Overview
- Headquarters
- The Woodlands, TX
- Total Firm Assets
- $549 million
- Average High-Net-Worth Client Portfolio Size
- $3.9 million
Fee Structure
Primary Fee Schedule (ADV FORM 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $2,000,000 | 1.00% |
| $2,000,001 | $10,000,000 | 0.60% |
| $10,000,001 | and above | 0.40% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $38,000 | 0.76% |
| $10 million | $68,000 | 0.68% |
| $50 million | $228,000 | 0.46% |
| $100 million | $428,000 | 0.43% |
Clients
- High-Net-Worth Share of Firm Assets
- 92.61%
- Number of High-Net-Worth Clients
- 130
- Total Client Accounts
- 231
- Discretionary Accounts
- 231
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 112486
Additional Brochure: ADV 07/01/2026 (2026-07-23)
View Document Text
Part 2A of Form ADV:
Firm Brochure
9303 New Trails Drive
Suite 450
The Woodlands, TX 77381
Telephone: 281-364-0606
Email:cj@iaswealth.com
Web Address: www.iaswealth.com
07/01/2026
This brochure provides information about the qualifications and business practices of
IAS Wealth Management, Inc. If you have any questions about the contents of this
brochure, please contact us at 281-364-0606 or cj@iaswealth.com. The information in
this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about IAS Wealth Management, Inc. also is available on the
SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. Our Firm's CRD number is 112486.
Item 2 Material Changes
This Firm Brochure, dated 07/01/2026, provides you with a summary of IAS Wealth Management,
Inc. advisory services fees, professionals, certain business practices and policies, as well as actual or
potential conflicts of interest, among other things. This brochure is used to provide our clients with a
summary of new and/or updated information and any revision(s) based on the nature of the
information as follows.
1. Annual Update: We are required to update certain information at least annually, within
90 days of our Firm’s fiscal year end (FYE) of December 31.
2. Material Changes: Should a material change in our operations occur, depending on its nature
we will promptly communicate this change to our clients (and it will be summarized in this
Item). "Material changes" requiring prompt notification will include changes of ownership or
control; location; disciplinary proceedings; significant changes to our advisory services or
advisory affiliates – any information that is critical to a client’s full understanding of who we
are, how to find us, and how we do business.
This Brochure does include a number of minor editorial changes and the updated information on our
assets under management.
Currently, our Brochure may be requested free of charge by contacting CJ Haynes, Chief Compliance
Officer.
Contact Information:
CJ Haynes
Chief Compliance Officer
Email: cj@iaswealth.com
Phone: 281-364-0606
Address: 9303 New Trails Drive, Suite 450
The Woodlands, TX 77381
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Item 3
Table of Contents
Page
Item 1
Cover Page
1
Item 2
Material Changes
2
Item 3
Table of Contents
3
Item 4
Advisory Business
4
Item 5
Fees and Compensation
6
Item 6
Performance Based Fees and Side By Side Management
9
Item 7
Types of Clients
9
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
9
Disciplinary Information
Item 9
Item 10 Other Financial Industry Activities and Affiliations
11
11
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
11
Item 12
Brokerage Practices
12
Item 13
Review of Accounts
13
Item 14
Client Referrals and Other Compensation
13
Item 15
Custody
13
Item 16
Investment Discretion
14
Item 17 Voting Client Securities
14
Item 18
Financial Information
15
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Item 4 Advisory Business
IAS Wealth Management, Inc. ("IAS") is an SEC-registered investment adviser with its principal
place of business in The Woodlands, Texas. Founded in 1994 by John Lester Haynes, IAS is a
privately owned advisory firm. Effective July 1, 2026, Henry A. Stevens and Jason Henry became
equity owners of the firm alongside founder, and majority shareholder, John Lester Haynes.
The officers of IAS Wealth Management, Inc. are: John L. Haynes, Chairman; Henry A. Stevens,
President; CJ Haynes, Chief Compliance Officer and Vice President; Curt E. Beck, Secretary,
Treasurer, and Vice President; and Jason Henry, Vice President.
As a fiduciary, IAS provides financial planning and investment advisory services to clients on a
consolidated fee-only basis.
As part of our team approach, services are provided utilizing the expertise of team members,
assuring our clients will have the opportunity of a long-term relationship with the advisors and the
Firm.
Through personal discussions with you, we listen carefully to gain a thorough understanding of your
unique goals and objectives based on your particular circumstances. As appropriate, we also review
and discuss a your prior investment history, as well as family composition and background. We
work with you, utilizing various tools and conversations to determine the best approach for you. As
part of the advisory process we work with each client to answer the following three questions:
Where are you now? Where do you want to be? And, How do you get there?
We manage investment advisory accounts on a discretionary basis. Account management is
guided by the client's stated objectives (i.e., capital preservation, current income, income and
growth, or long-term growth) as well as tax considerations. We will maintain a disciplined
approach to rebalancing your portfolio to match your allocation within your risk tolerance
levels. Your portfolio is designed and maintained with the goal of managing your risk to
match your stage in life as well as maximize tax efficiency. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors by
providing written instructions.
The team will work closely with clients to review any necessary changes to the portfolio based on the
following:
• Change in financial situation
• Change in goals
• Change in risk tolerance
• Diversification
IAS also provides customized services to clients, as needed, to help the client with their overall
financial picture, which may include:
• Ongoing discretionary investment management
• Periodic rebalancing
• Tax optimization and tax loss harvesting as applicable
• Collaboration with CPA and estate planning professionals
• Portfolio personalization, as applicable
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• Financial planning as appropriate
• Assignment of a personal financial advisor or team
• Quarterly Reporting of holdings and performance
•
Investment advice to retirement accounts
VALUE PROPOSITION
Organization – we will assist in bringing order to your financial life assimilating all of your financial
assets and liabilities into one central portal.
Partnership – we will partner with you, collaboratively to understand your financial needs and goals,
and ultimately assist you in the best financial life for you and your family.
Accountability – we will follow through on our financial commitments to you.
Objectivity – We provide objective, unbiased advice designed to keep your financial decisions focused
on your long-term goals rather than short-term emotions or market events.
Proactivity – we will be proactive in anticipating life transition issues in your life and assisting you to be
financially prepared for them.
Education – we will constantly work to secure or maintain the knowledge necessary to assist you with
the financial decisions that impact success for your particular situation.
THIRD-PARTY INVESTMENT ADVISORS SERVICES
IAS may use the services of third-party investment advisors as sub-advisors. If we choose this option, we
will select a third-party investment advisor whose style and talent best fit your individual needs and
objectives. Your agreement with us gives us the authority to hire or fire these managers on your behalf.
Once a third-party investment advisor is selected, we will continue to monitor their performance. If you
are interested in learning more about any of these third-party investment advisors and their services, a
complete description of their programs, services, fees, payment structure and termination features are
found in their service disclosure brochures. Our advisory responsibility is to select and monitor any third-
party investment advisor that provides services to us. Factors that we consider in their selection may
include their size, how long they have been in business, the experience level and turnover of their
portfolio managers, and a review of their historical performance and risk measurements.
In deciding to use a third-party investment adviser to manage your assets, we consider your risk
tolerance, goals, objectives, time horizons, and general financial situation. We also consider your level of
investment experience and the assets you have available for investment. If you were to go to these third-
party investment advisors on your own, the fees they charge you may be more or less than going through
us. However, when using their services directly, you will not receive our expertise in developing an
investment strategy, selecting the third-party investment advisors to use, monitoring the performance of
your account, and changing third-party investment advisors if needed.
AMOUNT OF MANAGED ASSETS
As of 06/30/2026, we have discretionary assets under management of $588,550,000.
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Item 5
Fees and Compensation
The annualized fee for services provided is charged as a percentage of assets under management,
according to the following schedule:
Assets Under Management
Annual Fee
First 2 Million
Next 8 Million
Above 10 Million
1.00%
0.60%
0.40%
We may group certain related client accounts within the same household for the purposes of achieving
the minimum account size requirements and/or to provide breakpoint pricing to the client. Management
fees are payable in advance on a quarterly basis by multiplying the assets under management by the
relevant annualized percent and dividing such product by four (4). Accounts opened in mid quarter may
be assessed a prorated management fee. Fees may be deducted from the client's account(s) held by the
Custodian within thirty (30) days from the beginning of the quarter for which said fees will be incurred.
We retain the discretion to waive minimum fees based upon relationship.
Third Party Investment Adviser Services: The fees for third-party advisory services that are utilized for
the management of a portion of your portfolio will be paid directly to the third-party adviser. The third-
party advisor fees will directly debit your account held by the Custodian for their fees. Clients will receive
a full disclosure of the fee schedule for the services provided to you, along with the third-party advisor’s
brochure or equivalent disclosure document, and their privacy policy, prior to placing the assets with the
third-party advisor selected.
Other Compensation: Neither IAS Wealth Management, Inc., or its team representatives, accept
compensation from the sale of securities or other investment products.
Limited Changes to Advisory Fees: Although IAS Wealth Management, Inc. has established the
aforementioned fee schedule(s), we retain the discretion to alter fees on a client by client basis. Factors
that may be considered are the complexity of client circumstances and account composition. The
specific annual fee schedule is identified in the contract between the adviser and each client.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees
and expenses charged by custodians and imposed by broker-dealers, including, but not limited to, any
transaction charges imposed by a broker-dealer with which an independent investment manager effects
transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this
Form ADV for additional information.
Grandfathering of Adviser Fees: Pre-existing advisory clients are subject to IAS Wealth Management,
Inc. advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our
Firm's advisory fees will differ among clients.
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Advisory Fees in General: Clients should note that similar advisory services may (or may not) be
available from other registered (or unregistered) investment advisers for higher, similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in
excess of $1,200 more than six months in advance of services rendered.
GENERAL INFORMATION
The Investment Management Agreement is effective upon the date of signing. The Agreements shall be
for one year in duration from the date of acceptance by both parties to this contract and automatically
renewed for additional one year terms unless terminated prior thereto as indicated under "Termination of
the Advisory Relationship.
Termination of the Advisory Relationship:
A client agreement may be canceled at any time, by either party, for any reason upon receipt of written
notice. Notwithstanding the above, if the appropriate disclosure statement was not delivered to the client
at least 48 hours prior to the client entering into any written or oral advisory or consultation contract with
us, then the client has the right to terminate the relationship contract without penalty within five (5)
business days after entering into the contract. As disclosed above, certain fees are paid in advance of
services provided. Upon termination of any account, any prepaid unearned fees will be refunded within
10 days. In calculating the reimbursement of fees to a client, we will pro rate the reimbursement
according to the number of days remaining in the billing period.
Limitation of Financial Planning and Investment Consulting/Implementation Services
To the extent specifically requested by a client (depending on the nature of the issue presented) IAS
may provide limited financial planning and related consulting services regarding non-investment
related matters, such as estate planning, tax planning, insurance, etc., however IAS does not serve
as an attorney, accountant, or insurance agency, and no portion of our services should be construed
as same. Accordingly, IAS does not prepare estate planning documents, tax returns or sell
insurance products. To the extent requested by a client, we may recommend the services of other
professionals for certain non-investment implementation purposes (i.e. attorneys, accountants,
insurance, etc.) You are under no obligation to engage the services of any of such recommended
professionals. The client retains absolute discretion overall for such implementation decisions and
is free to accept or reject any recommendation that we make. Please note: It remains the client’s
responsibility to promptly notify IAS if there is ever any change in his/her financial situation or
investment objectives for the purpose of reviewing/evaluating/revising IAS’s previous
recommendations or services.
ERISA/IRC Fiduciary Acknowledgement
If a client is (i) a retirement plan (“Plan”) organized under the Employment Retirement Income
Security Act of 1974 (“ERISA”); (ii) a participant or beneficiary of a plan subject to Title I of
ERISA or described in section 4975§ (1)(A) of the Internal Revenue Code with authority to direct
investment of assets in his or her Plan account or take a distribution; (iii) the beneficial owner of
an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or (iv) a Retail Fiduciary
with respect to a plan subject to Title I of ERISA or described in section 4975§ (1)(A) of the
Internal Revenue Code; then the firm represents that it and its representatives are fiduciaries under
ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by
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the firm or its representatives or with respect to any investment recommendations regarding an
ERISA Plan or participant or beneficiary account.
ERISA Accounts:
IAS Wealth Management, Inc. is deemed to be a fiduciary to advisory clients that are employee
benefit plans or rollover individual retirement accounts (IRAs) pursuant to the Employee
Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue
Code of 1986 (the "Code"), respectively. As such, our Firm is subject to specific duties and
obligations under ERISA and the Internal Revenue Code that include among other things,
restrictions concerning certain forms of compensation. To avoid engaging in prohibited
transactions, IAS Wealth Management, Inc. does not receive any commissions or 12b-1 fees.
Retirement Rollovers-Potential for Conflict of Interest
As part of our investment advisory services to you, we may recommend you withdraw the assets
from your employer’s (or former employer’s) retirement plan and roll the assets over to an
individual retirement account (IRA) that we will manage on your behalf. If you elect to roll assets
to an IRA that is subject to our management, we will charge you an asset-based fee as set-forth in
the management agreement executed by you with our firm. This practice presents a conflict of
interest because providing investment advice and suggesting a roll-over of assets will generate fee-
based compensation to the firm. You are under no obligation, contractually or otherwise, to
complete a rollover. Moreover, if you do not complete the rollover, you are under no obligation to
have the assets in the IRA or employer plan to be managed by our firm.
An employee will typically have four options:
Leave the funds in your employer’s (or former employer’s) plan
1.
2. Moving funds to a new employer’s retirement plan
3.
4.
Cashing out and taking a taxable distribution from the plan
Rolling the funds into an IRA account.
Each of these options has advantages and disadvantages and we encourage you to speak with your
CPA and/or Tax Attorney. It is important you understand the differences between these types of
accounts and decide whether a rollover is best for you.
Mutual Fund/ETF Fees: All fees paid to IAS Wealth Management, Inc. by clients for investment
advisory services are separate and distinct from the fees and expenses charged by mutual funds
and/or ETFs to their shareholders. Mutual funds and ETF fees and expenses are described in their
prospectus. These fees will generally include a management fee, and other fund expenses. A
client could invest in a mutual fund directly, without our services. In that case, the client would
not receive the services provided by our Firm which are designed, among other things, to assist the
client in determining which mutual fund or funds are most appropriate to each client's financial
condition and objectives. Our Firm considers the cost of a mutual fund to be an important variable
in the selection process. On certain mutual funds, we will have access to share classes which may
have lower costs than a share class an individual could purchase directly. Accordingly, the client
should review both the fees charged by the funds and our fees to fully understand the total amount
of fees to be paid by the client and to thereby evaluate the advisory services being provided.
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Item 6
Performance Based Fees and Side By Side Management
IAS Wealth Management, Inc. does not charge performance based fees nor does it engage in side by
side management.
Item 7
Types of Clients
IAS Wealth Management, Inc. provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
•
• High net worth individuals
• Trusts
• Estates
• Business Owners
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
IAS Wealth Management, Inc. utilizes a team-based investment committee. Herein
referred to as the “Committee”. The Committee maintains a Select List of
investments for portfolio construction. The Committee determines which securities to
add to or delete from the List, utilizing a number of sources.
Equity Securities
Individual selections/maintenance of Equities will generally be based on fundamental
factors as to the Company quality, market cap, sector, credit rating, revenue, earnings,
EPS growth rates, dividend distributions, relative valuation and other factors.
Technical factors utilized when buying/selling the position may consider short -term
volume and price movement, relative stock price position to the 50 and 200 -day
moving averages and other factors.
Equity Mutual Funds will be selected based on the overall Fund Family, the
manager(s) experience, size of fund, style of management (growth/value/balanced),
average market cap, sector weighting, performance relative to peers and benchmark,
unrealized capital gains, expense ratio and other factors.
ETF’s will be selected based on quality of the Corporate Sponsor, size and liquidity
of ETF, sector or theme representation, performance relative to peers and benchmark,
expense ratio and other factors.
Individual Fixed Income Securities
Fixed Income Securities and Mutual Funds that hold fixed -income securities will be
selected on accessibility, types of holdings, credit quality, duration and cost.
Resources Used in Analysis
Analyst’s reports - S&P (CFRA), Zacks, Morningstar, Fidelity and various other
sources.
Investment Research - Fidelity, IBD, MarketSmith, Barron’s, WSJ, S&P Outlook,
Sevens’ Report, Yahoo Finance, Clearnomics, other periodicals and business news
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including Bloomberg, CNBC, and Fox Business.
Meetings, Webinars, Web content - Fidelity, Mutual Fund and ETF providers
The Committee meets periodically as warranted, to discuss any additions and deletions from the IAS
Select list. Additionally, economic, market and other actions are discussed.
INVESTMENT STRATEGIES
Our Firm manages client accounts on an individualized basis.
Any investment strategies used in managing client accounts will be based on the needs of each
client and consistent with our understanding of a client's investment objectives, risk tolerance, and
time horizon among other considerations.
We attempt to manage risk through appropriate diversification including allocation between equity
securities and fixed income securities and cash.
Our investment recommendations are not limited to any specific product or service offered by a
broker/dealer company and will generally include advice regarding the following securities:
•
•
•
•
•
•
•
•
•
Mutual Fund shares
Exchange Traded Fund shares (ETF’s)
Publicly traded Equity securities
Corporate debt securities
Municipal securities
Certificates of Deposit
United States government and agency securities
Real Estate Investment Trusts (REITS)
Separately Managed Accounts (SMA’s)
Our Firm will generally look to buy/ hold positions for the long term (one year or longer) but will sell
or reduce holdings when appropriate based on valuation, adjustments to portfolio allocation,
opportunity to add portfolio tax efficiency, or fundamental changes that affect the position.
Our investment philosophy does not generally warrant making investment decisions based on short
term purchases or trading. Additionally, we do not utilize strategies based on leverage of risk
through the use of margin transactions whereby a portfolio can purchase more stock than the
available cash would allow.
Risk of Loss: While our Firm seeks to "preserve and grow" our clients' assets, investment securities
are not guaranteed and you may lose money on your investments. We ask that clients work with us
to help us understand their tolerance for risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to clients or prospective
clients for evaluation of our advisory business or the integrity of our management.
Our Firm, established in 1994 and our personnel have no reportable disciplinary events to disclose now
or since inception of the firm.
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Item 10 Other Financial Industry Activities and Affiliations
Our Firm and our related persons are not engaged in other financial industry activities and have no
other industry affiliations.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Our Firm, acting as a fiduciary has adopted a Code of Ethics which sets forth high ethical standards
of business conduct we require of our employees, including compliance with applicable federal and
state securities laws.
IAS Wealth Management, Inc., and our personnel owe a duty of loyalty, fairness, and good faith
towards our clients, and have an obligation to adhere not only to the specific provisions of the
Code of Ethics but to the general principles that guide the Code.
The Code of Ethics describes the general code of conduct the firm expects of all employees of
IAS, and specifically focuses on three specific areas where employee conduct has the potential to
adversely affect the client:
• Misuse of nonpublic information
• Personal securities trading
• Outside business activities
Our Code of Ethics includes policies and procedures for the review of securities transaction statements
and/or initial and annual securities holdings reports which are provided by the Firm’s access persons.
IAS Wealth Management, Inc.’s Code of Ethics further includes the Firm's policy prohibiting
the use of material non- public information. While we do not believe we have any particular
access to non- public information, and all employees are reminded that such information may
not be used in a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may
request a copy by email sent to: cj@iaswealth.com or by calling us at 281-364-0606.
The guiding principles of all aspects of the firm’s business and represent the requirements to which the
firm expects employees to adhere:
• Client’s interest come before employee’s personal interests and before the Firm’s interests.
• The firm will always fully disclose any material facts about conflict of interest between the
firm and the client as well as between Firm employees and clients.
• Employees must operate on the Firm’s behalf and on their own behalf consistently with the
Firm’s disclosures and appropriately manage any conflicts.
• The Firm and its employees must comply with all Federal and State applicable securities laws.
• The Firm and its employees will not take inappropriate advantage of their position of trust and
responsibility to clients.
The Code of Ethics contains a policy against the use of nonpublic information in conducting business
for the Firm. Employees may not convey nonpublic information or depend upon it for making personal
or client’s securities trades.
Individuals of the Firm, may buy, sell or hold the same securities in their personal accounts as the Firm
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recommends to its clients. This creates a potential conflict of interest with the possibility of Firm
personnel obtaining a better price than clients obtain. To mitigate this conflict, such trades may occur
on the same day at the same time receiving average pricing or after the client with the client receiving
the same or better pricing. Additionally, all trades by employees must be pre-approved when involving
reportable securities such as individual equities, Exchanged Traded Funds (ETF), and other securities
priced on an active basis.
Employees are required to submit reports of personal securities trades on a quarterly basis, and
securities holdings annually. These reports are reviewed by the Chief Compliance Officer to ensure
compliance with the Firm’s policies.
Item 12 Brokerage Practices
For discretionary clients, IAS Wealth Management, Inc. requires clients to provide us with written
authority to execute trades on their behalf with the custodian.
These clients must include any limitations on this discretionary authority in the written
authority statement. Clients may change/amend these limitations as required. Such
amendments must be provided to us in writing.
IAS Wealth Management, Inc. will aggregate trades where possible and when advantageous to
clients, however due to the individual nature of each portfolio, block trading may not be available.
The blocking of trades permits the trading of aggregate blocks of securities for multiple client
accounts.
IAS Wealth Management, Inc. has an arrangement with National Financial Services LLC, and
Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity") through
which Fidelity provides our Firm with their "institutional platform" services. The platform
services include, among others, brokerage, custodial, administrative support, record keeping, and
related services. These services are intended to support intermediaries like IAS Wealth Management,
Inc. in conducting business and in serving the best interests of clients. However, they may also
benefit IAS Wealth Management, Inc.
Fidelity's institutional platform services assist us in managing and administering clients' accounts
include software and other technology that:
facilitate payment of fees from clients' accounts; and
• provide access to client account data (such as trade confirmations and account statements);
•
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• provide research, pricing, and other market data;
•
• assist with back office functions, record keeping, and client reporting.
We receive these benefits because of our clients’ relationships with Fidelity, but have no formal soft
dollar arrangements and receive no compensation from Fidelity. These benefits provided by Fidelity
might assist us with the administration of client accounts, and thus slightly help our profitability,
thus creating a potential conflict of interest with clients. We believe this is not a material conflict.
Directed Brokerage
As a matter of policy and practice, IAS Wealth Management, Inc. may accept directed brokerage from
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clients. Clients should be aware that when we facilitate a client's request to direct their brokerage, our
Firm does not generally block the client directed brokerage trades; and, therefore, we implement client
transactions separately for each account. Consequently, certain client trades may be executed before
others and at a different price.
Item 13 Review of Accounts
While the underlying securities within Individual Portfolio Management Services accounts are
continually monitored by the team of advisors, all client accounts are reviewed at least quarterly.
Accounts are reviewed in the context of each client's stated investment objectives and guidelines. The
client is responsible for communicating his/her needs, goals, and objectives to the Firm in a timely
manner and to alert us to any changes in their needs, goals, and objectives. More frequent reviews may
be triggered by material changes in variables such as the client's individual circumstances, or the
market, political, or economic environment.
In addition to the monthly statements and confirmations of transactions that clients receive from
their broker/dealer, we provide quarterly reports summarizing account performance, balances, and
holdings.
Item 14 Client Referrals and Other Compensation
It is IAS Wealth Management, Inc.’s policy not to engage solicitors or to pay related or non-related
persons for referring potential clients to our Firm.
Item 15 Custody
Our Firm does not and will not have actual or constructive custody of client funds or
securities. We previously disclosed in the "Fees and Compensation" section (Item 5) of this
Brochure that our Firm directly debits advisory fees from client accounts. The client has the
responsibility to direct which account(s) the fee will be charged. There may be certain tax
consequences that occur as a result of this decision and a client should discuss any tax
consequences with their tax adviser.
Payment of our management fees may be made by the custodian holding the client's funds and securities
only when all three of the following criteria are met:
1.
2.
3.
The client provides us with written authorization permitting their fees to be paid directly from
his/her account that are held by the custodian;
The Firm sends the client an invoice showing the fee amount due, the value on which the fee
was calculated, and the method of calculation;
The custodian sends a statement to the client at least quarterly indicating the advisory fees that
were paid directly as well as any other disbursements from the account.
As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted
from that client's account.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for
clients to carefully review their custodial statements to verify the accuracy of the calculation, among
other things. Clients should contact us directly if they believe that there may be an error in their
statement.
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In addition to the periodic statements that clients receive directly from their custodians, we also send
account statements directly to our clients on a quarterly basis. We urge our clients to carefully
compare the information provided on these statements to ensure that all account transactions, holdings,
and values are correct and current.
Please Also Note: Other Custody Situations:
IAS Wealth Management, Inc. engages in practices and/or services on behalf of its clients
that require disclosure in ADV Part 1. Certain clients have established asset transfer
authorizations which permit the qualified custodian to rely upon instructions from IAS to
transfer client funds or securities to third parties. These arrangements are disclosed at Form
ADV Part 1, Item 9, but in accordance with the guidance provided in the SEC’s February 21,
2017 Investment Adviser Association No-Action Letter, the affected accounts are not
subject to an annual surprise CPA examination.
Item 16
Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we place trades
in a client's account without contacting the client prior to each trade to obtain the client's permission.
We place trades through a custodian by virtue of a limited power of attorney, solely allowing trade
authority. At no time may the Firm or its personnel withdraw funds to itself or to a third party with the
exception of management fees as outlined in Item 15.
Our discretionary authority includes the ability to do the following without contacting the client:
• determine the security to buy or sell; and/or
• determine the amount of the security to buy or sell
Clients give us discretionary investment authority when they sign a discretionary agreement with our
Firm, and may limit this authority by giving us written instructions. Clients may also change or amend
such limitations by once again providing us with written instructions.
Individual trades are usually executed through the client's custodian for their discounted commissions,
ease of clearing, and for the speed and accuracy of trading information. To the extent that other
broker/dealers may offer better executions, trades may be executed elsewhere on an exception basis.
17
Voting Client Securities
As a matter of Firm policy, we do not vote proxies on behalf of clients. Therefore, although our Firm
may provide 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, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. 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.
We do not offer any consulting assistance regarding proxy issues to clients.
Item 18 Financial Information
There is no financial condition that is reasonably likely to impair the Firm’s ability to meet its
contractual commitments to its clients.
14
Primary Brochure: ADV FORM 2A (2026-07-23)
View Document Text
Part 2A of Form ADV:
Firm Brochure
9303 New Trails Drive
Suite 450
The Woodlands, TX 77381
Telephone: 281-364-0606
Email:cj@iaswealth.com
Web Address: www.iaswealth.com
07/01/2026
This brochure provides information about the qualifications and business practices of
IAS Wealth Management, Inc. If you have any questions about the contents of this
brochure, please contact us at 281-364-0606 or cj@iaswealth.com. The information in
this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about IAS Wealth Management, Inc. also is available on the
SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. Our Firm's CRD number is 112486.
Item 2 Material Changes
This Firm Brochure, dated 07/01/2026, provides you with a summary of IAS Wealth Management,
Inc. advisory services fees, professionals, certain business practices and policies, as well as actual or
potential conflicts of interest, among other things. This brochure is used to provide our clients with a
summary of new and/or updated information and any revision(s) based on the nature of the
information as follows.
1. Annual Update: We are required to update certain information at least annually, within
90 days of our Firm’s fiscal year end (FYE) of December 31.
2. Material Changes: Should a material change in our operations occur, depending on its nature
we will promptly communicate this change to our clients (and it will be summarized in this
Item). "Material changes" requiring prompt notification will include changes of ownership or
control; location; disciplinary proceedings; significant changes to our advisory services or
advisory affiliates – any information that is critical to a client’s full understanding of who we
are, how to find us, and how we do business.
This Brochure does include a number of minor editorial changes and the updated information on our
assets under management.
Currently, our Brochure may be requested free of charge by contacting CJ Haynes, Chief Compliance
Officer.
Contact Information:
CJ Haynes
Chief Compliance Officer
Email: cj@iaswealth.com
Phone: 281-364-0606
Address: 9303 New Trails Drive, Suite 450
The Woodlands, TX 77381
2
Item 3
Table of Contents
Page
Item 1
Cover Page
1
Item 2
Material Changes
2
Item 3
Table of Contents
3
Item 4
Advisory Business
4
Item 5
Fees and Compensation
6
Item 6
Performance Based Fees and Side By Side Management
9
Item 7
Types of Clients
9
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
9
Disciplinary Information
Item 9
Item 10 Other Financial Industry Activities and Affiliations
11
11
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
11
Item 12
Brokerage Practices
12
Item 13
Review of Accounts
13
Item 14
Client Referrals and Other Compensation
13
Item 15
Custody
13
Item 16
Investment Discretion
14
Item 17 Voting Client Securities
14
Item 18
Financial Information
15
3
Item 4 Advisory Business
IAS Wealth Management, Inc. ("IAS") is an SEC-registered investment adviser with its principal
place of business in The Woodlands, Texas. Founded in 1994 by John Lester Haynes, IAS is a
privately owned advisory firm. Effective July 1, 2026, Henry A. Stevens and Jason Henry became
equity owners of the firm alongside founder, and majority shareholder, John Lester Haynes.
The officers of IAS Wealth Management, Inc. are: John L. Haynes, Chairman; Henry A. Stevens,
President; CJ Haynes, Chief Compliance Officer and Vice President; Curt E. Beck, Secretary,
Treasurer, and Vice President; and Jason Henry, Vice President.
As a fiduciary, IAS provides financial planning and investment advisory services to clients on a
consolidated fee-only basis.
As part of our team approach, services are provided utilizing the expertise of team members,
assuring our clients will have the opportunity of a long-term relationship with the advisors and the
Firm.
Through personal discussions with you, we listen carefully to gain a thorough understanding of your
unique goals and objectives based on your particular circumstances. As appropriate, we also review
and discuss a your prior investment history, as well as family composition and background. We
work with you, utilizing various tools and conversations to determine the best approach for you. As
part of the advisory process we work with each client to answer the following three questions:
Where are you now? Where do you want to be? And, How do you get there?
We manage investment advisory accounts on a discretionary basis. Account management is
guided by the client's stated objectives (i.e., capital preservation, current income, income and
growth, or long-term growth) as well as tax considerations. We will maintain a disciplined
approach to rebalancing your portfolio to match your allocation within your risk tolerance
levels. Your portfolio is designed and maintained with the goal of managing your risk to
match your stage in life as well as maximize tax efficiency. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors by
providing written instructions.
The team will work closely with clients to review any necessary changes to the portfolio based on the
following:
• Change in financial situation
• Change in goals
• Change in risk tolerance
• Diversification
IAS also provides customized services to clients, as needed, to help the client with their overall
financial picture, which may include:
• Ongoing discretionary investment management
• Periodic rebalancing
• Tax optimization and tax loss harvesting as applicable
• Collaboration with CPA and estate planning professionals
• Portfolio personalization, as applicable
4
• Financial planning as appropriate
• Assignment of a personal financial advisor or team
• Quarterly Reporting of holdings and performance
•
Investment advice to retirement accounts
VALUE PROPOSITION
Organization – we will assist in bringing order to your financial life assimilating all of your financial
assets and liabilities into one central portal.
Partnership – we will partner with you, collaboratively to understand your financial needs and goals,
and ultimately assist you in the best financial life for you and your family.
Accountability – we will follow through on our financial commitments to you.
Objectivity – We provide objective, unbiased advice designed to keep your financial decisions focused
on your long-term goals rather than short-term emotions or market events.
Proactivity – we will be proactive in anticipating life transition issues in your life and assisting you to be
financially prepared for them.
Education – we will constantly work to secure or maintain the knowledge necessary to assist you with
the financial decisions that impact success for your particular situation.
THIRD-PARTY INVESTMENT ADVISORS SERVICES
IAS may use the services of third-party investment advisors as sub-advisors. If we choose this option, we
will select a third-party investment advisor whose style and talent best fit your individual needs and
objectives. Your agreement with us gives us the authority to hire or fire these managers on your behalf.
Once a third-party investment advisor is selected, we will continue to monitor their performance. If you
are interested in learning more about any of these third-party investment advisors and their services, a
complete description of their programs, services, fees, payment structure and termination features are
found in their service disclosure brochures. Our advisory responsibility is to select and monitor any third-
party investment advisor that provides services to us. Factors that we consider in their selection may
include their size, how long they have been in business, the experience level and turnover of their
portfolio managers, and a review of their historical performance and risk measurements.
In deciding to use a third-party investment adviser to manage your assets, we consider your risk
tolerance, goals, objectives, time horizons, and general financial situation. We also consider your level of
investment experience and the assets you have available for investment. If you were to go to these third-
party investment advisors on your own, the fees they charge you may be more or less than going through
us. However, when using their services directly, you will not receive our expertise in developing an
investment strategy, selecting the third-party investment advisors to use, monitoring the performance of
your account, and changing third-party investment advisors if needed.
AMOUNT OF MANAGED ASSETS
As of 06/30/2026, we have discretionary assets under management of $588,550,000.
5
Item 5
Fees and Compensation
The annualized fee for services provided is charged as a percentage of assets under management,
according to the following schedule:
Assets Under Management
Annual Fee
First 2 Million
Next 8 Million
Above 10 Million
1.00%
0.60%
0.40%
We may group certain related client accounts within the same household for the purposes of achieving
the minimum account size requirements and/or to provide breakpoint pricing to the client. Management
fees are payable in advance on a quarterly basis by multiplying the assets under management by the
relevant annualized percent and dividing such product by four (4). Accounts opened in mid quarter may
be assessed a prorated management fee. Fees may be deducted from the client's account(s) held by the
Custodian within thirty (30) days from the beginning of the quarter for which said fees will be incurred.
We retain the discretion to waive minimum fees based upon relationship.
Third Party Investment Adviser Services: The fees for third-party advisory services that are utilized for
the management of a portion of your portfolio will be paid directly to the third-party adviser. The third-
party advisor fees will directly debit your account held by the Custodian for their fees. Clients will receive
a full disclosure of the fee schedule for the services provided to you, along with the third-party advisor’s
brochure or equivalent disclosure document, and their privacy policy, prior to placing the assets with the
third-party advisor selected.
Other Compensation: Neither IAS Wealth Management, Inc., or its team representatives, accept
compensation from the sale of securities or other investment products.
Limited Changes to Advisory Fees: Although IAS Wealth Management, Inc. has established the
aforementioned fee schedule(s), we retain the discretion to alter fees on a client by client basis. Factors
that may be considered are the complexity of client circumstances and account composition. The
specific annual fee schedule is identified in the contract between the adviser and each client.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees
and expenses charged by custodians and imposed by broker-dealers, including, but not limited to, any
transaction charges imposed by a broker-dealer with which an independent investment manager effects
transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this
Form ADV for additional information.
Grandfathering of Adviser Fees: Pre-existing advisory clients are subject to IAS Wealth Management,
Inc. advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our
Firm's advisory fees will differ among clients.
6
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be
available from other registered (or unregistered) investment advisers for higher, similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in
excess of $1,200 more than six months in advance of services rendered.
GENERAL INFORMATION
The Investment Management Agreement is effective upon the date of signing. The Agreements shall be
for one year in duration from the date of acceptance by both parties to this contract and automatically
renewed for additional one year terms unless terminated prior thereto as indicated under "Termination of
the Advisory Relationship.
Termination of the Advisory Relationship:
A client agreement may be canceled at any time, by either party, for any reason upon receipt of written
notice. Notwithstanding the above, if the appropriate disclosure statement was not delivered to the client
at least 48 hours prior to the client entering into any written or oral advisory or consultation contract with
us, then the client has the right to terminate the relationship contract without penalty within five (5)
business days after entering into the contract. As disclosed above, certain fees are paid in advance of
services provided. Upon termination of any account, any prepaid unearned fees will be refunded within
10 days. In calculating the reimbursement of fees to a client, we will pro rate the reimbursement
according to the number of days remaining in the billing period.
Limitation of Financial Planning and Investment Consulting/Implementation Services
To the extent specifically requested by a client (depending on the nature of the issue presented) IAS
may provide limited financial planning and related consulting services regarding non-investment
related matters, such as estate planning, tax planning, insurance, etc., however IAS does not serve
as an attorney, accountant, or insurance agency, and no portion of our services should be construed
as same. Accordingly, IAS does not prepare estate planning documents, tax returns or sell
insurance products. To the extent requested by a client, we may recommend the services of other
professionals for certain non-investment implementation purposes (i.e. attorneys, accountants,
insurance, etc.) You are under no obligation to engage the services of any of such recommended
professionals. The client retains absolute discretion overall for such implementation decisions and
is free to accept or reject any recommendation that we make. Please note: It remains the client’s
responsibility to promptly notify IAS if there is ever any change in his/her financial situation or
investment objectives for the purpose of reviewing/evaluating/revising IAS’s previous
recommendations or services.
ERISA/IRC Fiduciary Acknowledgement
If a client is (i) a retirement plan (“Plan”) organized under the Employment Retirement Income
Security Act of 1974 (“ERISA”); (ii) a participant or beneficiary of a plan subject to Title I of
ERISA or described in section 4975§ (1)(A) of the Internal Revenue Code with authority to direct
investment of assets in his or her Plan account or take a distribution; (iii) the beneficial owner of
an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or (iv) a Retail Fiduciary
with respect to a plan subject to Title I of ERISA or described in section 4975§ (1)(A) of the
Internal Revenue Code; then the firm represents that it and its representatives are fiduciaries under
ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by
7
the firm or its representatives or with respect to any investment recommendations regarding an
ERISA Plan or participant or beneficiary account.
ERISA Accounts:
IAS Wealth Management, Inc. is deemed to be a fiduciary to advisory clients that are employee
benefit plans or rollover individual retirement accounts (IRAs) pursuant to the Employee
Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue
Code of 1986 (the "Code"), respectively. As such, our Firm is subject to specific duties and
obligations under ERISA and the Internal Revenue Code that include among other things,
restrictions concerning certain forms of compensation. To avoid engaging in prohibited
transactions, IAS Wealth Management, Inc. does not receive any commissions or 12b-1 fees.
Retirement Rollovers-Potential for Conflict of Interest
As part of our investment advisory services to you, we may recommend you withdraw the assets
from your employer’s (or former employer’s) retirement plan and roll the assets over to an
individual retirement account (IRA) that we will manage on your behalf. If you elect to roll assets
to an IRA that is subject to our management, we will charge you an asset-based fee as set-forth in
the management agreement executed by you with our firm. This practice presents a conflict of
interest because providing investment advice and suggesting a roll-over of assets will generate fee-
based compensation to the firm. You are under no obligation, contractually or otherwise, to
complete a rollover. Moreover, if you do not complete the rollover, you are under no obligation to
have the assets in the IRA or employer plan to be managed by our firm.
An employee will typically have four options:
Leave the funds in your employer’s (or former employer’s) plan
1.
2. Moving funds to a new employer’s retirement plan
3.
4.
Cashing out and taking a taxable distribution from the plan
Rolling the funds into an IRA account.
Each of these options has advantages and disadvantages and we encourage you to speak with your
CPA and/or Tax Attorney. It is important you understand the differences between these types of
accounts and decide whether a rollover is best for you.
Mutual Fund/ETF Fees: All fees paid to IAS Wealth Management, Inc. by clients for investment
advisory services are separate and distinct from the fees and expenses charged by mutual funds
and/or ETFs to their shareholders. Mutual funds and ETF fees and expenses are described in their
prospectus. These fees will generally include a management fee, and other fund expenses. A
client could invest in a mutual fund directly, without our services. In that case, the client would
not receive the services provided by our Firm which are designed, among other things, to assist the
client in determining which mutual fund or funds are most appropriate to each client's financial
condition and objectives. Our Firm considers the cost of a mutual fund to be an important variable
in the selection process. On certain mutual funds, we will have access to share classes which may
have lower costs than a share class an individual could purchase directly. Accordingly, the client
should review both the fees charged by the funds and our fees to fully understand the total amount
of fees to be paid by the client and to thereby evaluate the advisory services being provided.
8
Item 6
Performance Based Fees and Side By Side Management
IAS Wealth Management, Inc. does not charge performance based fees nor does it engage in side by
side management.
Item 7
Types of Clients
IAS Wealth Management, Inc. provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
•
• High net worth individuals
• Trusts
• Estates
• Business Owners
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
IAS Wealth Management, Inc. utilizes a team-based investment committee. Herein
referred to as the “Committee”. The Committee maintains a Select List of
investments for portfolio construction. The Committee determines which securities to
add to or delete from the List, utilizing a number of sources.
Equity Securities
Individual selections/maintenance of Equities will generally be based on fundamental
factors as to the Company quality, market cap, sector, credit rating, revenue, earnings,
EPS growth rates, dividend distributions, relative valuation and other factors.
Technical factors utilized when buying/selling the position may consider short -term
volume and price movement, relative stock price position to the 50 and 200 -day
moving averages and other factors.
Equity Mutual Funds will be selected based on the overall Fund Family, the
manager(s) experience, size of fund, style of management (growth/value/balanced),
average market cap, sector weighting, performance relative to peers and benchmark,
unrealized capital gains, expense ratio and other factors.
ETF’s will be selected based on quality of the Corporate Sponsor, size and liquidity
of ETF, sector or theme representation, performance relative to peers and benchmark,
expense ratio and other factors.
Individual Fixed Income Securities
Fixed Income Securities and Mutual Funds that hold fixed -income securities will be
selected on accessibility, types of holdings, credit quality, duration and cost.
Resources Used in Analysis
Analyst’s reports - S&P (CFRA), Zacks, Morningstar, Fidelity and various other
sources.
Investment Research - Fidelity, IBD, MarketSmith, Barron’s, WSJ, S&P Outlook,
Sevens’ Report, Yahoo Finance, Clearnomics, other periodicals and business news
9
including Bloomberg, CNBC, and Fox Business.
Meetings, Webinars, Web content - Fidelity, Mutual Fund and ETF providers
The Committee meets periodically as warranted, to discuss any additions and deletions from the IAS
Select list. Additionally, economic, market and other actions are discussed.
INVESTMENT STRATEGIES
Our Firm manages client accounts on an individualized basis.
Any investment strategies used in managing client accounts will be based on the needs of each
client and consistent with our understanding of a client's investment objectives, risk tolerance, and
time horizon among other considerations.
We attempt to manage risk through appropriate diversification including allocation between equity
securities and fixed income securities and cash.
Our investment recommendations are not limited to any specific product or service offered by a
broker/dealer company and will generally include advice regarding the following securities:
•
•
•
•
•
•
•
•
•
Mutual Fund shares
Exchange Traded Fund shares (ETF’s)
Publicly traded Equity securities
Corporate debt securities
Municipal securities
Certificates of Deposit
United States government and agency securities
Real Estate Investment Trusts (REITS)
Separately Managed Accounts (SMA’s)
Our Firm will generally look to buy/ hold positions for the long term (one year or longer) but will sell
or reduce holdings when appropriate based on valuation, adjustments to portfolio allocation,
opportunity to add portfolio tax efficiency, or fundamental changes that affect the position.
Our investment philosophy does not generally warrant making investment decisions based on short
term purchases or trading. Additionally, we do not utilize strategies based on leverage of risk
through the use of margin transactions whereby a portfolio can purchase more stock than the
available cash would allow.
Risk of Loss: While our Firm seeks to "preserve and grow" our clients' assets, investment securities
are not guaranteed and you may lose money on your investments. We ask that clients work with us
to help us understand their tolerance for risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to clients or prospective
clients for evaluation of our advisory business or the integrity of our management.
Our Firm, established in 1994 and our personnel have no reportable disciplinary events to disclose now
or since inception of the firm.
10
Item 10 Other Financial Industry Activities and Affiliations
Our Firm and our related persons are not engaged in other financial industry activities and have no
other industry affiliations.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Our Firm, acting as a fiduciary has adopted a Code of Ethics which sets forth high ethical standards
of business conduct we require of our employees, including compliance with applicable federal and
state securities laws.
IAS Wealth Management, Inc., and our personnel owe a duty of loyalty, fairness, and good faith
towards our clients, and have an obligation to adhere not only to the specific provisions of the
Code of Ethics but to the general principles that guide the Code.
The Code of Ethics describes the general code of conduct the firm expects of all employees of
IAS, and specifically focuses on three specific areas where employee conduct has the potential to
adversely affect the client:
• Misuse of nonpublic information
• Personal securities trading
• Outside business activities
Our Code of Ethics includes policies and procedures for the review of securities transaction statements
and/or initial and annual securities holdings reports which are provided by the Firm’s access persons.
IAS Wealth Management, Inc.’s Code of Ethics further includes the Firm's policy prohibiting
the use of material non- public information. While we do not believe we have any particular
access to non- public information, and all employees are reminded that such information may
not be used in a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may
request a copy by email sent to: cj@iaswealth.com or by calling us at 281-364-0606.
The guiding principles of all aspects of the firm’s business and represent the requirements to which the
firm expects employees to adhere:
• Client’s interest come before employee’s personal interests and before the Firm’s interests.
• The firm will always fully disclose any material facts about conflict of interest between the
firm and the client as well as between Firm employees and clients.
• Employees must operate on the Firm’s behalf and on their own behalf consistently with the
Firm’s disclosures and appropriately manage any conflicts.
• The Firm and its employees must comply with all Federal and State applicable securities laws.
• The Firm and its employees will not take inappropriate advantage of their position of trust and
responsibility to clients.
The Code of Ethics contains a policy against the use of nonpublic information in conducting business
for the Firm. Employees may not convey nonpublic information or depend upon it for making personal
or client’s securities trades.
Individuals of the Firm, may buy, sell or hold the same securities in their personal accounts as the Firm
11
recommends to its clients. This creates a potential conflict of interest with the possibility of Firm
personnel obtaining a better price than clients obtain. To mitigate this conflict, such trades may occur
on the same day at the same time receiving average pricing or after the client with the client receiving
the same or better pricing. Additionally, all trades by employees must be pre-approved when involving
reportable securities such as individual equities, Exchanged Traded Funds (ETF), and other securities
priced on an active basis.
Employees are required to submit reports of personal securities trades on a quarterly basis, and
securities holdings annually. These reports are reviewed by the Chief Compliance Officer to ensure
compliance with the Firm’s policies.
Item 12 Brokerage Practices
For discretionary clients, IAS Wealth Management, Inc. requires clients to provide us with written
authority to execute trades on their behalf with the custodian.
These clients must include any limitations on this discretionary authority in the written
authority statement. Clients may change/amend these limitations as required. Such
amendments must be provided to us in writing.
IAS Wealth Management, Inc. will aggregate trades where possible and when advantageous to
clients, however due to the individual nature of each portfolio, block trading may not be available.
The blocking of trades permits the trading of aggregate blocks of securities for multiple client
accounts.
IAS Wealth Management, Inc. has an arrangement with National Financial Services LLC, and
Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity") through
which Fidelity provides our Firm with their "institutional platform" services. The platform
services include, among others, brokerage, custodial, administrative support, record keeping, and
related services. These services are intended to support intermediaries like IAS Wealth Management,
Inc. in conducting business and in serving the best interests of clients. However, they may also
benefit IAS Wealth Management, Inc.
Fidelity's institutional platform services assist us in managing and administering clients' accounts
include software and other technology that:
facilitate payment of fees from clients' accounts; and
• provide access to client account data (such as trade confirmations and account statements);
•
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• provide research, pricing, and other market data;
•
• assist with back office functions, record keeping, and client reporting.
We receive these benefits because of our clients’ relationships with Fidelity, but have no formal soft
dollar arrangements and receive no compensation from Fidelity. These benefits provided by Fidelity
might assist us with the administration of client accounts, and thus slightly help our profitability,
thus creating a potential conflict of interest with clients. We believe this is not a material conflict.
Directed Brokerage
As a matter of policy and practice, IAS Wealth Management, Inc. may accept directed brokerage from
12
clients. Clients should be aware that when we facilitate a client's request to direct their brokerage, our
Firm does not generally block the client directed brokerage trades; and, therefore, we implement client
transactions separately for each account. Consequently, certain client trades may be executed before
others and at a different price.
Item 13 Review of Accounts
While the underlying securities within Individual Portfolio Management Services accounts are
continually monitored by the team of advisors, all client accounts are reviewed at least quarterly.
Accounts are reviewed in the context of each client's stated investment objectives and guidelines. The
client is responsible for communicating his/her needs, goals, and objectives to the Firm in a timely
manner and to alert us to any changes in their needs, goals, and objectives. More frequent reviews may
be triggered by material changes in variables such as the client's individual circumstances, or the
market, political, or economic environment.
In addition to the monthly statements and confirmations of transactions that clients receive from
their broker/dealer, we provide quarterly reports summarizing account performance, balances, and
holdings.
Item 14 Client Referrals and Other Compensation
It is IAS Wealth Management, Inc.’s policy not to engage solicitors or to pay related or non-related
persons for referring potential clients to our Firm.
Item 15 Custody
Our Firm does not and will not have actual or constructive custody of client funds or
securities. We previously disclosed in the "Fees and Compensation" section (Item 5) of this
Brochure that our Firm directly debits advisory fees from client accounts. The client has the
responsibility to direct which account(s) the fee will be charged. There may be certain tax
consequences that occur as a result of this decision and a client should discuss any tax
consequences with their tax adviser.
Payment of our management fees may be made by the custodian holding the client's funds and securities
only when all three of the following criteria are met:
1.
2.
3.
The client provides us with written authorization permitting their fees to be paid directly from
his/her account that are held by the custodian;
The Firm sends the client an invoice showing the fee amount due, the value on which the fee
was calculated, and the method of calculation;
The custodian sends a statement to the client at least quarterly indicating the advisory fees that
were paid directly as well as any other disbursements from the account.
As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted
from that client's account.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for
clients to carefully review their custodial statements to verify the accuracy of the calculation, among
other things. Clients should contact us directly if they believe that there may be an error in their
statement.
13
In addition to the periodic statements that clients receive directly from their custodians, we also send
account statements directly to our clients on a quarterly basis. We urge our clients to carefully
compare the information provided on these statements to ensure that all account transactions, holdings,
and values are correct and current.
Please Also Note: Other Custody Situations:
IAS Wealth Management, Inc. engages in practices and/or services on behalf of its clients
that require disclosure in ADV Part 1. Certain clients have established asset transfer
authorizations which permit the qualified custodian to rely upon instructions from IAS to
transfer client funds or securities to third parties. These arrangements are disclosed at Form
ADV Part 1, Item 9, but in accordance with the guidance provided in the SEC’s February 21,
2017 Investment Adviser Association No-Action Letter, the affected accounts are not
subject to an annual surprise CPA examination.
Item 16
Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we place trades
in a client's account without contacting the client prior to each trade to obtain the client's permission.
We place trades through a custodian by virtue of a limited power of attorney, solely allowing trade
authority. At no time may the Firm or its personnel withdraw funds to itself or to a third party with the
exception of management fees as outlined in Item 15.
Our discretionary authority includes the ability to do the following without contacting the client:
• determine the security to buy or sell; and/or
• determine the amount of the security to buy or sell
Clients give us discretionary investment authority when they sign a discretionary agreement with our
Firm, and may limit this authority by giving us written instructions. Clients may also change or amend
such limitations by once again providing us with written instructions.
Individual trades are usually executed through the client's custodian for their discounted commissions,
ease of clearing, and for the speed and accuracy of trading information. To the extent that other
broker/dealers may offer better executions, trades may be executed elsewhere on an exception basis.
17
Voting Client Securities
As a matter of Firm policy, we do not vote proxies on behalf of clients. Therefore, although our Firm
may provide 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, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. 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.
We do not offer any consulting assistance regarding proxy issues to clients.
Item 18 Financial Information
There is no financial condition that is reasonably likely to impair the Firm’s ability to meet its
contractual commitments to its clients.
14
Additional Brochure: JULY 1, 2026 ADV (2026-07-23)
View Document Text
Part 2A of Form ADV:
Firm Brochure
9303 New Trails Drive
Suite 450
The Woodlands, TX 77381
Telephone: 281-364-0606
Email:cj@iaswealth.com
Web Address: www.iaswealth.com
07/01/2026
This brochure provides information about the qualifications and business practices of
IAS Wealth Management, Inc. If you have any questions about the contents of this
brochure, please contact us at 281-364-0606 or cj@iaswealth.com. The information in
this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about IAS Wealth Management, Inc. also is available on the
SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. Our Firm's CRD number is 112486.
Item 2 Material Changes
This Firm Brochure, dated 07/01/2026, provides you with a summary of IAS Wealth Management,
Inc. advisory services fees, professionals, certain business practices and policies, as well as actual or
potential conflicts of interest, among other things. This brochure is used to provide our clients with a
summary of new and/or updated information and any revision(s) based on the nature of the
information as follows.
1. Annual Update: We are required to update certain information at least annually, within
90 days of our Firm’s fiscal year end (FYE) of December 31.
2. Material Changes: Should a material change in our operations occur, depending on its nature
we will promptly communicate this change to our clients (and it will be summarized in this
Item). "Material changes" requiring prompt notification will include changes of ownership or
control; location; disciplinary proceedings; significant changes to our advisory services or
advisory affiliates – any information that is critical to a client’s full understanding of who we
are, how to find us, and how we do business.
This Brochure does include a number of minor editorial changes and the updated information on our
assets under management.
Currently, our Brochure may be requested free of charge by contacting CJ Haynes, Chief Compliance
Officer.
Contact Information:
CJ Haynes
Chief Compliance Officer
Email: cj@iaswealth.com
Phone: 281-364-0606
Address: 9303 New Trails Drive, Suite 450
The Woodlands, TX 77381
2
Item 3
Table of Contents
Page
Item 1
Cover Page
1
Item 2
Material Changes
2
Item 3
Table of Contents
3
Item 4
Advisory Business
4
Item 5
Fees and Compensation
6
Item 6
Performance Based Fees and Side By Side Management
9
Item 7
Types of Clients
9
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
9
Disciplinary Information
Item 9
Item 10 Other Financial Industry Activities and Affiliations
11
11
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
11
Item 12
Brokerage Practices
12
Item 13
Review of Accounts
13
Item 14
Client Referrals and Other Compensation
13
Item 15
Custody
13
Item 16
Investment Discretion
14
Item 17 Voting Client Securities
14
Item 18
Financial Information
15
3
Item 4 Advisory Business
IAS Wealth Management, Inc. ("IAS") is an SEC-registered investment adviser with its principal
place of business in The Woodlands, Texas. Founded in 1994 by John Lester Haynes, IAS is a
privately owned advisory firm. Effective July 1, 2026, Henry A. Stevens and Jason Henry became
equity owners of the firm alongside founder, and majority shareholder, John Lester Haynes.
The officers of IAS Wealth Management, Inc. are: John L. Haynes, Chairman; Henry A. Stevens,
President; CJ Haynes, Chief Compliance Officer and Vice President; Curt E. Beck, Secretary,
Treasurer, and Vice President; and Jason Henry, Vice President.
As a fiduciary, IAS provides financial planning and investment advisory services to clients on a
consolidated fee-only basis.
As part of our team approach, services are provided utilizing the expertise of team members,
assuring our clients will have the opportunity of a long-term relationship with the advisors and the
Firm.
Through personal discussions with you, we listen carefully to gain a thorough understanding of your
unique goals and objectives based on your particular circumstances. As appropriate, we also review
and discuss a your prior investment history, as well as family composition and background. We
work with you, utilizing various tools and conversations to determine the best approach for you. As
part of the advisory process we work with each client to answer the following three questions:
Where are you now? Where do you want to be? And, How do you get there?
We manage investment advisory accounts on a discretionary basis. Account management is
guided by the client's stated objectives (i.e., capital preservation, current income, income and
growth, or long-term growth) as well as tax considerations. We will maintain a disciplined
approach to rebalancing your portfolio to match your allocation within your risk tolerance
levels. Your portfolio is designed and maintained with the goal of managing your risk to
match your stage in life as well as maximize tax efficiency. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors by
providing written instructions.
The team will work closely with clients to review any necessary changes to the portfolio based on the
following:
• Change in financial situation
• Change in goals
• Change in risk tolerance
• Diversification
IAS also provides customized services to clients, as needed, to help the client with their overall
financial picture, which may include:
• Ongoing discretionary investment management
• Periodic rebalancing
• Tax optimization and tax loss harvesting as applicable
• Collaboration with CPA and estate planning professionals
• Portfolio personalization, as applicable
4
• Financial planning as appropriate
• Assignment of a personal financial advisor or team
• Quarterly Reporting of holdings and performance
•
Investment advice to retirement accounts
VALUE PROPOSITION
Organization – we will assist in bringing order to your financial life assimilating all of your financial
assets and liabilities into one central portal.
Partnership – we will partner with you, collaboratively to understand your financial needs and goals,
and ultimately assist you in the best financial life for you and your family.
Accountability – we will follow through on our financial commitments to you.
Objectivity – We provide objective, unbiased advice designed to keep your financial decisions focused
on your long-term goals rather than short-term emotions or market events.
Proactivity – we will be proactive in anticipating life transition issues in your life and assisting you to be
financially prepared for them.
Education – we will constantly work to secure or maintain the knowledge necessary to assist you with
the financial decisions that impact success for your particular situation.
THIRD-PARTY INVESTMENT ADVISORS SERVICES
IAS may use the services of third-party investment advisors as sub-advisors. If we choose this option, we
will select a third-party investment advisor whose style and talent best fit your individual needs and
objectives. Your agreement with us gives us the authority to hire or fire these managers on your behalf.
Once a third-party investment advisor is selected, we will continue to monitor their performance. If you
are interested in learning more about any of these third-party investment advisors and their services, a
complete description of their programs, services, fees, payment structure and termination features are
found in their service disclosure brochures. Our advisory responsibility is to select and monitor any third-
party investment advisor that provides services to us. Factors that we consider in their selection may
include their size, how long they have been in business, the experience level and turnover of their
portfolio managers, and a review of their historical performance and risk measurements.
In deciding to use a third-party investment adviser to manage your assets, we consider your risk
tolerance, goals, objectives, time horizons, and general financial situation. We also consider your level of
investment experience and the assets you have available for investment. If you were to go to these third-
party investment advisors on your own, the fees they charge you may be more or less than going through
us. However, when using their services directly, you will not receive our expertise in developing an
investment strategy, selecting the third-party investment advisors to use, monitoring the performance of
your account, and changing third-party investment advisors if needed.
AMOUNT OF MANAGED ASSETS
As of 06/30/2026, we have discretionary assets under management of $588,550,000.
5
Item 5
Fees and Compensation
The annualized fee for services provided is charged as a percentage of assets under management,
according to the following schedule:
Assets Under Management
Annual Fee
First 2 Million
Next 8 Million
Above 10 Million
1.00%
0.60%
0.40%
We may group certain related client accounts within the same household for the purposes of achieving
the minimum account size requirements and/or to provide breakpoint pricing to the client. Management
fees are payable in advance on a quarterly basis by multiplying the assets under management by the
relevant annualized percent and dividing such product by four (4). Accounts opened in mid quarter may
be assessed a prorated management fee. Fees may be deducted from the client's account(s) held by the
Custodian within thirty (30) days from the beginning of the quarter for which said fees will be incurred.
We retain the discretion to waive minimum fees based upon relationship.
Third Party Investment Adviser Services: The fees for third-party advisory services that are utilized for
the management of a portion of your portfolio will be paid directly to the third-party adviser. The third-
party advisor fees will directly debit your account held by the Custodian for their fees. Clients will receive
a full disclosure of the fee schedule for the services provided to you, along with the third-party advisor’s
brochure or equivalent disclosure document, and their privacy policy, prior to placing the assets with the
third-party advisor selected.
Other Compensation: Neither IAS Wealth Management, Inc., or its team representatives, accept
compensation from the sale of securities or other investment products.
Limited Changes to Advisory Fees: Although IAS Wealth Management, Inc. has established the
aforementioned fee schedule(s), we retain the discretion to alter fees on a client by client basis. Factors
that may be considered are the complexity of client circumstances and account composition. The
specific annual fee schedule is identified in the contract between the adviser and each client.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees
and expenses charged by custodians and imposed by broker-dealers, including, but not limited to, any
transaction charges imposed by a broker-dealer with which an independent investment manager effects
transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this
Form ADV for additional information.
Grandfathering of Adviser Fees: Pre-existing advisory clients are subject to IAS Wealth Management,
Inc. advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our
Firm's advisory fees will differ among clients.
6
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be
available from other registered (or unregistered) investment advisers for higher, similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in
excess of $1,200 more than six months in advance of services rendered.
GENERAL INFORMATION
The Investment Management Agreement is effective upon the date of signing. The Agreements shall be
for one year in duration from the date of acceptance by both parties to this contract and automatically
renewed for additional one year terms unless terminated prior thereto as indicated under "Termination of
the Advisory Relationship.
Termination of the Advisory Relationship:
A client agreement may be canceled at any time, by either party, for any reason upon receipt of written
notice. Notwithstanding the above, if the appropriate disclosure statement was not delivered to the client
at least 48 hours prior to the client entering into any written or oral advisory or consultation contract with
us, then the client has the right to terminate the relationship contract without penalty within five (5)
business days after entering into the contract. As disclosed above, certain fees are paid in advance of
services provided. Upon termination of any account, any prepaid unearned fees will be refunded within
10 days. In calculating the reimbursement of fees to a client, we will pro rate the reimbursement
according to the number of days remaining in the billing period.
Limitation of Financial Planning and Investment Consulting/Implementation Services
To the extent specifically requested by a client (depending on the nature of the issue presented) IAS
may provide limited financial planning and related consulting services regarding non-investment
related matters, such as estate planning, tax planning, insurance, etc., however IAS does not serve
as an attorney, accountant, or insurance agency, and no portion of our services should be construed
as same. Accordingly, IAS does not prepare estate planning documents, tax returns or sell
insurance products. To the extent requested by a client, we may recommend the services of other
professionals for certain non-investment implementation purposes (i.e. attorneys, accountants,
insurance, etc.) You are under no obligation to engage the services of any of such recommended
professionals. The client retains absolute discretion overall for such implementation decisions and
is free to accept or reject any recommendation that we make. Please note: It remains the client’s
responsibility to promptly notify IAS if there is ever any change in his/her financial situation or
investment objectives for the purpose of reviewing/evaluating/revising IAS’s previous
recommendations or services.
ERISA/IRC Fiduciary Acknowledgement
If a client is (i) a retirement plan (“Plan”) organized under the Employment Retirement Income
Security Act of 1974 (“ERISA”); (ii) a participant or beneficiary of a plan subject to Title I of
ERISA or described in section 4975§ (1)(A) of the Internal Revenue Code with authority to direct
investment of assets in his or her Plan account or take a distribution; (iii) the beneficial owner of
an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or (iv) a Retail Fiduciary
with respect to a plan subject to Title I of ERISA or described in section 4975§ (1)(A) of the
Internal Revenue Code; then the firm represents that it and its representatives are fiduciaries under
ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by
7
the firm or its representatives or with respect to any investment recommendations regarding an
ERISA Plan or participant or beneficiary account.
ERISA Accounts:
IAS Wealth Management, Inc. is deemed to be a fiduciary to advisory clients that are employee
benefit plans or rollover individual retirement accounts (IRAs) pursuant to the Employee
Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue
Code of 1986 (the "Code"), respectively. As such, our Firm is subject to specific duties and
obligations under ERISA and the Internal Revenue Code that include among other things,
restrictions concerning certain forms of compensation. To avoid engaging in prohibited
transactions, IAS Wealth Management, Inc. does not receive any commissions or 12b-1 fees.
Retirement Rollovers-Potential for Conflict of Interest
As part of our investment advisory services to you, we may recommend you withdraw the assets
from your employer’s (or former employer’s) retirement plan and roll the assets over to an
individual retirement account (IRA) that we will manage on your behalf. If you elect to roll assets
to an IRA that is subject to our management, we will charge you an asset-based fee as set-forth in
the management agreement executed by you with our firm. This practice presents a conflict of
interest because providing investment advice and suggesting a roll-over of assets will generate fee-
based compensation to the firm. You are under no obligation, contractually or otherwise, to
complete a rollover. Moreover, if you do not complete the rollover, you are under no obligation to
have the assets in the IRA or employer plan to be managed by our firm.
An employee will typically have four options:
Leave the funds in your employer’s (or former employer’s) plan
1.
2. Moving funds to a new employer’s retirement plan
3.
4.
Cashing out and taking a taxable distribution from the plan
Rolling the funds into an IRA account.
Each of these options has advantages and disadvantages and we encourage you to speak with your
CPA and/or Tax Attorney. It is important you understand the differences between these types of
accounts and decide whether a rollover is best for you.
Mutual Fund/ETF Fees: All fees paid to IAS Wealth Management, Inc. by clients for investment
advisory services are separate and distinct from the fees and expenses charged by mutual funds
and/or ETFs to their shareholders. Mutual funds and ETF fees and expenses are described in their
prospectus. These fees will generally include a management fee, and other fund expenses. A
client could invest in a mutual fund directly, without our services. In that case, the client would
not receive the services provided by our Firm which are designed, among other things, to assist the
client in determining which mutual fund or funds are most appropriate to each client's financial
condition and objectives. Our Firm considers the cost of a mutual fund to be an important variable
in the selection process. On certain mutual funds, we will have access to share classes which may
have lower costs than a share class an individual could purchase directly. Accordingly, the client
should review both the fees charged by the funds and our fees to fully understand the total amount
of fees to be paid by the client and to thereby evaluate the advisory services being provided.
8
Item 6
Performance Based Fees and Side By Side Management
IAS Wealth Management, Inc. does not charge performance based fees nor does it engage in side by
side management.
Item 7
Types of Clients
IAS Wealth Management, Inc. provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
•
• High net worth individuals
• Trusts
• Estates
• Business Owners
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
IAS Wealth Management, Inc. utilizes a team-based investment committee. Herein
referred to as the “Committee”. The Committee maintains a Select List of
investments for portfolio construction. The Committee determines which securities to
add to or delete from the List, utilizing a number of sources.
Equity Securities
Individual selections/maintenance of Equities will generally be based on fundamental
factors as to the Company quality, market cap, sector, credit rating, revenue, earnings,
EPS growth rates, dividend distributions, relative valuation and other factors.
Technical factors utilized when buying/selling the position may consider short -term
volume and price movement, relative stock price position to the 50 and 200 -day
moving averages and other factors.
Equity Mutual Funds will be selected based on the overall Fund Family, the
manager(s) experience, size of fund, style of management (growth/value/balanced),
average market cap, sector weighting, performance relative to peers and benchmark,
unrealized capital gains, expense ratio and other factors.
ETF’s will be selected based on quality of the Corporate Sponsor, size and liquidity
of ETF, sector or theme representation, performance relative to peers and benchmark,
expense ratio and other factors.
Individual Fixed Income Securities
Fixed Income Securities and Mutual Funds that hold fixed -income securities will be
selected on accessibility, types of holdings, credit quality, duration and cost.
Resources Used in Analysis
Analyst’s reports - S&P (CFRA), Zacks, Morningstar, Fidelity and various other
sources.
Investment Research - Fidelity, IBD, MarketSmith, Barron’s, WSJ, S&P Outlook,
Sevens’ Report, Yahoo Finance, Clearnomics, other periodicals and business news
9
including Bloomberg, CNBC, and Fox Business.
Meetings, Webinars, Web content - Fidelity, Mutual Fund and ETF providers
The Committee meets periodically as warranted, to discuss any additions and deletions from the IAS
Select list. Additionally, economic, market and other actions are discussed.
INVESTMENT STRATEGIES
Our Firm manages client accounts on an individualized basis.
Any investment strategies used in managing client accounts will be based on the needs of each
client and consistent with our understanding of a client's investment objectives, risk tolerance, and
time horizon among other considerations.
We attempt to manage risk through appropriate diversification including allocation between equity
securities and fixed income securities and cash.
Our investment recommendations are not limited to any specific product or service offered by a
broker/dealer company and will generally include advice regarding the following securities:
•
•
•
•
•
•
•
•
•
Mutual Fund shares
Exchange Traded Fund shares (ETF’s)
Publicly traded Equity securities
Corporate debt securities
Municipal securities
Certificates of Deposit
United States government and agency securities
Real Estate Investment Trusts (REITS)
Separately Managed Accounts (SMA’s)
Our Firm will generally look to buy/ hold positions for the long term (one year or longer) but will sell
or reduce holdings when appropriate based on valuation, adjustments to portfolio allocation,
opportunity to add portfolio tax efficiency, or fundamental changes that affect the position.
Our investment philosophy does not generally warrant making investment decisions based on short
term purchases or trading. Additionally, we do not utilize strategies based on leverage of risk
through the use of margin transactions whereby a portfolio can purchase more stock than the
available cash would allow.
Risk of Loss: While our Firm seeks to "preserve and grow" our clients' assets, investment securities
are not guaranteed and you may lose money on your investments. We ask that clients work with us
to help us understand their tolerance for risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to clients or prospective
clients for evaluation of our advisory business or the integrity of our management.
Our Firm, established in 1994 and our personnel have no reportable disciplinary events to disclose now
or since inception of the firm.
10
Item 10 Other Financial Industry Activities and Affiliations
Our Firm and our related persons are not engaged in other financial industry activities and have no
other industry affiliations.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Our Firm, acting as a fiduciary has adopted a Code of Ethics which sets forth high ethical standards
of business conduct we require of our employees, including compliance with applicable federal and
state securities laws.
IAS Wealth Management, Inc., and our personnel owe a duty of loyalty, fairness, and good faith
towards our clients, and have an obligation to adhere not only to the specific provisions of the
Code of Ethics but to the general principles that guide the Code.
The Code of Ethics describes the general code of conduct the firm expects of all employees of
IAS, and specifically focuses on three specific areas where employee conduct has the potential to
adversely affect the client:
• Misuse of nonpublic information
• Personal securities trading
• Outside business activities
Our Code of Ethics includes policies and procedures for the review of securities transaction statements
and/or initial and annual securities holdings reports which are provided by the Firm’s access persons.
IAS Wealth Management, Inc.’s Code of Ethics further includes the Firm's policy prohibiting
the use of material non- public information. While we do not believe we have any particular
access to non- public information, and all employees are reminded that such information may
not be used in a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may
request a copy by email sent to: cj@iaswealth.com or by calling us at 281-364-0606.
The guiding principles of all aspects of the firm’s business and represent the requirements to which the
firm expects employees to adhere:
• Client’s interest come before employee’s personal interests and before the Firm’s interests.
• The firm will always fully disclose any material facts about conflict of interest between the
firm and the client as well as between Firm employees and clients.
• Employees must operate on the Firm’s behalf and on their own behalf consistently with the
Firm’s disclosures and appropriately manage any conflicts.
• The Firm and its employees must comply with all Federal and State applicable securities laws.
• The Firm and its employees will not take inappropriate advantage of their position of trust and
responsibility to clients.
The Code of Ethics contains a policy against the use of nonpublic information in conducting business
for the Firm. Employees may not convey nonpublic information or depend upon it for making personal
or client’s securities trades.
Individuals of the Firm, may buy, sell or hold the same securities in their personal accounts as the Firm
11
recommends to its clients. This creates a potential conflict of interest with the possibility of Firm
personnel obtaining a better price than clients obtain. To mitigate this conflict, such trades may occur
on the same day at the same time receiving average pricing or after the client with the client receiving
the same or better pricing. Additionally, all trades by employees must be pre-approved when involving
reportable securities such as individual equities, Exchanged Traded Funds (ETF), and other securities
priced on an active basis.
Employees are required to submit reports of personal securities trades on a quarterly basis, and
securities holdings annually. These reports are reviewed by the Chief Compliance Officer to ensure
compliance with the Firm’s policies.
Item 12 Brokerage Practices
For discretionary clients, IAS Wealth Management, Inc. requires clients to provide us with written
authority to execute trades on their behalf with the custodian.
These clients must include any limitations on this discretionary authority in the written
authority statement. Clients may change/amend these limitations as required. Such
amendments must be provided to us in writing.
IAS Wealth Management, Inc. will aggregate trades where possible and when advantageous to
clients, however due to the individual nature of each portfolio, block trading may not be available.
The blocking of trades permits the trading of aggregate blocks of securities for multiple client
accounts.
IAS Wealth Management, Inc. has an arrangement with National Financial Services LLC, and
Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity") through
which Fidelity provides our Firm with their "institutional platform" services. The platform
services include, among others, brokerage, custodial, administrative support, record keeping, and
related services. These services are intended to support intermediaries like IAS Wealth Management,
Inc. in conducting business and in serving the best interests of clients. However, they may also
benefit IAS Wealth Management, Inc.
Fidelity's institutional platform services assist us in managing and administering clients' accounts
include software and other technology that:
facilitate payment of fees from clients' accounts; and
• provide access to client account data (such as trade confirmations and account statements);
•
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• provide research, pricing, and other market data;
•
• assist with back office functions, record keeping, and client reporting.
We receive these benefits because of our clients’ relationships with Fidelity, but have no formal soft
dollar arrangements and receive no compensation from Fidelity. These benefits provided by Fidelity
might assist us with the administration of client accounts, and thus slightly help our profitability,
thus creating a potential conflict of interest with clients. We believe this is not a material conflict.
Directed Brokerage
As a matter of policy and practice, IAS Wealth Management, Inc. may accept directed brokerage from
12
clients. Clients should be aware that when we facilitate a client's request to direct their brokerage, our
Firm does not generally block the client directed brokerage trades; and, therefore, we implement client
transactions separately for each account. Consequently, certain client trades may be executed before
others and at a different price.
Item 13 Review of Accounts
While the underlying securities within Individual Portfolio Management Services accounts are
continually monitored by the team of advisors, all client accounts are reviewed at least quarterly.
Accounts are reviewed in the context of each client's stated investment objectives and guidelines. The
client is responsible for communicating his/her needs, goals, and objectives to the Firm in a timely
manner and to alert us to any changes in their needs, goals, and objectives. More frequent reviews may
be triggered by material changes in variables such as the client's individual circumstances, or the
market, political, or economic environment.
In addition to the monthly statements and confirmations of transactions that clients receive from
their broker/dealer, we provide quarterly reports summarizing account performance, balances, and
holdings.
Item 14 Client Referrals and Other Compensation
It is IAS Wealth Management, Inc.’s policy not to engage solicitors or to pay related or non-related
persons for referring potential clients to our Firm.
Item 15 Custody
Our Firm does not and will not have actual or constructive custody of client funds or
securities. We previously disclosed in the "Fees and Compensation" section (Item 5) of this
Brochure that our Firm directly debits advisory fees from client accounts. The client has the
responsibility to direct which account(s) the fee will be charged. There may be certain tax
consequences that occur as a result of this decision and a client should discuss any tax
consequences with their tax adviser.
Payment of our management fees may be made by the custodian holding the client's funds and securities
only when all three of the following criteria are met:
1.
2.
3.
The client provides us with written authorization permitting their fees to be paid directly from
his/her account that are held by the custodian;
The Firm sends the client an invoice showing the fee amount due, the value on which the fee
was calculated, and the method of calculation;
The custodian sends a statement to the client at least quarterly indicating the advisory fees that
were paid directly as well as any other disbursements from the account.
As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted
from that client's account.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for
clients to carefully review their custodial statements to verify the accuracy of the calculation, among
other things. Clients should contact us directly if they believe that there may be an error in their
statement.
13
In addition to the periodic statements that clients receive directly from their custodians, we also send
account statements directly to our clients on a quarterly basis. We urge our clients to carefully
compare the information provided on these statements to ensure that all account transactions, holdings,
and values are correct and current.
Please Also Note: Other Custody Situations:
IAS Wealth Management, Inc. engages in practices and/or services on behalf of its clients
that require disclosure in ADV Part 1. Certain clients have established asset transfer
authorizations which permit the qualified custodian to rely upon instructions from IAS to
transfer client funds or securities to third parties. These arrangements are disclosed at Form
ADV Part 1, Item 9, but in accordance with the guidance provided in the SEC’s February 21,
2017 Investment Adviser Association No-Action Letter, the affected accounts are not
subject to an annual surprise CPA examination.
Item 16
Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we place trades
in a client's account without contacting the client prior to each trade to obtain the client's permission.
We place trades through a custodian by virtue of a limited power of attorney, solely allowing trade
authority. At no time may the Firm or its personnel withdraw funds to itself or to a third party with the
exception of management fees as outlined in Item 15.
Our discretionary authority includes the ability to do the following without contacting the client:
• determine the security to buy or sell; and/or
• determine the amount of the security to buy or sell
Clients give us discretionary investment authority when they sign a discretionary agreement with our
Firm, and may limit this authority by giving us written instructions. Clients may also change or amend
such limitations by once again providing us with written instructions.
Individual trades are usually executed through the client's custodian for their discounted commissions,
ease of clearing, and for the speed and accuracy of trading information. To the extent that other
broker/dealers may offer better executions, trades may be executed elsewhere on an exception basis.
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Voting Client Securities
As a matter of Firm policy, we do not vote proxies on behalf of clients. Therefore, although our Firm
may provide 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, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. 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.
We do not offer any consulting assistance regarding proxy issues to clients.
Item 18 Financial Information
There is no financial condition that is reasonably likely to impair the Firm’s ability to meet its
contractual commitments to its clients.
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