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Evolve Private Wealth, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: January 29, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of Evolve Private Wealth, LLC (“Evolve” or the “Advisor”). If you have any questions about the content of this
Disclosure Brochure, please contact the Advisor at (424) 500-4601.
Evolve is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information about Evolve to assist you in determining whether to retain the Advisor.
information about Evolve and
its Advisory Persons
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 333932.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
https://evolvepw.com/
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Evolve.
Evolve believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. Evolve encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
The following material changes have been made to this disclosure brochure since the initial filing and delivery to
Clients:
● Effective January 14th, 2026, the Advisor has appointed Razmig Der-Tavitian as Chief Compliance Officer
● The Advisor serves as the investment manager to pooled investment vehicles. Please see Items 4, 5, 7, 8,
12, 13, and 15 for additional information.
● The Advisor may recommend Clients utilize non-purpose loan programs. Please see Items 4 and 8 for
additional information
● The Advisor’s phone number is now (424) 500-4601.
● Effective January 1, 2026, the Advisor has updated its name to Evolve Private Wealth, LLC.
● Evolve Wealth Insurance LLC is an affiliated insurance company. Please see item 10 for additional
information.
● The Advisor has established an institutional relationship with Charles Schwab & Co., Inc. (“Schwab”). Please
see items 12 and 14 for additional information.
● The Advisor may assume proxy voting responsibility for Clients. Please see item 17 for additional information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes
in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure
or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 333932. You may also
request a copy of this Disclosure Brochure at any time by contacting the Advisor at (424) 500-4601.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
Page 2
https://evolvepw.com/
Item 3 – Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
1
2Item 3 – Table of Contents
2Item 4 – Advisory Services
4A. Firm Information
4B. Advisory Services Offered
4C. Client Account Management
6D. Wrap Fee Programs
7E. Assets Under Management
7Item 5 – Fees and Compensation
7A. Fees for Advisory Services
7B. Fee Billing
8C. Other Fees and Expenses
9D. Advance Payment of Fees and Termination
9E. Compensation for Sales of Securities
10Item 6 – Performance-Based Fees and Side-By-Side Management
10Item 7 – Types of Clients
11Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
11A. Methods of Analysis
11B. Risk of Loss
11Item 9 – Disciplinary Information
13Item 10 – Other Financial Industry Activities and Affiliations
13Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
13A. Code of Ethics
13B. Personal Trading with Material Interest
14C. Personal Trading in Same Securities as Clients
14D. Personal Trading at Same Time as Client
14Item 12 – Brokerage Practices
14A. Recommendation of Custodian[s]
14B. Aggregating and Allocating Trades
15Item 13 – Review of Accounts
15A. Frequency of Reviews
15B. Causes for Reviews
15C. Review Reports
15Item 14 – Client Referrals and Other Compensation
16A. Compensation Received by Evolve
16B. Compensation for Client Referrals
17Item 15 – Custody
17Item 16 – Investment Discretion
17Item 17 – Voting Client Securities
17Item 18 – Financial Information
18Privacy Policy
19
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
Page 3
https://evolvepw.com/
Item 4 – Advisory Services
A. Firm Information
Evolve Private Wealth, LLC (“Evolve” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State
of Delaware. Evolve was founded in September 2022 and became an independent registered investment advisor in
January 2025. Evolve is a wholly owned subsidiary of Evolve Wealth Holdings, LLC and is operated by Glen Strauss
(Founder & Managing Partner), Jonathan Lewis (Founder & Managing Partner), Edward Kahn (Founder & Managing
Partner), Razmig Der Tavitian (Chief Investment Officer, Chief Compliance Officer & Managing Partner), Adam
Weinstock (Managing Partner), and Hank Krakover (Partner & Portfolio Manager). This Disclosure Brochure provides
information regarding the qualifications, business practices, and the advisory services provided by Evolve.
B. Advisory Services Offered
Evolve offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, financial institutions, and pooled investment vehicles (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts
of interest. Evolve's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading.
Wealth Management Services
Evolve provides customized wealth management services for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary and non-discretionary investment management
services and a broad range of comprehensive financial planning. These services are listed below.
Investment Management Services – The Advisor provides discretionary and non-discretionary investment
management services. The Advisor works closely with each Client to identify their investment goals, objectives, risk
tolerance and financial situation in order to create a portfolio strategy. Evolve will then construct an investment
portfolio, consisting of low-cost, diversified mutual funds, exchange-traded funds (“ETFs”), individual stocks, and/or
bonds to achieve the Client’s investment goals. The Advisor may also utilize independent managers, options and
alternative investments to meet the needs of its Clients. The Advisor may retain Client’s legacy investments based
on portfolio fit and/or tax considerations.
The Advisor ’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market conditions.
The Advisor will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable
restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
The Advisor evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. The Advisor may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. The Advisor may recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a possible hedge against market movement. The Advisor may
recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses,
business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the
position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
Page 4
https://evolvepw.com/
advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a
recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a
result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by
the Advisor.
Use of Independent Managers – When deemed to be in the Client’s best interest, Evolve will recommend that Clients
utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”)
for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In certain instances,
the Client may be required to authorize and enter into an investment management agreement with the Independent
Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. The Advisor will
perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy
remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client
in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client,
prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's
Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Non-Purpose Loans – When deemed to be in the Client’s best interest, the Advisor will introduce Clients to available
to non-purpose loan programs (“Lending Program”). In such instances, the Client’s assets in their account[s] at the
Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a Lending Program presents
a conflict of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized
assets in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For
additional information related to the risks involved non-purpose loans, please see Item 8 – Methods of Analysis,
Investment Strategies and Risk of Loss.
At no time will the Advisor accept or maintain custody of a Client’s funds or securities, except for the limited authority
as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services – The Advisor provides a variety of financial planning and consulting services to Clients
as part of its wealth management services. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. Generally, such financial planning services involve preparing a formal
financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This
planning or consulting may encompass one or more areas of need, including but not limited to, investment planning,
retirement planning, personal savings, education savings, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations
may be made that the Client start or revise their investment programs, commence or alter retirement savings,
establish education savings and/or charitable giving programs.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients increase the level of
investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are
not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the
Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no
obligation to implement the transaction through the Advisor.
Private Fund Services
The Advisor also serves as an investment manager to pooled investment vehicles (each a “Fund” and collectively the
“Funds”). These services are detailed in the offering documents for the Funds, which include as applicable, operating
agreements, private placement memorandum and/or term sheets, subscription agreements, separate disclosure
documents, and all amendments thereto (“Offering Documents”).
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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https://evolvepw.com/
The Advisor manages the Funds based on the investment objectives, policies and guidelines as set forth in the
respective Offering Documents and not in accordance with the individual needs or objectives of any particular investor
therein. Each prospective investor (herein “Investors”) interested in investing in the Funds is required to complete a
subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets
the qualifications to invest in the Funds and further acknowledges and accepts the various risk factors associated
with such an investment.
Please note, there are two different classes of interests for Investors in the Fund. “Advisory Class” is available for
subscription by eligible Investors who are existing Clients of the Advisor, while the “Non-Advisory Class” is available
for subscription by eligible Investors who are not advisory clients of the Advisor.
The Advisor will recommend that certain Clients invest in the Funds. The recommendation to invest in the Funds
poses a conflict between the interests of the Advisor and the interests of the Client, as the Advisor is incentivized to
increase the amount of assets in the Funds in order to increase the revenue generated to the Advisor. To mitigate
this conflict Advisory Class Investors will not be assessed any fund management fees. Clients of the Advisor are
under no obligation to invest in the Funds. Please see Item 5 for additional information.
For more detailed information on investment objectives, policies and guidelines, please refer to the
respective Fund’s Offering Documents.
Financial Institution Consulting Services
Evolve provides investment consulting services to brokerage customers (herein “Brokerage Customers”) of Mutual
Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s consulting services,
pursuant to a written agreement with the Advisor. Consulting services are strictly on products Clients have purchased
through Mutual Securities, Inc. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional
details.
Retirement Plan Advisory Services
The Advisor provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and
the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to
the needs of the Plan and Plan Sponsor. Services generally include:
Investment Policy Statement (“IPS”) Design and Monitoring
● Vendor Analysis
● Plan Participant Enrollment and Education Tracking
●
● Ongoing Investment Recommendation and Assistance
● Performance Reports
● ERISA 404(c) Assistance
● Benchmarking Services
These services are provided by the Advisor serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor
is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered and all
direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Evolve to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
● Establishing an Investment Strategy – Evolve, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
Page 6
https://evolvepw.com/
● Asset Allocation – Evolve will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – Evolve will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
●
Investment Management and Supervision – Evolve will provide wealth management and ongoing oversight
of the Client’s investment portfolio.
D. Wrap Fee Programs
Evolve does not manage or place Client assets into a wrap fee program. Wealth management services are provided
directly by Evolve.
E. Assets Under Management
As of December 31, 2025, Evolve manages $2,147,950,288 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more
written agreements with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid monthly, in advance of each month pursuant to the terms of the wealth
management agreement. Wealth management fees are based on the market value of assets under management at
the end of the prior month. Wealth management fees range up to 1.50% annually based on several factors, including:
the scope and complexity of the services to be provided; the level of assets to be managed; and the overall
relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio
restrictions and other complexities may be charged a higher fee.
The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the
end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
Evolve will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.
Use of Independent Managers – As noted in Item 4, the Advisor may allocate all or a portion of a Client’s investment
portfolio to one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not receive
any compensation from an Independent Manager and earns only its wealth management fee as described above.
For dual contract arrangements, the Independent Manager’s fee is disclosed in its brochure and applicable agreement
with the Client. In single contract engagements, the fee terms are outlined in the executed agreement between the
Advisor and the Independent Manager. Clients will receive an addendum specifying the Independent Manager’s fee.
The total blended fee, including both the Advisor’s and the Independent Manager’s fees, will not exceed 3.00%
annually
Private Fund Services
The Advisor will charge the Fund an annual fee ranging up to 0.70% depending on the Investor Class and pursuant to
the terms of the Fund’s Offering Documents. Non advisory client Investors will also be subject to carried interest as
outlined in Item 6 below.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
Page 7
https://evolvepw.com/
The investment management fee shall accrue beginning on the initial closing date and will be payable quarterly in
advance, calculated as of the commencement of such quarter (or as of the initial closing date in the event of the first
period) on the last business day preceding each investment management fee payment date, with the first such
payment due and payable as of the initial closing date. Investors should refer the respective Fund’s Offering
Documents for more detailed information on advisory fees.
Financial Institution Consulting Services
Evolve receives a consulting fee based on the assets under MSI’s management from Brokerage Customers who
have provided written consent to MSI to receive the consulting service from the Advisor. The consulting fee is
calculated from the assets under MSI’s management as of the end of a calendar quarter period multiplied by the
annualized rate of 0.65%. The initial fee is paid only after the completion of one full calendar quarter period following
the date of the executed agreement with MSI.
Retirement Plan Advisory Services
Retirement plan advisory fees are charged an annual asset-based fee of up to 1.50%. Fees may be billed monthly
or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan advisory agreement.
Retirement plan fees are based on the market value of assets under management at the end of the Billing Period.
Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated
above.
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the beginning of the respective month. The amount due is calculated by applying the
monthly rate (annual rate divided by 12) to the total assets under management with Evolve at the end of the prior
month. Clients may make additions to and withdrawals from their account[s] at any time. However, reconciliations
are performed on a monthly basis to capture if, at any point, assets greater than or equal to $10,000 are deposited
into or withdrawn from an account after the start of the monthly billing period. An adjustment will be made in the form
of a credit or debit the following billing period to reflect the interim change in portfolio value from the date of the
deposit/withdrawal until the end of the month. Clients will be provided with a statement, at least quarterly, from the
Custodian reflecting deduction of the wealth management fee. Clients are urged to review the brokerage statement
from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization
permitting advisory fees to be deducted by Evolve to be paid directly from their account[s] held by the Custodian as
part of the wealth management agreement and separate account forms provided by the Custodian.
Use of Independent Managers – For Client accounts managed by an Independent Manager, the total fees may
include Evolve’s wealth management fee (as noted above), along with any investment management and/or platform
fees charged by the Independent Manager(s), as applicable. In certain cases, either the Independent Manager or the
Advisor may be responsible for calculating the Client’s fees and deducting all applicable fees directly from the Client’s
account(s).
Private Fund Services
The investment management fee shall accrue beginning on the initial closing date and will be payable quarterly in
advance, calculated as of the commencement of such quarter (or as of the initial closing date in the event of the first
period) on the last business day preceding each investment management fee payment date, with the first such
payment due and payable as of the initial closing date. The fee shall be paid from each Investors capital account
based on a proportionate share of the investment management fee. Investors should refer the respective Fund’s
Offering Documents for more detailed information on fee billing methodology.
Financial Institution Consulting Services
MSI shall calculate and pay the Advisor for its consulting services on or before thirty (30) days past the end of each
calendar quarter.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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https://evolvepw.com/
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Evolve, in connection with investments
made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees
charged by the Custodian, as applicable. The Advisor's recommended Custodian typically does not charge securities
transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and
conditions of the Custodian's brokerage requirements. However, Clients who elect to receive paper statements from
Fidelity are subject to third-party charges, which include securities transaction fees for ETF and equity trades. The
Custodian will also typically charge for mutual funds and other types of investments. The fees charged by Evolve are
separate and distinct from these custody and execution fees.
In addition, all fees paid to Evolve for wealth management services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. A Client may be able to invest in these products directly, without the services of Evolve, but would
not receive the services provided by Evolve which are designed, among other things, to assist the Client in
determining which products or services are most appropriate for each Client’s financial situation and objectives.
Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Evolve to fully
understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
Private Fund Services
Each Fund is responsible for paying its own expenses, which include but are not limited to tax, litigation,
indemnification, and other extraordinary expenses, as well as for all operating expenses of the Fund. Notwithstanding
the foregoing, any fees and expenses may be allocated to, and borne by, each Investor based on its percentage
interest, provided, that, any such expenses may be allocated to, and borne by the Investors in such manner as the
general partner determines in its sole discretion to be appropriate under the circumstances. Investors should refer
the respective Fund’s Offering Documents for more detailed information on other fees expenses.
D. Advance Payment of Fees and Termination
Wealth Management Services
Evolve is compensated for its wealth management services in advance of the month in which services are rendered.
Either party may terminate the wealth management agreement, at any time, by providing advance written notice to
the other party. The Client may also terminate the wealth management agreement within five (5) business days of
signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for
bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client.
Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the effective date of
termination to the end of the month. The Client’s wealth management agreement with the Advisor is non-transferable
without the Client’s prior consent.
Use of Independent Managers – If the Advisor determines that an Independent Manager is no longer in the Client’s
best interest, or if the Client wishes to terminate their relationship with the Independent Manager, the termination
terms will be governed by the applicable agreements. In a dual contract arrangement, the terms will be outlined in
the agreement between the Client and the Independent Manager, whereas in a single contract engagement, they will
be specified in the agreement between the Advisor and the Independent Manager. Evolve will assist the Client with
the termination and transition process as appropriate.
Private Fund Services
Evolve is compensated for its private fund services in advance of the quarter in which services are rendered. Either
party may request to terminate the Fund’s management agreement, at any time, by providing ninety (90) days
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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https://evolvepw.com/
advance written notice to the other party. The Funds shall be responsible for fees up to and including the effective
date of termination. The Fund’s agreement with the Advisor is non-transferable without the Fund’s prior consent.
Investors should refer to the Offering Documents for more detailed information on the withdrawal and
termination process.
Financial Institution Consulting Services
Either party may terminate the consulting agreement by providing thirty (30) days advance written notice to the other
party. The Advisor will be entitled to fees up to the date of termination.
Retirement Plan Advisory Services
The Advisor may be compensated for its services at the beginning of the Billing Period before services are rendered
pursuant to the terms of the retirement plan advisory agreement. Either party may request to terminate a retirement
plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be
responsible for fees up to and including the effective date of termination. If the fees are billed in advance, the Advisor
will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of
the Billing Period. The Client’s retirement plan services agreement with the Advisor is non-transferable without the
Client’s prior consent.
E. Compensation for Sales of Securities
Evolve does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the wealth management fees noted above.
Insurance Agency Affiliation
Evolve is also a licensed insurance agency and certain Advisory Persons are licensed as insurance professionals.
Evolve may earn commission-based compensation for selling insurance products, including insurance products sold
to Clients. Insurance commissions earned by Evolve is separate and in addition to advisory fees. This practice
presents a conflict of interest as Advisory Persons and members of Evolve’s management have an incentive to
recommend insurance products for the purpose of generating commissions and revenue rather than solely based on
Client needs. Evolve will never earn both a commission and an ongoing advisory fee on the same assets. Additionally,
Clients are under no obligation to purchase insurance products through any Advisory Person or Evolve. Please see
Item 10 – Other Financial Industry Activities and Affiliations.
Item 6 – Performance-Based Fees and Side-By-Side Management
The Advisor may be entitled to receive performance-based compensation in the form of Carried Interest through its
Private Fund Services. The fact that the Advisor may receive performance-based compensation creates a conflict of
interest in that it creates an incentive for the Advisor to make investments on behalf of the Funds that are riskier or
more speculative than would otherwise be the case in the absence of such performance-based compensation
arrangements. To mitigate the conflicts, the performance-based fees are structured so that certain performance
hurdles must be met in order to receive the fee. In addition, the Offering Documents contain disclosures regarding
the amount of fees and how they are calculated. Importantly, as part of the Advisor’s fiduciary duty, the Advisor must
act in the best interest of the Funds.
Regarding side-by-side management, the Advisor receives different types of fees, such as asset-based and
performance-based fees. Managing Clients that are charged different types of fees creates conflicts of interest
between the Advisor and its Clients, in addition to the ones listed above. For example, charging performance-based
fees could incentivize the Advisor to allocate more favorable investments to those Clients being charged a
performance-based fee. The Advisor has adopted and implemented policies and procedures intended to address
conflicts of interest relating to the management of multiple types of Clients, including Clients with multiple fee
arrangements, and the allocation of investment opportunities.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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https://evolvepw.com/
Item 7 – Types of Clients
Evolve offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, financial institutions and pooled investment vehicles. Evolve generally does not impose a minimum
relationship size.
Private Fund Services
The Funds require that all investors meet the definition of “accredited investors”, and also require investors to be
“qualified purchasers” within the meaning of Section 2(a)(51) of the Investment Company Act of 1940 Act. The Funds
generally require a minimum investment in the amount of $100,000.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Evolve primarily employs fundamental analysis methods in developing investment strategies for its Clients. Research
and analysis from Evolve are derived from numerous sources, including financial media companies, third-party
research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press
releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists
generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed.
Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value
discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does
not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the
fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these
economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
As noted above, Evolve generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. Evolve will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Evolve may also
buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals
of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. Evolve will assist Clients in determining an appropriate strategy based
on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their
investment goals.
While the methods of analysis help the Advisor 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 Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will
fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based
on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread
and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from
the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point
in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate
of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was
previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds
the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated
with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment
obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk
that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are
leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This
leverage can compound gains or losses.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Non-Purpose Loans
Non-Purpose Loans carry a number of risks, including but not limited to the risk of a market downturn, tax implications
if collateralized securities are liquidated, and an increase in interest rates. A decline in the market value of
collateralized assets held in the account[s] at the Custodian, may result in a reduction in the draw amount of the
Client’s loan, a demand from the Lending Program that the Client deposit additional funds or securities in the Client’s
collateral account[s], or a forced sale of securities in the Client’s collateral account[s].
Private Fund Risks
Private investment funds are not registered under the Investment Company Act of 1940 and are therefore not subject
to the regulatory requirements it imposes. An investment in a private fund involves risks not typically associated with
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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traditional investment funds. These risks include limitations on transfers, valuation of the underlying investments and
transparency with respect to the fund’s underlying investments. These funds are not readily marketable and have
limited liquidity.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Evolve or its management persons. Evolve
values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence
on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are
available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the
Advisor’s firm name or CRD# 333932.
Item 10 – Other Financial Industry Activities and Affiliations
Evolve Wealth Insurance LLC
The Adviser is affiliated through common ownership and control with Evolve Wealth Insurance LLC (“Evolve Wealth
Insurance”). Evolve Wealth Insurance is a licensed insurance company and offers access to various life and health
insurance policies. When deemed to be in the Client’s best interest, the Advisor will recommend that Clients engage
Evolve Wealth Insurance for their insurance needs. Due to the affiliation between Evolve and Evolve Wealth
Insurance, owners and management persons have an incentive to recommend Evolve Wealth Insurance to Clients
as they will benefit financially in their individual capacity if Clients implement commissionable insurance products
through Evolve Wealth Insurance. There is no requirement for the Advisor to recommend Evolve Wealth Insurance,
nor are Clients obligated to engage with Evolve Wealth Insurance in order to be/remain a Client with Evolve.
Financial Institution and Consulting Services
Evolve has an agreement with MSI to provide investment consulting services to Brokerage Customers, as noted in
Item 4 – Advisory Services above. MSI compensates Evolve for providing consulting services to Clients who have
purchased products through MSI. This consulting arrangement does not include assuming discretionary authority
over Brokerage Customers’ brokerage accounts or the monitoring of securities. These consulting services offered to
Brokerage Customers includes a general review of Brokerage Customers’ investment holdings, which will result in
Evolve’ Advisory Persons making specific securities recommendations or offering general investment advice. This
relationship presents conflicts of interest. Conflicts are mitigated by Brokerage Customers consenting to receive
consulting services from the Advisor. In addition, Evolve will not accept or bill for additional compensation on asset
under MSI’s management, beyond the consulting fees disclosed in Item 5 above. Advisory Persons of the Advisor
will not engage or hold itself as a registered representative of MSI, as Advisory Persons are not registered to conduct
commission-based activities under a broker-dealer.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Evolve has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client.
This Code applies to all persons associated with Evolve (“Supervised Persons”). The Code was developed to provide
general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Evolve and its
Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Evolve’s
Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that
guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request
a copy of the Code, please contact the Advisor at (424) 500-4601.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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B. Personal Trading with Material Interest
Evolve allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Evolve does not act as principal in any transactions. In addition, the Advisor does not
act as the general partner of a fund, or advise an investment company. However, Evolve does serve as an investment
manager to the Funds as noted in Item 4 above.
C. Personal Trading in Same Securities as Clients
Evolve allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated
by Evolve requiring reporting of personal securities trades by its Supervised Persons for review by the Chief
Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the
misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Evolve allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no
time will Evolve, or any Supervised Person of Evolve, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Evolve does not have discretionary authority to select the broker-dealer/custodian for custody and execution services.
The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize
Evolve to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, Evolve does
not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis.
Where Evolve does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the
Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Evolve.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged.
Evolve may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions
charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s
offices.
Evolve will generally recommend that Clients establish their account[s] with Fidelity Clearing & Custody Solutions
and related entities of Fidelity Investments, Inc. (collectively “Fidelity”) or Charles Schwab & Co., Inc. (“Schwab”),
both FINRA-registered broker-dealer and member SIPC. Evolve has established an institutional relationship with
Fidelity and Schwab to serve as the Client’s “qualified custodian” and assist the Advisor in managing Client
account[s]. Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters
into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other
services. Evolve does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see
Item 14 below.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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2. Brokerage Referrals - Evolve does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Evolve will place trades
within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded
within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security
from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security
into one Client account from another Client’s account[s]). Evolve will not be obligated to select competitive bids on
securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs
are determined by the Custodian.
Private Fund Advisor
As an investment advisor to the Funds, the Advisor does not typically engage in active trading of publicly traded
securities. When, on occasion, the Advisor or the Funds transact in publicly traded securities, the Advisor will seek
to facilitate such transactions through the retention of broker-dealer/custodian for custody and execution services.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. Evolve will execute its transactions through the Custodian as
authorized by the Client. Evolve may aggregate orders in a block trade or trades when securities are purchased or
sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be
executed in full at the same price or time, the securities actually purchased or sold by the close of each business day
must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be
done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Private Fund Advisor
To the extent that more than one investment opportunity is suitable for multiple Funds, the Advisor will seek to allocate
the opportunity in a manner that is fair and equitable to each Fund in accordance with the Offering Documents.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Evolve. Formal
reviews are generally conducted at least annually or more frequently depending on the needs of the Client.
Private Fund Advisor
The investments made by the Funds are generally private, illiquid and long-term in nature. Accordingly, the review
process is not directed toward a short-term decision to dispose of securities. However, the Advisor closely monitors
companies in which the Funds invest, and periodically checks to confirm that the Funds are maintained in accordance
with its stated objectives as outlined in the Offering Documents.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually.
Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major
changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify Evolve if changes occur in the Client’s
personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be
triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements
are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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website so that the Client may view these reports and their account activity. Client brokerage statements will include
all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with
periodic reports regarding their holdings, allocations, and performance.
Private Fund Advisor
Investors in the Funds will receive audited financial statements no less than annually. The Advisor may also provide
Investors with periodic reports regarding the respective Private Fund’s holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Evolve
Evolve may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate
planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Evolve may receive
non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform – Fidelity
As noted in item 12, Evolve has established an institutional relationship with Fidelity to assist the Advisor in managing
Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to
the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from
independent research companies. The Advisor may also receive additional services and support from Fidelity. As a
result of receiving such services for no additional cost, the Advisor has an incentive to continue to use or expand the
use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the
relationship with Fidelity and has determined that the relationship with Fidelity remains in the best interests of the
Advisor’s Clients in connection with its fiduciary obligations, including its duty to seek best execution. Please see Item
12 above.
The Advisor receives access to software, vendors, and related support without cost or at a discount because the
Advisor renders wealth management services to Clients that maintain assets at Fidelity The software and related
systems support benefit the Advisor and indirectly benefit the Clients. However, all services provided may not be
utilized for all Clients.
Further, Fidelity has provided the Advisor with financial support (further details of the financial support received will
be provided upon request) in connection with the initial launch and early operations of the Advisor’s business. Fidelity
provided this financial support due to the level of Client assets expected to be transitioned to the Fidelity custodial
platform. The Advisor is not obligated to trade in the Client’s accounts to receive these benefits and does not receive
higher compensation from effecting transactions in a Client’s account[s]. The Advisor is authorized to use the financial
support received from Fidelity for certain start-up, technology and transition costs. For instance, the financial support
was utilized to cover account transfer fees charged by the Client’s former custodian when transitioning to Fidelity.
The financial support has also been used to obtain technology and other support services that directly benefit the
Advisor and may benefit the Client indirectly.
In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients
should be aware, however, that the receipt of these economic benefits from Fidelity creates a conflict of interest as
these economic benefits may influence the Advisor's recommendation of Fidelity as a Custodian over another
custodian that does not furnish similar software, systems, back-office support, financial support, and/or other
economic benefits. Notwithstanding the conflicts noted herein, the Advisor firmly believes that Fidelity provides the
Client and the Advisor with excellent value and support.
Participation in Institutional Advisor Platform - Schwab
The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like the Advisor. As a registered investment
advisor participating on the Schwab Advisor Services platform, the Advisor receives access to software and related
support without cost because the Advisor renders investment management services to Clients that maintain assets
at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put
the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a
custodian creates a conflict of interest since these benefits can influence the Advisor's recommendation of Schwab
over a custodian that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to the Advisor that may not benefit
the Client, including: educational conferences and events, consulting services and discounts for various service
providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results
in a potential conflict of interest. The Advisor believes, however, that the selection of Schwab as Custodian is in the
best interests of its Clients.
B. Compensation for Client Referrals
Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and
receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate
the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities
requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the
Advisor, and shall not result in any additional charge to the Client.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have
custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have
adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions.
As the investment manager to the Funds, the Advisor is deemed to have custody over Client securities. As such, an
independent public accountant conducts an annual audit of the pooled investment vehicles that are managed by the
Advisor and the audited financial statements are distributed to the investors in the pools within 180 days of fiscal year
end.
Item 16 – Investment Discretion
Evolve generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Evolve.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such
authority. All discretionary trades made by Evolve will be in accordance with each Client's investment objectives and
goals. If a Client enters into a non-discretionary arrangement, Evolve will not have discretion over the selection and
amount of securities to be bought or sold in Client accounts and will be required to obtain prior approval from the
Client prior to executing trades or allocating investment assets.
Item 17 – Voting Client Securities
Evolve may assume the authority for proxy voting, pursuant to the terms of the Client’s agreement with the Advisor
and the account set up at the Custodian. The Client shall typically maintain exclusive responsibility for all legal
proceedings or other type events pertaining to the account assets, including, but not limited to, class action lawsuits.
The Advisor shall vote proxies and to do so in the best interest of its Clients. Any material conflicts of interest between
the Advisor’s interests and those of our Clients with regard to proxy voting must be resolved before proxies are voted.
The Advisor subscribes to a nationally-recognized proxy monitor and voting agent service and will follow the
recommendations offered by that service. Clients may request a copy of the Advisor’s written policies and procedures
regarding proxy voting and/or information on how particular proxies were voted by contacting the Advisor’s CCO.
Item 18 – Financial Information
Neither Evolve, nor its management, have any adverse financial situations that would reasonably impair the ability of
Evolve to meet all obligations to its Clients. Neither Evolve, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. Evolve is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or
more in the future.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
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https://evolvepw.com/
Privacy Policy
Effective: January 29, 2026
Our Commitment to You
Evolve Private Wealth, LLC (“Evolve” or the “Advisor”) 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 here in
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. Evolve (also referred to as "we", "our" and "us”)
protects the security and confidentiality of the personal information we have and implements controls to ensure that
such information is used for proper business purposes in connection with the management or servicing of our
relationship with you.
Evolve 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 are set forth
in this Policy.
Why 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
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other 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 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.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
Page 19
https://evolvepw.com/
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
to: processing
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide agreed
upon services to you, consistent with applicable law, including but not
limited
transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
No
Not Shared
Marketing Purposes
Evolve does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with financial
institutions where you are a customer and where Evolve 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
Authorized Users
Your non-public personal information may be disclosed to you and persons
that we believe to be your authorized agent[s] or representative[s].
No
Not Shared
Information About Former Clients
Evolve does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
State-specific Regulations
California
In response to a California law, to be conservative, we assume accounts with California addresses do not want us to disclose
personal information about you to non-affiliated third parties, except as permitted by California law. We also limit the sharing
of personal information about you with our affiliates to ensure compliance with California privacy laws.
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 (424) 500-4601.
Evolve Private Wealth, LLC
10877 Wilshire Boulevard, Suite 1406, Los Angeles, CA 90024
Phone: (424) 500-4601
Page 20
https://evolvepw.com/