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3333 Premier Drive, Suite 800
Plano, TX 75023
972.543.4800 | www.insightwp.com
Firm Contact: Wayne Smith, III, CCO
1. Cover Page
Firm Brochure (Form ADV Part 2A)
March 2025
This brochure provides information about the qualifications and business practices of Insight Wealth Partners,
LLC. If you have any questions about the contents of this brochure, please contact by telephone at 972.543.4800
or email at info@insightwp.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 Insight Wealth Partners, LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov by searching CRD # 153635.
Please note that the use of the term “registered investment adviser” and description of Insight Wealth Partners,
LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged
to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more
information on the qualifications of our firm and its employees.
Dear Valued Client:
Thank you for choosing Insight Wealth Partners, LLC to serve you in your financial planning needs. Our
mission is to help you determine and implement a personal wealth strategy that allows you to focus on
leading a purposeful, fulfilling life. We appreciate the opportunity to work together with you in achieving
your goals.
At IWP, we know that every client is unique and requires a customized approach to financial planning.
We also understand that all areas of a client’s financial life are highly integrated. That’s why we use a
thorough and disciplined approach, first to fully understand your goals and what really matters to you,
and then to ensure that all areas of your financial life are aligned to realize those goals. As an
independent, fee-only investment advisory firm, we only work for you and have no hidden agendas. Our
only goal is to help you achieve yours.
As an SEC - Registered Investment Adviser firm, we file a complete disclosure of our advisory business
with the SEC on Form ADV. The following disclosure Brochure is Part 2A of this Form ADV. The Brochure
provides important information on the services that we offer as well as how we receive compensation
for our services. It also gives important details on many other aspects of our advisory business.
If you have any questions regarding the information in this Brochure, please talk to your advisor or
contact me directly at 972.543.4800 between 8:30 a.m. and 5:00 p.m. Central time. Again, thank you for
allowing us to partner with you in achieving your dreams.
Best Regards,
Wayne Smith, III, CFP®, CRPC®, CKA®
CERTIFIED FINANCIAL PLANNER™ Practitioner
CHARTERED RETIREMENT PLANNING COUNSELORSM
CERTIFIED KINGDOM ADVISOR®
Managing Partner | Chief Compliance Officer
Insight Wealth Partners, LLC |
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2. Material Changes
Insight Wealth Partners, LLC is required to advise you of any material changes to our Firm Brochure
(“Brochure”) from our last annual update, identify those changes on the cover page of our Brochure or
on the page immediately following the cover page, or in a separate communication accompanying our
Brochure. We must state clearly that we are discussing only material changes since the last annual
update of our Brochure, and we must provide the date of the last annual update of our Brochure.
Since our last annual amendment filing on 03/06/2024, we have the following material change(s) to
disclose:
Our firm has disclosed that we may have a financial affiliation with Absolute Capital
Management (“Absolute Capital”) that allows our clients to utilize their platform in order to
actively managed held away assets. Please see items 10 & 14 of our firm’s Form ADV Part 2A or
reach out to Insight Wealth Partners, LLC for additional information or questions.
Insight Wealth Partners, LLC | 2. Material Changes
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3. Table of Contents
1. Cover Page .............................................................................................................................................. 1
Firm Brochure (Form ADV Part 2A) ......................................................................................................... 1
2. Material Changes .................................................................................................................................... 3
3. Table of Contents .................................................................................................................................... 4
4. Advisory Business .................................................................................................................................... 5
Advisory Services - Financial Advice ........................................................................................................ 5
Comprehensive Personal Financial Planning ....................................................................................... 5
Referrals to Third Party Money Managers .......................................................................................... 6
Advisory Services - Professional Asset Management ............................................................................. 7
Traditional Portfolio Management ...................................................................................................... 7
Synthetic Equity Portfolio Management ............................................................................................. 8
Pension Consulting .............................................................................................................................. 9
5. Fees and Compensation ........................................................................................................................ 10
6. Performance-Based Fees & Side-By-Side Management ....................................................................... 11
7. Types of Clients and Account Requirements ........................................................................................ 11
8. Methods of Analysis, Investment Strategies, and Risk of Loss ............................................................. 12
9. Disciplinary Information........................................................................................................................ 16
10. Other Financial Industry Activities and Affiliations ............................................................................ 16
11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................... 17
12. Brokerage Practices ............................................................................................................................ 18
13. Review of Accounts or Financial Plans ................................................................................................ 22
14. Client Referrals and Other Compensation .......................................................................................... 22
15. Custody ............................................................................................................................................... 26
16. Investment Discretion ......................................................................................................................... 27
17. Voting Client Securities ....................................................................................................................... 27
18. Financial Information .......................................................................................................................... 27
Insight Wealth Partners, LLC | 3. Table of Contents
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4. Advisory Business
We specialize in the following types of services: Asset management, financial planning and consultations,
referrals to third party money managers, and pension consulting. As of 12/31/2024 We manage
$968,636,261 on a discretionary basis and $1,648,370 on a non-discretionary basis. In addition, we have
$118,525,418 in assets under advisement for a total of $1,088,810,049 in Assets Under Administration.
We provide individuals and other types of clients with a wide array of investment advisory services. Our
firm is a limited liability company formed in the State of Texas. Our firm has been in business as an
investment adviser since 2010 and is owned as follows:
Owner
David Dryden
Travis Carter
Wayne Smith III
M. Chad Lowe
Ryan Ferguson
Ownership Percentage
20%
20%
20%
20%
20%
Advisory Services - Financial Advice
Comprehensive Personal Financial Planning
We provide a variety of financial planning and consultation services to individuals, families, and other
clients regarding the management of their financial resources based upon an analysis of the client’s
current situation, goals, and objectives. Generally, such financial planning services will involve preparing
a financial plan or rendering a financial consultation for clients based on the client’s financial goals and
objectives. This planning or consulting may encompass one or more of the following areas: Investment
Planning, Retirement Planning, Estate Planning, Employer Benefits Analysis, Employer Stock Option
Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost
Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance
Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning.
Our financial planning or financial consultations rendered to clients usually
include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish
education or charitable giving programs. It should also be noted that we refer clients to an accountant,
attorney, or other specialist, as necessary for non-advisory-related services. For financial planning
engagements, we may provide our clients with a written summary of their financial situation,
observations, and recommendations. For financial consulting engagements, we usually do not provide
Insight Wealth Partners, LLC | 4. Advisory Business
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our clients with a written summary of our observations and recommendations, as the process is less
formal than our planning service. Implementation of the recommendations will be at the discretion of
the client.
We charge on an hourly or flat fee basis for financial planning and consultation services. The total
estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of
our engagement with you. Our hourly fees are $350 for financial advisors, $150 per hour for para-
planners and $75 for administrative time.
We generally charge first-year financial planning or consultation services fee of $2,500 to $20,000.
Annual or ongoing financial planning fees are generally flat fees and typically range from $1,000 to
$15,000 per year depending upon time and complexity. The client, on an annual basis, can choose to
renew their financial planning and consultation services. Annual financial planning and consultation
services fees can be paid in advance by direct billing or billed on a quarterly basis and deducted from
their managed account.
We generally require the first-year financial planning or consultation services fee in advance. In all cases,
we will not require a retainer exceeding $1,200 when services cannot be rendered within 6 (six) months
of the engagement.
Referrals to Third Party Money Managers
We provide clients with a list of investment advisory services of third-party professional portfolio
management firms for the individual management of client accounts. As part of this process, we assist
clients in identifying an appropriate third-party money manager. We provide initial due diligence on third
party money managers and ongoing reviews of their management of your account.
To assist clients in the selection of a third-party money manager, we typically gather information from
the client about their financial situation, investment objectives, and reasonable restrictions they can
impose on the management of the account, which are often very limited. It is important to note that we
do not offer advice on any specific securities or other investments in connection with this service.
Investment advice and trading of securities is only offered by or through the third-party money managers
to clients.
We periodically review third party money managers’ reports provided to the client, but no less often
than on an annual basis. Our associates contact the clients from time to time, as agreed to with the
client, to review their financial situation and objectives; communicate information to third party money
managers as warranted; and assist the client in understanding and evaluating the services provided by
the third-party money manager. The client will be expected to notify us of any changes in his/her
financial situation, investment objectives, or account restrictions that could affect their account. The
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client may also directly contact the third-party money manager managing the account or sponsoring the
program.
We are paid by third party money managers when we refer you to them and you decide to open a
managed account. Third party money managers pay us a portion of the investment advisory fee that
they charge you for managing your account. Fees paid to us by third party money manager are generally
ongoing. All fees we receive from third party money managers and the written separate disclosures
made to you regarding these fees comply with Rule 206(4)-3 of the Investment Advisers Act of 1940. The
separate written disclosures you need to be provided with include a copy of the third-party money
manager’s Form ADV Part 2, all relevant Brochures, a Solicitation Disclosure Statement detailing the
exact fees we are paid and a copy of the third-party money manager’s privacy policy. The third-party
money managers we recommend will not directly charge you a higher fee than they would have charged
without us introducing you to them.
Third party money managers establish and maintain their own separate billing processes which we have
no control over. In general, they will directly bill you and describe how this works in their separate
written disclosure documents.
Advisory Services - Professional Asset Management
Traditional Portfolio Management
We provide individualized investment advice and emphasize continuous and regular account
supervision. As part of our asset management service, we generally create a portfolio, consisting of
individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds, annuities, 401(k),
403(b), 457 and other public and private securities, investments and/or accounts. Traditional Portfolio
Management is our investment strategy based upon Modern Portfolio Theory that comprises both
strategic and tactical asset allocation as a core strategy with satellite opportunities using sector rotation
or momentum-based modeling. The client’s individual investment strategy is tailored to their specific
needs and may include some or all the previously mentioned securities. Each portfolio will be initially
designed to meet a particular investment goal, which we determine to be suitable for the client’s
circumstances. Once the appropriate portfolio has been determined, we review the portfolio regularly
and, if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and
objectives. Each client can place reasonable restrictions on the types of investments to be held in the
portfolio.
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Traditional Portfolio
Assets Under Management
$0 - $250,000
$250,001 - $750,000
$750,001 - $1,500,000
$1,500,001 - $3,000,000
$3,000,001 - $6,000,000
Over $6,000,000
Annual Percentage of Assets
Charge
1.50%
1.25%
1.00%
0.85%
0.65%
0.50%
Insurance and/or annuity products may be recommended to certain clients if suitable for the client’s
particular facts and circumstances. An advisor, in their individual capacity as a licensed insurance agent,
may receive a commission for the sale of these products. To the extent that an advisor receives a
commission for the sale of an insurance or annuity product, no advisory fees will be charged on the
related assets even though they may be a part of the overall investment strategy. In addition, to the
extent that assets within insurance or annuity products are incorporated into the overall asset
management strategy, they will be considered as assets under management which may allow a client to
qualify for lower advisory fee rates on all remaining assets under management as outlined in the table
above. Please see Item 10 of this Brochure for more information about our firm’s licensed
representatives and fees generated using insurance products.
Synthetic Equity Portfolio Management
We emphasize continuous and regular account supervision for our Synthetic Equity Strategy Portfolio.
As part of our asset management service, we generally create a portfolio, consisting of individual stocks
or bonds, exchange traded funds (“ETFs”), options, mutual funds, annuities, 401(k), 403(b), 457 and
other public and private securities, investments, and/or accounts. Synthetic Equity Strategy attempts to
mirror the upside momentum of the major market indices while preserving the downside risk exposure
by using a heavily weighted fixed-income portfolio combined with advanced options strategies such as
puts, calls, and leaps. Each portfolio will be tailored to meet your particular investment goal while
utilizing the strategy we’ve developed. Our strategy is aimed at replicating the upward momentum of
the broad equity market while maintaining a higher level of principal stability (relative to traditional
equity investments) during periods of decline. Once the appropriate portfolio has been determined, we
review the portfolio regularly, and if necessary, rebalance the portfolio based upon the client’s individual
needs, stated goals and objectives. Each client can place reasonable restrictions on the types of
investments to be held in the portfolio.
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Synthetic Equity Portfolio Assets
Under Management
$0 - $300,000
$300,001 - $1,000,000
$1,000,001 - $2,000,000
$2,000,001 - $3,000,000
$3,000,001 - $5,000,000
$5,000,001 - $10,000,000
Over $10,000,000
Annual Percentage
of Assets Charge
1.95%
1.75%
1.50%
1.25%
1.00%
0.75%
0.50%
Insurance and/or annuity products may be recommended to certain clients if suitable for the client’s
particular facts and circumstances. An advisor, in their individual capacity as a licensed insurance agent,
may receive a commission for the sale of these products. To the extent that an advisor receives a
commission for the sale of an insurance or annuity product, no advisory fees will be charged on the
related assets even though they may be a part of the overall investment strategy. In addition, to the
extent that assets within insurance or annuity products are incorporated into the overall asset
management strategy, they will be considered as assets under management which may allow a client to
qualify for lower advisory fee rates on all remaining assets under management as outlined in the table
above. Please see Item 10 of this Brochure for more information about our firm’s licensed
representatives and fees generated using insurance products.
Pension Consulting
We provide pension consulting services to employer plan sponsors. Generally, such pension consulting
services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their
company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of
advising could include investment options, plan structure and participant education.
All pension consulting services shall follow the applicable State law(s) regulating the services provided
by this Agreement. This section applies to an Account that is a pension or other employee benefit plan
(a “Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If
the client accounts are part of a Plan, and we accept appointments to provide our services to such
accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but only
with respect to the provision of services described in section 1 of the Pension Consulting Agreement).
Client represents that (i) Adviser’s appointment and services are consistent with the Plan documents, (ii)
Client has furnished Adviser true and complete copies of all documents establishing and governing the
Plan and evidencing your authority to retain Adviser. Client further represents that they will promptly
furnish Adviser with any amendments to the Plan, and Client agrees that, if any amendment affects our
rights or obligations, such amendment will be binding on Adviser only with our prior written consent. If
Insight Wealth Partners, LLC | 4. Advisory Business
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the Account contains only a part of the assets of the Plan, Client understands that Adviser will have no
responsibilities for the diversification of all the Plan’s investments, and Adviser will have no duty,
responsibility or liability for the assets that are not in the account. If ERISA or other applicable law
requires bonding with respect to the assets in the account, Client will obtain and maintain at his/her/its
expense bonding that satisfies this requirement and covers Adviser and any of our affiliates.
Pension Assets Monitored
$0 - $1,000,000
$1,000,001 - $5,000,000
$5,000,001 - $20,000,000
$20,000,001 - $100,000,000
Over $100,000,000
Annual Percentage of Assets
Charge
1.00%
0.75%
0.75% - 0.50%
0.50% - 0.25%
0.20%
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your
account on the last day of the previous quarter. Fees will be adjusted for deposits and withdrawals of
$25,000 or more made during the quarter and will be deducted from your managed account. Our firm
bills on cash unless indicated otherwise in writing. In limited instances our firm will agree to direct billing
as an option to our asset management clients. As part of this process, you understand and acknowledge
the following:
• Your independent custodian sends statements at least quarterly to you showing the market
values for each security included in the Assets and all disbursements in your account including
the amount of the advisory fees paid to us;
• You provide authorization permitting us to be directly paid by these terms. We send our invoice
•
directly to the custodian; and
If we send a copy of our invoice to you, it will include a legend urging you to compare information
provided in our statement with those from the qualified custodian.
5. Fees and Compensation
Please refer to section 4 of this Brochure for a description of our brokerage, custody, fees and fund
expenses so you will know how much you are charged and by whom for our advisory services provided
to you. Our fees are negotiable in certain circumstances.
Clients will incur transaction charges for trades executed by their chosen custodian via individual
transaction charges. These transaction fees are separate from our fees and will be disclosed by the firm
that the trades are executed through. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction
fees for U.S. listed equities and exchange traded funds. Fidelity Brokerage Services (“Fidelity”) eliminated
Insight Wealth Partners, LLC | 5. Fees and Compensation
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transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic
delivery of statements or maintain at least $1 million in assets at Fidelity. Clients who do not meet either
criteria will be subject to transaction fees charged by Fidelity for U.S. listed equities and exchange traded
funds.
Clients may also pay holdings charges imposed by their custodian for certain investments, as well as
charges imposed directly by a mutual fund, index fund, or exchange-traded fund, which shall be disclosed
in the fund’s prospectus (e.g., fund management fees, distribution fees, surrender charges, variable
annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market
makers, fees for trades executed away from custodian, wire transfer fees, and other fees and taxes on
brokerage accounts and securities transactions). Our firm does not receive a portion of these fees.
Please see Item 10 of this Brochure for more information about fees generated using insurance and
annuity products.
We charge our advisory fees quarterly in advance on all assets that are considered part of the advisor’s
investment strategy, which may include cash, illiquid securities, and other alternative investments. If you
wish to terminate our services, we will refund the unearned portion of our advisory fee to you. You need
to contact us in writing and state that you wish to terminate our services. Upon receipt of your letter of
termination, we will proceed to close out your account and process a pro-rata refund of unearned
advisory fees.
Financial Planning clients may terminate their agreement at any time before the delivery of a financial
plan by providing written notice. For the purpose of calculating refunds, all work performed by us up to
the point of termination shall be calculated at the hourly rate disclosed in the signed consulting
agreement. Clients will receive a pro-rata refund of unearned fees based on the time and effort
expended by our firm.
We do not sell securities for a commission. To sell securities for a commission, we would need to have
our associated persons registered with a broker-dealer. We have chosen not to do so.
6. Performance-Based Fees & Side-By-Side Management
We do not charge performance fees to our clients.
7. Types of Clients and Account Requirements
We offer advisory services to the following types of clients:
•
Individuals and High Net Worth Individuals;
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• Trusts, Estates or Charitable Organizations;
• Pension and Profit-Sharing Plans;
• Corporations, limited liability companies and/or other business types.
Our requirements for opening and maintaining accounts or otherwise engaging us:
• We do not require a minimum account balance for our Portfolio Management services, but we
require a minimum annual advisory fee of $1,000 for accounts under management. Generally,
this minimum advisory fee requirement is negotiable.
• We generally charge a minimum first-year fee of $2,500 for financial planning services.
8. Methods of Analysis, Investment Strategies, and Risk of
Loss
Methods of Analysis
• Charting: In this type of technical analysis, we review charts of market and security activity to
identify when the market is moving up or down and to predict when how long the trend may last
and when that trend might reverse.
• Cyclical Analysis: In this type of technical analysis, we measure the movements of a particular
stock against the overall market to predict the price movement of the security.
• Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company itself) to determine if the company is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to
sell). Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market
regardless of the economic and financial factors considered in evaluating the stock.
• Technical Analysis: We analyze past market movements and apply that analysis to the present
to recognize recurring patterns of investor behavior and potentially predict future price
movement. Technical analysis does not consider the underlying financial condition of a company.
This presents a risk in that a poorly managed or financially unsound company may underperform
regardless of market movement.
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Investment Strategies we use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations.
• Cash & Cash Equivalents: Cash & Cash Equivalents generally refer to either United States Dollars
or highly liquid short-term debt instruments such as but not limited to, treasury bills, bank CD’s
and commercial papers. Generally, these assets are considered nonproductive and will be
exposed to inflation risk as well as considerable opportunity cost risk. Further it is important to
note that investments in Cash & Cash Equivalents will generally return less than the advisory fee
charged by our firm. Our firm will from time to time use Cash and Cash Equivalents as part of our
clients’ asset allocation when deemed appropriate, such as but not limited to, when employing
the Traditional Portfolio Management strategy.
The use of Cash and Cash Equivalents is an integral part of the Synthetic Equity Portfolio
Management strategy. When we believe that a market decline or asset class decline may occur,
we may consider holding a larger Cash & Cash equivalent position. This may allow us to
potentially invest in assets at a lower price. It is important to note that our firm considers Cash
and Cash Equivalents as an asset class when we tactically allocate a portion of our client’s assets
to a cash position; we consider this position actively managed and bill on these positions
according to the agreed upon fee for our advisory services.
• Long-Term Purchases: When utilizing this strategy, we may purchase securities with the idea of
holding them for a relatively long time (typically held for at least a year). A risk in a long-term
purchase strategy is that by holding the security for this length of time, we may not take
advantage of short-term gains that could be profitable to a client. Moreover, if our predictions
are incorrect, a security may decline sharply in value before we make the decision to sell.
Typically, we employ this sub-strategy when we believe the securities to be undervalued; and/or
we want exposure to an asset class over time, regardless of the current projection for this class.
The potential risks associated with this investment strategy involve a lower-than-expected
return, for many years in a row. Lower-than-expected returns that last for a long time and/or
that are severe in nature would have the impact of dramatically lowering the ending value of
your portfolio and thus could significantly threaten your ability to meet financial goals.
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Insight Wealth Partners, LLC | 8. Methods of Analysis, Investment Strategies, and Risk of
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• Short-Term Purchases: When utilizing this strategy, we may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). We do this to take
advantage of conditions that we believe will soon result in a price swing in the securities we
purchase. The potential risk associated with this investment strategy is associated with the
currency or exchange rate. Currency or exchange rate risk is a form of risk that arises from the
change in price of one currency against another. The constant fluctuations in the foreign currency
in which an investment is denominated vis-à-vis one's home currency may add risk to the value
of a security. Currency risk is greater for shorter term investments, which do not have time to
level off like longer term foreign investments.
• Trading: We may purchase securities with the idea of selling them very quickly (typically within
30 days or less). We do this to take advantage of our predictions of brief price swings. Trading
involves risk that may not be suitable for every investor and may involve a high volume of trading
activity. Each trade generates a commission and the total daily commission on such a high volume
of trading can be considerable. Active trading accounts should be considered speculative in
nature with the objective being to generate short-term profits. This activity may result in the loss
of more than 100% of an investment. However, lack of trading does not indicate that there is not
active management of the portfolio. Lack of trading of positions may indicate a desire for a long-
term hold on a given security, or that conditions for the continued growth of the investment still
exist. In addition, current tax circumstances and laws may influence whether a security is bought
or sold.
• Short Sales: We may borrow shares of a stock for your portfolio from someone who owns the
stock on a promise to replace the shares on a future date at a certain price. Those borrowed
shares are then sold. On the agreed-upon future date, we buy the same stock and return the
shares to the original owner. We engage in short selling based on our determination that the
stock will go down in price after we have borrowed the shares. If we are correct and the stock
price has gone down since the shares were purchased from the original owner, the client account
realizes the profit. The two primary perceived risks of short selling are that the in the long term,
markets trend upward and short selling can expose investors to potentially unlimited risk. Due to
the “upside gap”, sellers risk not being able to react until after a significant loss has already been
incurred.
• Margin Transactions: We may purchase stocks for your portfolio with money borrowed from
your brokerage account. This allows you to purchase more stock than you would be able to with
your available cash and allows us to purchase stock without selling other holdings. Margin
accounts and transactions are risky and not necessarily for every client. The potential risks
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Insight Wealth Partners, LLC | 8. Methods of Analysis, Investment Strategies, and Risk of
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associated with these transactions are (1) You can lose more funds than are deposited into the
margin account; (2) the force sale of securities or other assets in your account; (3) the sale of
securities or other assets without contacting you; and (4) you may not be entitled to choose
which securities or other assets in your account(s) are liquidated or sold to meet a margin call.
• Option Writing: We may use options as an investment strategy. An option is a contract that gives
the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a
specific price on or before a certain date. An option, just like a stock or bond, is a security. An
option is also a derivative because it derives its value from an underlying asset. The two types of
options are calls and puts. A call gives us the right to buy an asset at a certain price within a
specific period of time. We will buy a call if we have determined that the stock will increase
substantially before the option expires. A put gives us the holder the right to sell an asset at a
certain price within a specific period of time. We will buy a put if we have determined that the
price of the stock will fall before the option expires. We will use options to "hedge" a purchase
of the underlying security; in other words, we will use an option purchase to limit the potential
upside and downside of a security we have purchased for your portfolio. We use "covered calls",
in which we sell an option on security you own. In this strategy, you receive a fee for making the
option available, and the person purchasing the option has the right to buy the security from you
at an agreed-upon price. We use a "spreading strategy", in which we purchase two or more
option contracts (for example, a call option that you buy and a call option that you sell) for the
same underlying security. This effectively puts you on both sides of the market, but with the
ability to vary price, time and other factors. The potential risks associated with these transactions
are that (1) all options expire. The closer the option gets to expiration, the quicker the premium
in the option deteriorates; and (2) Prices can move very quickly. Depending on factors such as
time until expiration and the relationship of the stock price to the option’s strike price, small
movements in a stock can translate into big movements in the underlying options.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market
may increase and your account(s) could enjoy a gain, it is also possible that the stock market may
decrease, and your account(s) could suffer a loss. It is important that you understand the risks associated
with investing in the stock market, are appropriately diversified in your investments, and ask us any
questions you may have.
We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit,
high-grade commercial paper and/or government backed debt instruments at our chosen custodians.
Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low-risk
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Insight Wealth Partners, LLC | 8. Methods of Analysis, Investment Strategies, and Risk of
Loss
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to Portfolio
Management services, as applicable.
9. Disciplinary Information
We do not have legal or disciplinary events material to client’s or prospective client’s evaluation of our
advisory business or the integrity of our management.
10. Other Financial Industry Activities and Affiliations
Representatives of our firm are licensed insurance agents. Insurance and/or annuity products may be
recommended to clients with specific client circumstances. Because of these transactions, our
representatives receive normal and customary commissions. In addition to the generated commissions,
some insurance carriers or brokers may also pay for travel to conferences, reimburse expenses
associated with the sale of insurance products and/or compensate our representatives in addition to
generated commissions for meeting certain production goals. As such, a conflict of interest exists as
these commissionable sales and additional compensation create an incentive to recommend products
based on the compensation earned and the individual’s production quota. The recommendation of these
insurance or annuity products will only be made if suitable for the client. Clients are under no obligation
to purchase any of these products and are free to seek out similar products sold by other carriers.
Insurance and/or annuity fees may be higher or lower than what the client currently pays as part of our
Traditional Portfolio Management or Synthetic Equity Portfolio Management service. To the extent that
an advisor receives a commission for the sale of an insurance or annuity product, no advisory fees will
be charged on the related assets even though they may be a part of an overall investment strategy. In
addition, to the extent assets within insurance or annuity products are incorporated into the overall
asset management strategy, they will be considered as assets under management which may allow a
client to qualify for lower advisory fee rates on all remaining assets under management.
Since we may recommend or select other third-party investment advisers for our clients and receive
compensation directly or indirectly from those advisers, or have other business relationships with those
advisers, please refer to Item 4 of this Brochure for a description of these practices, a discussion of the
conflicts of interest these practices create, and how we address them.
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16
Absolute Capital Management
Our firm may have a financial affiliation with Absolute Capital Management (“Absolute Capital”) that
allows our clients to utilize their platform in order to actively managed held away 401k assets. Conflicts
of interest exist as our firm receives compensation for these referrals as well as this service can only be
provided to plan participants of retirement plans. To mitigate these conflicts of interest, our firm will act
in the client’s best interest. For more information regarding our referral relationship with Absolute
Capital, please see item 14.
in Client
11. Code of Ethics, Participation or Interest
Transactions and Personal Trading
In accordance with and pursuant to SEC rule 204A-1, we recognize that the personal investment
transactions of members and employees of our firm demand the application of a high Code of Ethics and
require that all such transactions be carried out in a way that does not endanger the interest of any
client. At the same time, we believe that if investment goals are similar for clients and for members and
employees of our firm, it is logical and even desirable that there be common ownership of some
securities.
Therefore, to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing
procedure) with respect to transactions effected by our members, officers and employees for their
personal accounts 1 . To monitor compliance with our personal trading policy, we have a quarterly
securities transaction reporting system for all our associates.
Furthermore, our firm has established a Code of Ethics which applies to all our associated persons. An
investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to
provide fair and full disclosure of all material facts and to act solely in the best interest of each of our
clients always. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying
principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions
Policies and Procedures. We require all our supervised persons to conduct business with the highest
level of ethical standards and to comply with all federal and state securities laws always. Upon
employment or affiliation and at least annually thereafter, all supervised persons will sign an
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate,
his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee
or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of
his/her household has a direct or indirect beneficial interest in.
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Insight Wealth Partners, LLC | 11. Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our
firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.
This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential
client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which
our firm or a related person has a material financial interest without prior disclosure to the client.
Related persons of our firm may buy or sell securities and other investments that are also recommended
to clients. To minimize this conflict of interest, our related persons will place client interests ahead of
their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or
selling the same securities prior to buying or selling for our clients in the same day unless included in a
block trade.
12. Brokerage Practices
Our firm does not maintain custody of client assets (although our firm may be deemed to have custody
of client assets if given the authority to withdraw assets from client accounts. See Item 15 Custody,
below). Client assets must be maintained in an account at a “qualified custodian,” generally a broker-
dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division of Charles
Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC as well as Fidelity
Institutional Wealth Services (“FIWS”) through Fidelity Brokerage Services LLC, registered broker-dealers
with FINRA/SIPC as the qualified custodians. Our firm is independently owned and operated and not
affiliated with Schwab or FIWS. Schwab and FIWS will hold client assets in a brokerage account and buy
and sell securities when instructed. While our firm recommends that clients use Schwab or FIWS as
custodian/broker, clients will decide whether to do so and open an account with Schwab or FIWS by
entering into an account agreement directly with them. Our firm does not open the account.
As part of the arrangement described above, Schwab and/or FIWS makes certain research and brokerage
services available at no additional cost to our firm. These services include certain research and brokerage
services, including research services obtained by Schwab and/or FIWS directly from independent
research companies, as selected by our firm (within specific parameters). Research products and services
provided by Schwab and/or FIWS to our firm may include research reports on recommendations or other
Insight Wealth Partners, LLC | 12. Brokerage Practices
18
information about, particular companies or industries; economic surveys, data and analyses; financial
publications; portfolio evaluation services; financial database software and services; computerized news
and pricing services; quotation equipment for use in running software used in investment decision-
making; and other products or services that provide lawful and appropriate assistance by Schwab and/or
FIWS to our firm in the performance of our investment decision-making responsibilities. The research
and brokerage services are used by our firm to manage accounts for which we have investment
discretion. Without this arrangement, our firm might be compelled to purchase the same or similar
services at our own expense.
Because of receiving the services discussed above of this Firm Brochure for no additional cost, we have
an incentive to continue to use or expand the use of Schwab’s and/or FIWS’ services. Our firm examined
this potential conflict of interest when we chose to enter the relationship with Schwab and/or FIWS and
we have determined that the relationship is in the best interest of our firm’s clients and satisfies our
client obligations, including our duty to seek best execution.
Schwab and/or FIWS charges brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are
charged for debt securities transactions). However, Schwab recently eliminated transaction fees for U.S.
listed equities and exchange traded funds. FIWS also recently eliminated transaction fees for U.S. listed
equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain
at least $1 million in assets at Fidelity. Schwab and/or FIWS enable us to obtain many no-load mutual
funds without transaction charges and other no-load funds at nominal transaction charges. Schwab’s
and/or FIWS's commission rates are generally discounted from customary retail commission rates. The
commission and transaction fees charged by Schwab and/or FIWS's may be higher or lower than those
charged by other custodians and broker-dealers.
Clients may pay a commission to Schwab and/or FIWS that is higher than another qualified broker dealer
might charge to execute the same transaction where we determine in good faith that the commission is
reasonable in relation to the value of the brokerage and research services received. In seeking best
execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s
services, including the value of research provided, execution capability, commission rates, and
responsiveness. Accordingly, although we will seek competitive rates, to the benefit of all clients, we
may not necessarily obtain the lowest possible commission rates for specific client account transactions.
In certain circumstances, our firm may utilize the brokerage services provided by Northern Capital
Securities Corporation (“Northern Capital”), member FINRA/SIPC, and RBC Correspondent Services, a
division of RBC Capital Markets, LLC (“RBC”), member NYSE/FINRA/SIPC. Neither Northern Capital nor
RBC are affiliated with our firm or its representatives. As the introducing broker, Northern Capital shall
transmit fixed income orders to RBC for the execution of trades. Northern Capital will clear these
Insight Wealth Partners, LLC | 12. Brokerage Practices
19
transactions in an RBC broker-dealer account established in the name of our firm and designated for our
client accounts established at Schwab and/or FIWS.
Our firm will transmit the details for each transaction to Northern Capital to be executed through RBC,
including, but not limited to, the client account name and number, contract amount, the security
involved, the number of shares or units, and whether the transaction was a long or short sale or a
purchase. Factors considered in using Northern Capital to effect trades in client accounts include
potentially better trade price execution, research and trade recommendations, individual holdings
monitoring and alerts, economic and sector updates, etc. Our firm does not receive compensation from
Northern Capital or RBC, nor are we under any obligation to use their services. Schwab and/or FIWS may
charge “trade away” fees to the client for allowing a third party to effect trades in the account, which
may potentially result in a higher cost of the transaction for the client. We will only use a third party if
we determine in good faith that the additional “trade away” fees are reasonable in relation to the value
obtained by placing the trade through the third-party broker.
Although the investment research products and services that may be obtained by our firm will generally
be used to service all our clients, a brokerage commission paid by a specific client may be used to pay
for research that is not used in managing that specific client’s account.
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will generally
be used to service all our clients but not necessarily all at any one particular time..
Educational & Due Diligence Travel Reimbursements
Our representatives will occasionally receive reimbursements to cover travelling costs while attending
industry educational conferences. These reimbursements are often provided by the products sponsors
or vendors who stand to benefit from our use of their products being evaluated. Such payments are not
in any way contingent upon our use of their products and our advisors will continue to act as fiduciaries
in our clients’ best interests.
As a fiduciary, we have an obligation to obtain "best execution" of clients' transactions under the
circumstances of the particular transaction. Consequently, notwithstanding the safe harbor provided
under Section 28(e), no allocation for soft dollar payments shall be made unless best execution of the
transaction is reasonably expected to be obtained.
Our firm does not receive brokerage commissions or fees for client referrals. Neither we nor any of our
firm’s related persons have discretionary authority in making the determination of the brokers with
whom orders for the purchase or sale of securities are placed for execution, and the commission rates
at which such securities transactions are executed.
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Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through
a specific broker or dealer to obtain goods or services on behalf of the plan. Such direction is permitted
provided that the goods and services provided are reasonable expenses of the plan incurred in the
ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA
prohibits directed brokerage arrangements when the goods or services purchased are not for the
exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan brokerage
provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan.
Special Considerations for Sub-Advisory Management Clients
a. We select brokers and dealers for any purchase or sale of assets of Client Accounts and are
responsible for obtaining best execution for transactions. Consistent with this idea, we may, in
the allocation of portfolio brokerage business and the payment of brokerage commissions,
consider the brokerage and research services furnished to the Sub-Adviser by brokers and
dealers, in accordance with the provisions of Section 28(e) of the Securities Exchange Act of 1934,
as amended. Such research generally will be used to service all our clients, but brokerage
commissions paid by the Client Accounts may be used to pay for research that is not used in
managing the Client Accounts.
b. Should a Client direct in writing that the Adviser or our firm use a specific broker or dealer, then
such Client will negotiate terms and arrangements for their Account with that broker or dealer
and we will not seek better execution services or prices from other broker-dealers. As a result,
such Client Account may pay higher commissions or greater spreads, or receive less favorable net
prices, on transactions for the Client Account than would otherwise be the case.
c. Adviser and our firm are not responsible or liable for the acts or omissions of any broker-dealer.
We perform investment management services for various clients. There are occasions on which portfolio
transactions may be executed as part of concurrent authorizations to purchase or sell the same security
for numerous accounts served by our firm, which involve accounts with similar investment objectives.
Although such concurrent authorizations potentially could be either advantageous or disadvantageous
to any one or more particular accounts, they are affected only when we believe that to do so will be in
the best interest of the effected accounts. When such concurrent authorizations occur, the objective is
to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given
situation, we attempt to allocate trade executions in the most equitable manner possible, taking into
consideration client objectives, current asset allocation and availability of funds using price averaging,
proration and consistently non-arbitrary methods of allocation.
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13. Review of Accounts or Financial Plans
We review client portfolios regularly for our clients subscribing to the following services: Traditional
Portfolio Management, Synthetic Equity Portfolio Management, and Pension Consulting. Third Party
Money Management clients also receive regular reviews. The nature of these reviews is to learn whether
clients’ accounts are in line with their investment objectives, appropriately positioned based on market
conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will
conduct reviews. Clients will have daily access to account summaries and performance reports online.
Financial planning clients will not receive reviews of their plans unless they opt for our annual financial
planning service. We would contact the client to discuss updates to their plans, changes in their
circumstances, etc. and provide an updated plan on an annual basis. We may set up an account with
eMoney Advisor online which offers clients increased visibility of their accounts and overall financial
situation. Clients will be able to view their aggregate account data, have secure document storage, and
view presentations to provide analyses of their investments and financial planning services. Basic
account access is available to all active advisory clients. Clients who have also engaged in our annual
financial planning services will receive integrated financial planning and overall wealth management
advice and service in addition to basic account access.
14. Client Referrals and Other Compensation
Our firm receives economic benefit from Schwab in the form of the support products and services made
available to our firm and other independent investment advisors that have their clients maintain
accounts at Schwab. These products and services, how they benefit our firm, and the related conflicts of
interest are described above (see Item 12 – Brokerage Practices). The availability of Schwab’s products
and services is not based on our firm giving particular investment advice, such as buying particular
securities for our clients.
We may also execute or recommend that clients execute their securities transactions through Fidelity
Institutional Wealth Services (“FIWS”) through Fidelity Brokerage Services LLC, registered broker-dealers
with FINRA/SIPC.
FIWS may charge commissions (ticket charges) for executing our transactions. We do not receive any
part of these separate charges, which are assessed directly to you. FIWS does not have a role with respect
to our investment advisory accounts; however, they may serve as the broker-dealer in cases where
clients wish to execute recommendations as part of the implementation of a financial plan. It is
important to note that FIWS does not maintain supervisory relationships with respect to us or our
representatives nor are they in any way affiliated with it. We are independently owned and operated.
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22
We may recommend/require that clients establish accounts with FIWS to maintain custody of clients’
assets and to effect trades for their accounts. FIWS may provide us with access to their institutional
trading and custody services, which are typically not available to FIWS retail investors. FIWS ’s services
include brokerage custody, research and access to mutual funds and other investments that are
otherwise generally available only to institutional investors or would require a significantly higher
minimum initial investment.
For our firm’s Clients’ accounts maintained in their custody, FIWS does not charge separately for custody
but are compensated by account holders through commissions or other transaction-related fees or
securities trades that are executed through FIWS or that settle into FIWS. FIWS may charge an annual
fee to custody non-standard assets such as private investments and non-publicly traded real estate
investment trusts.
FIWS also makes available to us other products and services that may benefit us. These types of services
will help us in managing and administering client accounts. These include software and other technology
that provide access to client account data (i.e., trade confirmations and account statements); facilitate
trade executions; provide research, pricing information, and other market data; facilitate in the payment
of our fees from our clients’ accounts; and assist with back-office functions, record-keeping, and client
reporting. Many of these services may be used to service all or a substantial number of our accounts.
We may also execute or recommend/require that clients execute their securities transactions through
Northern Capital or RBC.
Northern Capital or RBC does not have a role with respect to our investment advisory accounts; however,
they may serve as the broker-dealer in cases where clients wish to execute recommendations as part of
the implementation of a financial plan. It is important to note that Northern Capital does not maintain
supervisory relationships with respect to us or our representatives nor are they in any way affiliated with
it. We are independently owned and operated.
We place trades for our Clients' accounts subject to our duty to seek best execution and other fiduciary
duties. We may use broker-dealers other than FIWS to execute trades for client accounts maintained at
FIWS, but this practice may result in additional costs to clients so that we are more likely to place trades
through FIWS rather than other broker-dealers. FIWS’s execution quality may be different from other
broker-dealers.
Additional Compensation/Services
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23
You should be aware that we receive research and execution related services from the parties mentioned
above to assist us in managing accounts. These services and products would include financial
publications, pricing information and other products or services. Such research and execution related
services are offered to all investment advisors who utilize these firms. The commissions charged by these
parties may be higher than those charged by a broker who does not provide the research and execution
related services.
Because receiving such services for no additional cost, we have an incentive to continue to use or expand
the use of Schwab, FIWS, Northern Capital, or RBC's services. We examined this potential conflict of
interest when we chose to enter the relationship with Schwab, FIWS, Northern Capital, and RBC and
have determined that the relationships are in the best interests of our clients and satisfies our client
obligations, including our duty to seek best execution. A client may pay a commission that is higher than
another qualified broker-dealer might charge to execute the same transaction where we determine in
good faith that the commission is reasonable in relation to the value of the brokerage and research
services received. In seeking best execution, the determinative factor is not the lowest possible cost, but
whether the transaction represents the best qualitative execution, taking into consideration the full
range of a broker-dealer’s services, including the value of research provided, execution capability,
commission rates, and responsiveness. Accordingly, although we will seek competitive rates, to the
benefit of all clients, it may not necessarily obtain the lowest possible commission rates for specific client
account transactions. Although the investment research products and services that may be obtained by
us will generally be used to service all our clients, a brokerage commission paid by a specific client may
be used to pay for research that is not used in managing that specific client’s account. Neither are we,
Schwab, FIWS, Northern Capital, nor RBC affiliates. No broker-dealer affiliated with us is involved in the
relationship between us and Schwab, FIWS, Northern Capital, or RBC.
Finally, one or more Investment Advisor Representatives may receive asset allocation advice, from time
to time, from one of several product sponsors. This advice can create a conflict of interest by influencing
the representative to use the investment products from that fund sponsor. If the fund sponsors
investment products are used, this conflict of interest will be managed by conducting due diligence on
the investments used to ensure that they meet the investment needs of the client. Relative fund
performance and principles guiding investment decisions will be among the factors used to evaluate the
appropriateness of the funds.
Product Sponsor Funded Events
Various product wholesalers provide financial assistance to allow us to sponsor client educational
seminars, or attend such seminars hosted by the product sponsor. This money is not directly tied to our
use of their products, nor is it contingent upon any future business to be directed to their products,
nonetheless it creates a conflict of interest that may incentivize us to utilize their products. Our firm will
Insight Wealth Partners, LLC | 14. Client Referrals and Other Compensation
24
adhere to our fiduciary duty to act in our client’s best interest when selecting what products to use in
client accounts.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or non-
cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which
include client referrals). Such compensation arrangements will not result in higher costs to the referred
client. In this regard, our firm maintains a written agreement with each unaffiliated person that is
compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the
equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206
(4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following
information will be disclosed clearly and prominently to referred prospective clients at the time of each
testimonial or endorsement:
• Whether or not the unaffiliated person is a current client of our firm,
• A description of the cash or non-cash compensation provided directly or indirectly by our firm to
the unaffiliated person in exchange for the referral, if applicable, and
• A brief statement of any material conflicts of interest on the part of the unaffiliated person giving
the referral resulting from our firm’s relationship with such unaffiliated person.
In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are
paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm is
paying solicitation fees to another registered investment adviser, the licensure of individuals is the other
firm’s responsibility.
Absolute Capital Management
Our firm has entered into and are currently a party to promoter’s agreements with Absolute Capital
whereby we receive payment for referring clients, in accordance with the requirements of Rule 206(4)-
1 of the Advisers Act and any corresponding state securities law requirements. For additional
information on Absolute Capital please refer to item 10.
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15. Custody
Deduction of Advisory Fees
While we do not maintain physical custody of client assets (which are maintained by a qualified
custodian, as discussed above), we are deemed to have custody of certain client assets if given the
authority to withdraw assets from client accounts, as further described below under “Third Party Money
Movement.” All our clients receive at least quarterly account statements directly from their custodians.
Upon opening an account with a qualified custodian on a client's behalf, we promptly notify the client in
writing of the qualified custodian's contact information. If we decide to also send account statements to
clients, such notice and account statements include a legend that recommends that the client compare
the account statements received from the qualified custodian with those received from our firm.
We encourage our clients to raise any questions with us about the custody, safety or security of their
assets. The custodians we do business with will send you independent account statements listing your
account balance(s), transaction history and any fee debits or other fees taken out of your account.
Third Party Money Movement
On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4)-2 (“Custody
Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the
Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third
party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has
adopted the following safeguards in conjunction with our custodians:
• The client provides instructions to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s account
number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s form
or separately, to direct transfers to the third party either on a specified schedule or from time to
time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the client’s authorization and provides a transfer of
funds notice to the client promptly after each transfer.
• The client can terminate or change the instruction to the client’s qualified custodian.
• The investment adviser has no authority or ability to designate or change the identity of the third
party, the address, or any other information about the third party contained in the client’s
instruction.
• The investment adviser maintains records showing that the third party is not a related party of
the investment adviser or located at the same address as the investment adviser.
Insight Wealth Partners, LLC | 15. Custody
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• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
16. Investment Discretion
We maintain discretion over our clients’ accounts. To give us discretionary authority our clients must
sign a discretionary investment advisory agreement. This type of agreement only applies to our
Traditional Portfolio Management and Synthetic Equity Portfolio Management clients. We do not take
or exercise discretion with respect to our other clients.
17. Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other
solicitations directly from their custodian or a transfer agent. If proxies are sent to our firm, our firm will
forward them to the appropriate client and ask the party who sent them to mail them directly to the
client in the future. In the case where our firm receives a duplicate proxy for a client, our firm will confirm
that it is a duplicate proxy, destroy the duplicate proxy, and ask the party who sent them to discontinue
sending duplicates to our firm in the future. Clients may call, write or email us to discuss questions they
may have about proxy votes or other solicitations.
Third party money managers selected or recommended by our firm may vote proxies for clients.
Therefore, except in the event a third-party money manager votes proxies, 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.
Therefore (except for proxies that may be voted by a third-party money manager), our firm and/or the
client shall instruct the qualified custodian to forward to copies of all proxies and shareholder
communications relating to the client’s investment assets.
18. Financial Information
We do not require, nor do we solicit prepayment of more than $1,200 in fees per client, when services
cannot be rendered within 6 (six) months of the engagement.
. Our firm does not take custody of client funds or securities. Therefore, we have not included a balance
sheet for our most recent fiscal year. We have never been the subject of a bankruptcy petition.
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