSource who have access to client
accounts or investment recommendations (“Access Persons”) are required to provide a copy of
statements for all personal accounts that are covered by the Personal Securities Policy. These
accounts are then reviewed and added to our monitoring system.
C. Contemporaneous Trading and Trading in Securities Recommended to Clients
EverSource does not buy securities for its own account. Therefore, no potential conflict of
interest exists at the firm level.
Our firm or individuals associated with our firm do buy or sell for their personal accounts
securities identical to those recommended to or purchased for customers. In addition, any
related person may have an existing interest or position in a certain security which may also be
recommended to a client. This practice results in a potential conflict of interest, as we could have
an incentive to manipulate the timing of such purchases to obtain a better price or more
favorable allocation in rare cases of limited availability.
To mitigate these potential conflicts of interest and ensure the fulfillment of our fiduciary
responsibilities, we have established the following restrictions:
(1) No supervised person of our firm is allowed to buy or sell securities for their personal
portfolio(s) where their decision is substantially derived, in whole or in part, by reason of
his or her employment or association unless the information is also available to the
investing public on reasonable inquiry. No supervised person of our firm is allowed to
prefer his or her own interest to that of the advisory client;
(2) It is the express policy of our firm that no supervised person of our firm can purchase or
sell any security prior to a transaction being implemented for an advisory account, and
therefore, preventing such supervised persons from benefiting from transactions placed
on behalf of advisory accounts;
(3) We emphasize the unrestricted right of the client to decline to implement any advice
rendered;
(4) For financial planning, consulting, and pension/retirement benefit plan consulting clients
we emphasize the unrestricted right of the client to select and choose any broker-dealer
and/or insurance company he/she wishes; and
(5) All of our supervised persons must act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
Any supervised person not in observance of the above will be subject to disciplinary action,
including termination.
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Item 12 Brokerage Practices
A. Factors Considered in Selecting or Recommending Broker-Dealers
1. Research and Other Economic Benefits
For clients in need of brokerage or custodial services, and depending on client circumstances and
needs, EverSource will recommend the use of one of several broker-dealers, including Fidelity
Institutional (“Fidelity”) or Schwab Advisor Services, a division of Charles Schwab Corporation,
member FINRA/SIPC (“Schwab”). EverSource is independently owned and operated and is not
affiliated with Schwab or Fidelity. EverSource receives access to benefits from Fidelity and
Schwab, including institutional trading and custody services, that are generally not available to
retail investors.
These benefits may include: (1) access to a proprietary trading platforms and execution of trades;
(2) access to a dedicated trading desk serving program participants exclusively; (3) the ability to
have investment advisory fees deducted directly from a client’s account; (4) research and
compliance publications; (5) access to certain mutual funds which generally require significantly
higher minimum initial investments or that are available only to institutional investors, and (6)
invitations to education seminars provided online or at conferences. These economic benefits
are provided by Fidelity, and Schwab to independent advisors who custody client assets with
them on an unsolicited basis at no charge and are not generated by or tied to client brokerage
commissions.
Our clients do not pay brokerage commissions higher than those charged by other broker-dealers
as a result of our receipt of these benefits, and all clients benefit from these benefits. However,
participation in the programs described above does gives rise to a potential conflict of interest
for our firm, as the receipt of program benefits creates an incentive for us to recommend
program sponsors to clients for brokerage or custodial services.
We review the services of broker-dealers and recommend them based on a number of factors.
These factors include the professional services offered, commission rates, and the custodial
platform provided to clients. While, based on our business model, we will not seek to exercise
discretion to negotiate trades among various broker-dealers on behalf of clients, we will,
however, periodically review and attempt to negotiate lower commission rates for our clients
with them.
The final decision of where to custody assets is at the discretion of the client, including those
accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the
plan sponsor or IRA account holder. However, we reserve the right to decline acceptance of any
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client account for which the client directs the use of a broker-dealer if we believe that this choice
would hinder our firm’s fiduciary duty to the client or our ability to service the account.
2. Brokerage for Client Referrals
Neither EverSource nor any related party participates in any client referral programs with any
custodian or broker-dealer. EverSource’s client referral arrangements with third parties,
described in Item 14, are not in any way connected to or considered in selecting or
recommending a broker-dealer for a client account.
3. Directed Brokerage – Third-Party Managers and Programs
Third party managers may require prime brokerage arrangements for trading client accounts
which may impose an additional trading cost on client accounts. Our firm does not control or
benefit from the brokerage practices of any third-party manager or investment program. Clients
should be aware that participation in certain investment programs, including “wrap fee”
programs may be conditional on the use of a certain broker-dealer, often the sponsor of the
program. In such situations, best execution may not always be attained for program participants.
B. Trading-Order Aggregation
We will frequently but not always utilize block trading (i.e., trade aggregation) for client trades.
When we do not implement block trading, certain client trades may be executed before others
at a different price. If EverSource determines that aggregation of trades in a certain situation will
be beneficial to clients, transactions will be blocked to achieve an average price and will be
allocated among clients in proportion to the purchase and sale orders placed from each client
account on any given day.
Item 13 Review of Accounts
Investment Advisory Services
Reviews
For our clients who have an investment advisory relationship, their accounts are monitored on
an ongoing basis by their IAR. On at least an annual basis, IARs review client accounts’ current
asset allocation vs. target, recent investment activity, performance, and portfolio management
changes needed based on clients’ updated investment objectives and/or financial situation.
EverSource provides a daily investment dashboard and quarterly performance reports accessible
via the Black Diamond Client Portal for clients to review their own investment strategy and
performance.
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On at least an annual basis, meetings are held with (or at least offered to) clients to discuss
investment performance, objectives, and notable changes in a client’s financial situation. More
frequent non-periodic reviews can be triggered by changes in financial or life circumstances or
external market, economic, or political events.
Reports
In addition to the monthly statements and confirmations of transactions that clients receive from
their custodian or broker-dealer, we provide quarterly online reports summarizing account
performance, balances, and holdings. Paper statements will be provided at the request of the
client. Certain clients may receive additional or alternative reports, as contracted at the inception
of the advisory relationship.
Financial Planning Services
Clients that utilize the financial planning services provided by EverSource as a part of an ongoing
engagement can expect to have an annual review of their financial plans. The plan
recommendations will be reviewed in the context of each client’s goals and objectives. More
frequent non-periodic reviews can be triggered by changes in financial or life circumstances or
external market, economic, or political events. EverSource will provide reports, forecasts,
illustrations, or written descriptions in situations in which it is beneficial or upon a client’s
request.
Financial Planning clients will receive a completed financial plan either in hard copy form or via
digital access via a web-based portal for the initial financial plan as per the client engagement
letter. Additional reports will not typically be provided unless otherwise contracted.
Item 14 Client Referrals and Other Compensation
Economic Benefits for Providing Advice or Services to Clients
EverSource receives an economic benefit from custodians and broker dealers in the form of the
support products and services made available to EverSource in the same way they do for other
independent investment advisors that have their clients maintain accounts at these companies.
These products and services, how they benefit EverSource, and the related conflicts of interest
are described under Item 12 of this Brochure. The availability to EverSource of the custodians’ or
broker dealers’ products and services is not based on EverSource giving particular investment
advice, such as buying particular securities for clients or in exchange for client’s brokerage
commissions.
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EverSource may from time to time receive additional direct or indirect compensation from asset
managers, product sponsors, and vendors; such as reimbursement for travel and/or marketing
expenses, costs associated with EverSource employees and IARs attending various education or
training events, an occasional dinner or ticket to a sporting event, and/or other gifts. This may
include payments in connection with client workshops, marketing events or advertising
initiatives, including EverSource-sponsored conferences and events. Although receipt of these
gifts/reimbursements are not predicated upon specific sales, they are typically made in
anticipation that sales will be made. Clients should be aware that the receipt of economic
benefits by EverSource or its Associated Persons in and of itself creates a conflict of interest and
could influence EverSource’s choice of these various vendors. We address this conflict of interest
by recommending custodians, vendors, and products that we believe in good faith are
appropriate for the client’s particular needs.
Clients are under no obligation contractually or otherwise, to use any of the custodians, vendors,
and products recommended by us.
Client Referrals
In some situations, Eversource pays referral fees to EverSource’s supervised persons,
independent persons or other investment advisor firms (“Promoter”) for introducing clients to
EverSource. Whenever we pay a referral fee to anyone other than an EverSource supervised
person, we require the Promoter to provide the prospective client with a copy of this document
(our Firm Brochure) and a separate disclosure statement that includes the following information:
the Promoter’s name and relationship with our firm;
the fact that the Promoter is being paid a referral fee;
the amount of the fee; and
whether the fee paid to EverSource by the client will be increased above our normal
fees in order to compensate the Promoter.
As a matter of firm practice, the advisory fees paid to EverSource by clients referred by Promoters
are not increased as a result of any referral or referral fee paid to Promoters.
Payment of fees for the referral of prospective clients creates a potential conflict of interest to
the extent that such a referral to our firm is not unbiased and the Promoter is, at least partially,
motivated by financial gain. Therefore, such a referral could be made even if our advisory services
are not suitable to a particular client’s needs. We address this conflict of interest through making
the disclosures described above and carefully screening referred clients to ensure that our fees,
services, and investment strategies are suitable to their investment needs and objectives.
For certain retirement plans, EverSource has agreed to provide investment education to plan
participants, deliver documents provided by the plan sponsor, conduct initial and ongoing
enrollments, and undertake similar administrative support tasks on behalf of the plan sponsor
and fiduciaries engaged by the plan sponsor. Part of the compensation received for this service
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is considered a referral fee, and that arrangement is fully disclosed in the documents provided to
the plan sponsor.
EverSource has a relationship with Counsel Trust Company (“CTC”), a Tennessee-chartered trust
company, for the provision of corporate trust services to our clients. Trust services are provided
through a division of CTC operating, through a licensing agreement with EverSource and with the
approval of the Tennessee Department of Financial Institutions, as “EverSource Trust Services”.
In all marketing materials, presentations to clients, and client agreements, we make it clear that
the trust services will be provided by CTC and not by EverSource. We also disclose that CTC has
agreed to pay us fifteen percent (15%) of the revenue it receives from serving EverSource clients.
This presents a conflict of interest in that EverSource could refer clients to CTC because of the
resulting financial benefit to EverSource. We address this conflict of interest through disclosure,
due diligence of CTC, and communicating to clients that they can select a different corporate
trustee.
Referrals of Other Professionals
EverSource refers clients to other service professionals if requested or deemed necessary based
on the specific needs of the client. For example, EverSource may refer clients to legal counsel and
insurance agents or to BMSS, BMSS’ payroll company, Payroll & Benefit Solutions, and BMSS’ IT
Company, Abacus IT Solutions. It is possible that these professionals will make referrals of their
clients seeking investment advice to EverSource. However, EverSource does not pay for or
receive any compensation from these referrals.
Other Compensation
EverSource does not receive sales charges, securities commissions, service fees, 12b-1 fees or
other compensation from a non-client in connection with providing investment advice to a client.
Our supervised persons may receive additional compensation as described in Item 5 of this
Brochure. Please refer to Item 5 and Item 10 of this Brochure for a detailed explanation of these
relationships and important conflict of interest disclosures.
Item 15 Custody
Custody is defined as any legal or actual ability by EverSource to access client funds or securities.
Since all client funds and securities are maintained with a qualified custodian or, in the case of
some private assets, self-custodied by the client, we do not take physical possession of client
assets. However, under the current SEC rules, our firm is deemed to have constructive custody
of client assets because we are permitted in our agreement with the client to directly debit client
custodial accounts for advisory fees. Because the custodian does not calculate the amount of the
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fee to be deducted, it is important for clients to carefully review their custodial statements to
verify the accuracy of the calculation. In the quarterly reports available to clients through the
Black Diamond Wealth Platform, clients are urged to compare the account statements they
receive from the qualified custodian with those quarterly Clients should contact EverSource as
soon as possible if they believe that there may be an error or discrepancy in their statement.
EverSource does not accept authority to sign checks or otherwise disburse funds on behalf of
any advisory clients. However, certain clients have established asset transfer authorizations
which permit the qualified custodian to rely upon instructions from EverSource to transfer client
funds to third parties. According to SEC guidance, EverSource is considered to have custody of
those client assets subject to such a “standing letter of authorization” or “move money” form
(collectively “SLOAs”). EverSource works with the qualified custodian in these situations to
satisfy the SEC’s guidance with respect to SLOAs, including requiring clear and specific written
instructions from the client and ensuring the client has the ability to terminate or change the
instructions at any time.
Client funds invested in the pooled investment fund EverSource Capital Access Fund I, LLC are in
turn invested in the single private real estate fund described in the offering documents, except
for funds set aside to pay for third-party expenses, such as accounting charges. Those assets will
be held in accounts at a qualified custodian. However, because EverSource acts as the manager
of the Fund, we are deemed to have custody of those assets and are subject to the SEC’s related
custody rules. This requires that we obtain an annual audit of the Fund and provide clients with
written notification of any change in the affected accounts’ custodial arrangements.
Item 16 Investment Discretion
Clients may hire EverSource to provide discretionary asset management services. For clients
granting us discretionary authority, EverSource determines which securities and the amounts of
securities that are to be bought or sold for their account, we require that such authority be
granted in writing, typically in the executed Client Agreement. With respect to the use of third-
party managers, EverSource does not directly manage these client portfolios, or this portion of
these client assets. However, we monitor these managers as part of our ongoing third-party
manager review process. As such, the client generally grants us the authority to hire and fire the
selected registered investment advisor directly.
Discretionary investment authority granted to us may be delegated by us to selected third-party
managers with prior client consent.
Should the client wish to impose reasonable limitations on this discretionary authority, the
limitations shall be included in a written authority statement. Modifications must be submitted
by the client in writing and are subject to EverSource’s approval.
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Item 17 Voting of Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Clients will receive their
proxies and other solicitations directly from their custodian or transfer agent and retain sole
responsibility for voting.
Although our firm provides investment advisory services relative to client investment assets,
clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited
by issuers of securities beneficially owned by the client shall be voted; (2) making all elections
relative to any mergers, acquisitions, tender offers, bankruptcy proceedings, class actions or
other type events pertaining to the client’s investment assets; and (3) engaging with corporate
leadership to advocate for certain policies or actions.
Clients are responsible for instructing each custodian of the assets to forward to the client copies
of all proxies and shareholder communications relating to the client’s investment assets.
However, third-party asset managers may vote proxies, engage with company leaders, and/or
evaluate class actions relative to the client’s assets. In the event we engage a subadvisor to
manage a client’s account who requests that authority, the client has granted us the ability to
delegate that authority to the subadvisor.
Item 18 Financial Information
A. EverSource’s Balance Sheet
Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client six
(6) months or more in advance. Therefore, we are not required to include a financial statement.
EverSource has no financial condition that impairs our ability to meet our contractual obligations
to our clients and has never been the subject of a bankruptcy proceeding.
B. Financial Conditions Likely to Impair EverSource’s Ability to Meet Client Commitments
We have nothing to disclose in this regard.
C. Bankruptcy Petitions
We have nothing to disclose in this regard.
[END OF PART 2A OF FORM ADV]
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