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Item 1 - Cover Page
4725 S. Monaco Street, Suite 335
Denver, CO 80237
303.716.5777
www.integrity-wealth.com
Form ADV Part 2A – Firm Brochure
06/20/2025
This brochure provides information about the qualifications and business practices of Integrity Wealth Solutions.
Please contact Clint Thomas (clint@integrity-wealth.com), Owner, or Justina Welch (justina@integrity-wealth.com),
Owner, at 303.716.5777, if you have any questions about the contents of this brochure.
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 Integrity Wealth Solutions is available on the Internet at www.adviserinfo.sec.gov.
You can search this site by a unique identifying number, known as a CRD number. The CRD number for Integrity
Wealth Solutions is 284862. Registration as a Registered Investment Adviser does not imply a certain level of skill
or training.
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Item 2 - Material Changes
Since the last annual update of our firm’s Form ADV Brochure, dated March 4, 2025, the Firm has no material
changes to report.
Full Brochure Available
Whenever you would like to receive a copy of our Firm Brochure, please contact us by telephone at: 303.716.5777
or by email at info@integrity-wealth.com.
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Item 3 – Table of Contents
Item 1 - Cover Page ....................................................................................................................................................... 1
Item 2 - Material Changes............................................................................................................................................. 2
Item 3 – Table of Contents ........................................................................................................................................... 3
Item 4 - Advisory Business ............................................................................................................................................ 4
Item 5 - Fees and Compensation .................................................................................................................................. 5
Item 6 - Performance-Based Fees and Side-By-Side Management .............................................................................. 7
Item 7 - Types of Clients ............................................................................................................................................... 7
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss ....................................................................... 7
Item 9 - Disciplinary Information .................................................................................................................................. 9
Item 10 - Other Financial Industry Activities and Affiliations ....................................................................................... 9
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................. 9
Item 12 - Brokerage Practices ..................................................................................................................................... 10
Item 13 - Review of Accounts ..................................................................................................................................... 11
Item 14 - Client Referrals and Other Compensation .................................................................................................. 11
Item 15 - Custody ........................................................................................................................................................ 12
Item 16 - Investment Discretion ................................................................................................................................. 12
Item 17 - Voting Client Securities ............................................................................................................................... 12
Item 18 - Financial Information .................................................................................................................................. 12
Part 2B of Form ADV Brochure Supplements ............................................................................................................. 13
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Item 4 - Advisory Business
Integrity Wealth Solutions (IWS) has been providing wealth management consulting services to clients since August
2016. The principal owners are Clint Thomas and Justina Welch. We have no public or privately-owned affiliated
companies.
IWS provides portfolio management and financial planning services, including investment advice to individuals and
families and ERISA retirement plans. Portfolio management services include developing an investment policy
statement, building portfolio recommendations, and implementing these recommendations at a third-party
custodian (see Custody) by entering purchase and sell orders on client’s behalf. Portfolio management services also
include the ongoing monitoring of the investment portfolio, including quarterly performance reporting, asset
allocation analysis, rebalancing and tax-loss harvesting recommendations. Investment recommendations are
primarily limited to open-end mutual funds and exchange-traded funds and help clients with existing positions in
individual stocks and bonds. We typically do not advise our clients to invest in individual stocks and bonds.
All client portfolios are customized and built for each individual relationship, although many clients will hold similar
securities and allocations. Although we will try and accommodate client’s requested portfolio restrictions to the
best of our ability, we may not be able to due to the nature of the mutual funds and ETFs in the portfolio. The
portfolio construction process begins with a discussion of the client's goals and risk tolerance to determine a
suitable long-term investment portfolio. We do not participate in wrap fee programs.
Financial planning services include retirement income planning, asset allocation/portfolio evaluation, education
funding planning, investment selection, income tax planning, risk management, multi-generational financial
planning, and general estate planning. If applicable, we will incorporate assets held outside of our firm into the
comprehensive financial planning process. Examples of these types of assets could be, but are not limited to, 401(k),
403(b), and 529 accounts.
IWS can engage a client in tax planning and estate planning discussions, although the firm does not prepare tax
returns and does not draft estate plan documents. The firm can work in concert with tax accountants and estate
attorneys to assist the client in determining the most proper plan regarding their income taxes and various estate
planning concerns.
For asset allocation and investment selection, IWS treats each client relationship as separate and unique. Portfolio
allocations of cash, fixed income, and equity mutual funds and ETFs and other types of investments are determined
on a client-by-client basis, based on discussions with each client as to their tolerance for risk. Investment selection
is also customized to utilize investments that may offer more tax-efficiency (municipal bonds or exchange-traded
funds, for example) for non-retirement accounts, depending on the client’s current income tax situation.
IWS provides ongoing monitoring and standard reporting on each client’s investment portfolio. Additionally, IWS
will schedule an annual financial planning meeting to review the client’s overall situation and update portions of
the financial plan, as required. In addition to reviewing portfolio composition and performance, these meetings
typically include tax planning, retirement planning, risk management and/or estate planning advice and
consultation.
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IWS portfolio management services may provide investment advice to some of its clients with held away assets,
such as annuities, 529 plans, 401(k), 403(b), TSP, or other employer retirement plans. This service allows IWS to
incorporate these assets into the client’s entire asset allocation, which thereby helps create a more diversified
portfolio tailored to the client’s goals and risk tolerance. Please note, we will not execute any trades in these types
of accounts, trading in these accounts will be the responsibility of the client.
IWS provides fiduciary services, including 3(21) fiduciary services, to ERISA retirement plans, including profit sharing
401(k) plans and defined benefit plans. These services include investment plan offering review and selection, model
portfolio development, monitoring and management and regular compliant reporting to plan sponsors.
IWS hereby acknowledges that it is a "fiduciary" when the firm’s services are subject to the provisions of ERISA of
1974, as amended.
As of December 31, 2024, IWS manages $276,554,504 assets under management on a discretionary basis and
$6,750 assets under management on a non-discretionary basis.
Item 5 - Fees and Compensation
IWS compensation depends on the type of advisory service we are performing. Please review the fee and
compensation information below.
Asset Management
IWS annual fee is calculated in accordance with the fee schedule below. Asset management services, including
financial planning and portfolio management, are provided on an active basis for accounts with an appropriate
minimum value, typically $500,000.
Assets Managed
$500,001 - $1,000,000
$1,000,001 - $3,000,000
$3,000,001 - $6,000,000
$6,000,001 - $10,000,000
$10,000,001 - $15,000,000
$15,000,001 - $25,000,000
$25,000,001 - $40,000,000
$40,000,001 - $55,000,000
$55,000,001 - $70,000,000
$70,000,001 - $85,000,000
$85,000,001 - $100,000,000
$100,000,001 and above
Annualized Fee
$5,000
$7,500
$10,000
$15,000
$25,000
$40,000
$60,000
$80,000
$100,000
$120,000
$140,000
Negotiable
Quarterly Fee
$1,250
$1,875
$2,500
$3,750
$6,250
$10,000
$15,000
$20,000
$25,000
$30,000
$35,000
Negotiable
IWS may accept asset management relationships under $500,000 in billable assets at our discretion. For
accounts that are within this range there is an annual fee of 1% charged quarterly determined based on the value
of the assets at the end of each calendar quarter. For relationships under $500,000, financial planning services
may be billed separately on a per-project basis.
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Fees for asset management will be pro-rated to the end of the initial calendar quarter and will be charged at the
beginning of each calendar quarter (in advance) thereafter based on the value of billable assets on the last business
day of prior calendar quarter end.
Clients terminating their contract with IWS within the first five days are entitled to a full refund. Should a client
terminate the relationship with IWS outside the five-day window, the unearned portion of the asset management
fee will be refunded.
Clients may elect to pay this fee directly or have the quarterly charge deducted from investment accounts. Please
refer to Custody on Page 11 for information regarding fees deducted from investment accounts.
For Clients that elect direct invoicing - IWS will invoice Client on a quarterly basis at the beginning of each calendar
quarter. Management fees will be due within 30 days of invoice billing date. Management fees not paid after 45
days from the beginning of the billable quarter may result in the termination of relationship with IWS.
Clients where IWS is providing asset management services on held away assets, clients may either pay our asset
management fee through a deduction from a taxable account (e.g., non-IRA or other non-retirement investment
account) held at the custodian of record or through direct invoicing.
IWS asset management fee and account minimums are negotiable under certain circumstances.
Clients may incur fees from the custodian selected to provide services related to record keeping, tax reporting and
statement production. These fees may include IRA and retirement account annual fees, nominal trade ticket
charges or banking fees. Clients will be subject to the annual operating expenses of the mutual funds and ETFs
themselves. Detailed information on mutual fund and ETFs expenses are contained in the prospectus for each fund
or ETF, which is delivered to clients by the custodian. No portion of these fees is retained by or remitted to IWS.
See Brokerage Practices.
Financial Planning Services
For new asset management clients with relationships under $500,000, the initial financial plan may be billed
separately on a one-time basis. After the initial financial plan, ongoing financial planning services are included in
the asset management fee. Asset management clients with relationships above $500,000, the financial planning
services are included in the asset management fee as outlined in the table above.
The typical fee for planning service is $3,000; however, this fee can range from $1,000 to $5,000, depending upon
the scope and complexity of the work to be performed.
At IWS discretion, IWS may accept one-time project-based financial planning on a fixed fee basis.
IWS will invoice Client upon completion and delivery of financial plan and fees will be due to IWS within 30 days.
Clients may terminate the agreement in writing and any earned portion of the fee, based upon the advisor’s
estimate of percentages of work completed, is due at the time of notice of termination.
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IWS may also provide advice on insurance (disability, long-term care, and life) and annuity products to its clients via
a relationship with insurance providers. IWS compensation is covered via the client’s annual asset management fee
or financial planning fee. No additional compensation is received from the insurance provider.
Retirement Plan Services
Retirement Plan “Consulting” fees for company sponsored retirement plans are generally based on plan size and
services rendered. Fees are determined on a case-by-case basis and typically range from 0.20% to 1.00% or an
agreed upon fixed fee.
Consulting fees will be pro-rated to the end of the initial calendar quarter and will be charged each calendar quarter
(in advance or arrears) thereafter based on the value of billable assets on the value of billable assets on the last day
of calendar quarter. Consulting fees are either deducted from plan assets or remitted directly to IWS based on
Client’s election.
Clients paying in advance who terminate their contract with IWS within the first five days are entitled to a full
refund. Should a client terminate the relationship with IWS outside the five-day window, the unearned portion of
the consulting fee will be refunded. Clients paying in arrears will incur a pro rata charge for services rendered prior
to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of
days in the quarter for which you are a client.
Item 6 - Performance-Based Fees and Side-By-Side Management
IWS does not charge performance-based fees.
Item 7 - Types of Clients
Our firm works primarily with individuals and families but also serves retirement plans, foundations, endowments,
and other non-profit organizations.
IWS currently requires a minimum relationship size of $500,000 of investable assets. Exceptions to this minimum
are allowed but must receive the approval of one of the principal officers of the firm.
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss
IWS’ core investment philosophy is built on the foundation of portfolio diversification and the client’s individual
asset allocation with the proper cash, fixed income, and equity mutual funds and ETFs based on their individual risk
tolerance. Our investment strategy begins with a general long-term acceptance of the Efficient Market Hypothesis,
which states that the primary driver of a portfolio’s risk and return characteristics is determined by asset allocation,
and not security selection. We will primarily utilize a passive investment strategy but will incorporate active
managers when deemed necessary. The primary vehicles recommended to IWS clients are mutual funds and
exchange-traded funds.
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IWS believes that an accurate prediction can never be made about which asset classes will outperform going
forward, we take a disciplined approach by allocating to many different asset classes, and then using rebalancing
to bring the portfolio back into alignment not only in terms of the mix among cash, fixed income, and equity mutual
funds and ETFs, but also keeping the proper style balance between large cap and small cap equity, growth versus
value, etc.
And, as with any stock-based investment, mutual funds, including index mutual funds, carry the risk of losses. While
we can reduce company-specific risk through diversification, eliminate manager-risk with passive portfolios and
reduce overall portfolio volatility with a broad mix of equity mutual funds and ETFs, fixed income, and other assets,
we cannot eliminate the risk of fluctuation that comes with investing in stocks and bonds. It is always possible in
any given week, month, or year that an investor’s portfolio value could be less than the previous period. For the
client that chooses to have a portfolio more heavily weighted in stock investments versus bond investments, he/she
needs to be prepared for a potential drop in the value of the portfolio of more than 20% during extremely volatile
market conditions. The Efficient Market Hypothesis dictates that it is this market risk that offers investors potential
long-term rewards, so we aim to reduce other previously mentioned risks wherever possible.
Risks of Specific Securities Used
We do not primarily recommend one particular type of security over another since each client has different needs
and a different tolerance for risk. Each type of security has its own unique set of risks associated with it and even
within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated
return of an investment, the higher the risk of loss associated with the investment. A description of the types of
securities we may recommend to you and some of their inherent risks are provided below.
Mutual Funds: Investments in mutual funds generally involve the same risks as investing in underlying equity or
fixed income securities. Nearly all mutual funds and closed-end funds have expenses that reduce net-of-fee
investment returns. Mutual funds carry the risk of rapid redemptions and forced selling. Closed-end funds carry
liquidity risk. Mutual fund prices may vary significantly from the Net Asset Value due to market conditions.
Exchange Traded Funds: Investing in an exchange traded fund (“ETF”) often involves the same risks as investing in
the underlying securities the ETF is tracking. ETF prices may vary significantly from the Net Asset Value due to
market conditions.
Buffer Funds: IWS may recommend Buffer Mutual Funds and/or Buffer ETFs to clients when suitable. Buffer funds
seek to provide investors with the upside of an asset’s returns (generally up to a capped percentage) while also
providing downside protection on the first predetermined percentage of losses. Buffer funds are designed to
safeguard against market downturns by employing complex options strategies. If the market performs well and
exceeds the buffer, the buffer fund will not enjoy gains beyond a certain point. If the market experiences losses
beyond the buffer, the buffer fund is exposed to open-ended losses. As buffer funds own options, they do not
receive dividends from their equity holdings. We encourage clients to carefully read the relevant prospectus to fully
understand the cost structures, risks, and features of these complex products.
Bonds: Corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk
can also vary widely based on the financial health of the issuer; the risk that the issuer might default; when the
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bond is set to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may
not be possible to replace it with a bond of equal character paying the same rate of return.
Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or
"stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it.
However, stock prices can be affected by many other factors including, but not limited to the class of stock (for
example, preferred or common); the health of the market sector of the issuing company; and the overall health of
the economy. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up
companies ("small cap") are but the mere size of an issuer is not, by itself, an indicator of the safety of the
investment.
Item 9 - Disciplinary Information
Neither Clint Thomas nor Justina Welch nor any employees of IWS have ever been convicted of, pled guilty or no
contest to any felony or misdemeanor in a criminal or civil action in any foreign or domestic court. Neither Clint
Thomas nor Justina Welch nor any employees of IWS have ever been part of a proceeding before the SEC or any
other industry regulatory agency. Neither Clint Thomas or Justina Welch nor any employees of IWS have ever been
part of a self-regulatory organization’s proceeding.
Item 10 - Other Financial Industry Activities and Affiliations
Neither Clint Thomas or Justina Welch nor any employees of IWS are registered or applying to register as a custodian
or a registered representative of a custodian, nor a futures commission merchant, commodity pool operator,
commodity trading advisor.
Neither Clint Thomas or Justina Welch nor any employee of IWS has a relationship with a broker dealer, municipal
securities dealer, government securities dealer or broker, investment company, outside investment adviser,
banking or thrift institution, accounting firm, law firm, insurance agency, pension consultant, real estate broker,
sponsor, or syndicator of limited partnerships.
IWS receives no compensation from outside investment advisers and receives no compensation other than the
asset management or financial planning fee paid by the firm’s clients.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
As a Registered Investment Adviser, IWS has a fiduciary duty to its clients. In the simplest of terms this means that
our first obligation is to put the client’s needs above all other interests or conflicts. IWS takes our fiduciary duty very
seriously and has built our business model around our obligation to minimize conflicts of interest with our clients
and to truly make recommendations that our in their best interests.
IWS’ owner and employees will adhere to all federal and state securities laws and regulations. All IWS related
persons will be held to the highest standard of conduct and shall not withhold pertinent information from clients
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regarding securities recommendations, act to deceive or defraud any client or outside party, or otherwise partake
in any activity with the intent to deceive or defraud any regulatory body, government office or client.
IWS’ owners and employees may buy or sell securities for themselves, which are also recommended to clients,
which represents a conflict of interest. To avoid conflicts of interest, IWS monitors and supervises the personal
securities transactions of all employees and its owners. Monitoring is conducted by Justina Welch, Chief Compliance
Officer of IWS. IWS retains records of all securities transactions conducted by employees and owners. For
compliance purposes with regulations, all employees and the owner are considered “access persons” whose
transactions will be monitored.
As a matter of principle IWS’ owner and employees are to withhold public comment regarding advice on individual
securities, as to avoid conflicts of interest when these comments may enrich the IWS associated person.
Item 12 - Brokerage Practices
Selection and Recommendation of Broker-dealers
IWS has a duty to select brokers dealers that provide best execution for clients. The duty of best execution requires
an investment adviser to seek to execute securities transactions for clients in such a manner that the client’s total
cost or proceeds in each transaction is the most favorable under the circumstances. The lowest possible
commission, while very important, is not the only consideration. Factors IWS may take into consideration include:
quality and promptness of overall execution services provided by the custodian; competitiveness of transaction fees
charged by the custodian; quality and accuracy of statements; availability of investment research and tools;
efficiency; and reputation. IWS typically recommends the implementation of any investment recommendation be
completed through Charles Schwab & Co., Inc. (“Schwab”), member FINRA/SIPC.
IWS evaluates the execution and performance of the broker-dealers it uses at least annually. IWS can elect to change
its broker/dealer at any time should it feel that Schwab is not providing an adequate level of service for the
associated costs.
Research and other soft dollar benefits
IWS does not have any formal soft dollar arrangements. However, as a registered investment adviser, we have
access to the institutional platform of your account custodian. As such, we will also have access to research products
and services from your account custodian. These products may include research reports, financial publications,
information about particular companies and industries, and other products or services that provide lawful and
appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Schwab
also makes available software and other technology that provides access to client account data (such as trade
confirmations and account statements); facilitates trade execution; facilitates payment of our fees from our clients’
accounts; and assists with back-office functions, recordkeeping, and client reporting. Such research products and
services are provided to all investment advisers that utilize the institutional services platform of Schwab and are
not considered to be paid for with soft dollars. The availability of these services from Schwab benefits us because
we do not have to produce or purchase them. This creates a conflict of interest, since we have an incentive to
request the use of Schwab, rather than making such a decision based exclusively on your interest in receiving the
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best value in custody services and the most favorable execution of your transactions. We believe, however, that
taken in the aggregate, our selection of Schwab as custodian and broker is in the best interests of our clients. Our
selection is primarily supported by the scope, quality, and price of Schwab’s services, and not the services that
benefit only us.
Brokerage for client referrals
IWS does not receive client referrals from any custodians.
Directed Brokerage
IWS will generally require clients to direct the Firm to execute transactions through a specified broker-dealer. Not
all investment advisers require their clients to direct brokerage.
Order Aggregation
We manage individual portfolios and not “model” portfolios. However, we may aggregate ETF trades in order to
obtain the best execution. If IWS decides to purchase or sell the same security for several clients at approximately
the same time, allocations are made in an equitable fashion, typically on a pro rata basis.
Item 13 - Review of Accounts
Clint Thomas and Justina Welch, Owners of IWS, review each client’s portfolio no less frequently than once per
quarter. At the end of each quarter IWS generates an updated Asset Allocation analysis and trailing period
performance report for all investment management clients. The Asset Allocation report is then compared to the
client’s signed Investment Policy Statement to analyze the variance from the target portfolio allocation.
Additionally, performance is compared to broad market averages to ensure that the client is capturing as much of
the long-term return of the market as possible. Clients will also receive monthly statements from their custodian
(i.e., Schwab). Accounts are also reviewed during an annual portfolio review meeting with the firm’s clients to
ensure that the advisory services provided to you and/or the portfolio mix are consistent with your current
investment needs and objectives.
Item 14 - Client Referrals and Other Compensation
IWS does not compensate existing clients or other outside professionals (such as CPAs, attorneys, etc.) for client
referrals. IWS also does not receive any economic benefit from someone who is not a client for providing investment
advice or other advisory services to our clients.
IWS does pay to be listed as a recommended financial advisor on certain third-party websites. These websites are
independent blogs and online communities that offer personal finance and investment information to their
audiences. These websites have a vetting process, and firms must meet certain criteria and be approved before
being listed. IWS does not receive client referrals from these websites in exchange for compensation; rather, the
payment is solely for the listing.
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Item 15 - Custody
IWS does not accept physical custody of client funds or securities but is deemed to have constructive custody where
IWS has authorization to deduct fees from client accounts. Additionally, certain clients have signed a Standing Letter
of Authorization (SLOA) that gives IWS third-party money movement authority.
For client accounts in which IWS is deemed to have custody the Firm will take the following steps:
i.
ii.
iii.
The client will provide written authorization to IWS, permitting IWS to be paid directly for the client’s
accounts held by the custodian.
IWS will send the client a written invoice itemizing the fee, including any formula used to calculate the fee,
the date range covered by the fee and the amount of assets under management on which the fee was
based.
The custodian will send at least quarterly statements to the client showing all disbursements for the
account, including the amount of the advisory fee.
Clients should receive at least quarterly statements from the custodian that holds and maintains client’s investment
assets. Clients of IWS are encouraged to carefully review such statements and compare official custodial records to
the account reports and invoices that IWS may provide to the client and notify IWS of any discrepancies. IWS reports
may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies
of certain strategies.
Item 16 - Investment Discretion
As outlined in our Asset Management Agreement, IWS requires discretionary authority over clients’ investment
portfolio under our management, including the type of security and number of shares. Having discretion over
mutual fund and ETF trades allows us to be more flexible for those clients who prefer not to discuss each trade with
us.
Item 17 - Voting Client Securities
IWS does not proxy vote for our clients’ investment positions. Clients will receive proxy solicitations directly from
the custodian. We are happy to discuss these solicitations with our clients.
Further, we will have no power, authority, responsibility, or obligation to take any action with regard to any claim
or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding
relating to securities held at any time in a client account, including without limitation, to file proofs of claim or other
documents related to such proceeding, or to investigate, initiate, supervise, or monitor class action or other
litigation involving client assets.
Item 18 - Financial Information
IWS does not require the prepayment of more than $1,200 in fees six months or more in advance. IWS has no
outstanding liabilities or financial impairments that would inhibit our ability to provide promised services to clients.
No owner or employee of IWS has ever filed for bankruptcy.
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Part 2B of Form ADV Brochure Supplement for:
Clint Thomas
Integrity Wealth Solutions LLC
4725 S. Monaco Street, Suite 335
Denver, CO 80237
Phone: 303.716.5777
clint@integrity-wealth.com
March 4, 2025
This brochure supplement provides information about Clint Thomas that supplements the Integrity Wealth
Solutions Part 2A of form ADV Firm Brochure. You should have received a copy of that brochure, if you did not or
have questions on the brochure, please contact us at 303.716.5777 and a copy will be provided to you.
Additional information about Clint is available at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. The CRD number for Clint Thomas is 4310393.
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Educational Background and Business Experience
Name: Clint Thomas
DOB: 10/27/1975
Education and Training
Bachelor of Business Administration, Lubbock Christian University, 1998
Master of Science in Finance, University of Denver, 2003
Certified Financial Planner (CFP®), 2007
CERTIFIED FINANCIAL PLANNER™ (CFP®)
I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards,
Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™ professional or a CFP®
professional, and I may use these and CFP Board’s other certification marks (the “CFP Board Certification Marks”).
CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold CFP®
certification. You may find more information about CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To
become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program.
The coursework covers the financial planning subject areas CFP Board has determined are necessary
for the competent and professional delivery of financial planning services, as well as a comprehensive
financial plan development capstone course. A candidate may satisfy some of the coursework
requirements through other qualifying credentials.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for
CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
to remain certified and maintain the right to continue to use the CFP Board Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to
CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of
the client, at all times when providing financial advice and financial planning. CFP Board may sanction
a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional's services. A client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education hours every two years to
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maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up
with developments in financial planning. Two of the hours must address the Code and Standards.
Business Background
From August 2016 to present, Clint is a Principal and Co-Owner of Integrity Wealth Solutions.
From 2003 to 2016, Clint was a Financial Consultant with M.J. Smith and Associates.
From 2000 to 2002, Clint was a Financial Representative with Merrill Lynch.
Disciplinary Information
Clint Thomas has no record of any disciplinary event with the SEC, any other federal regulatory agency, state
regulatory agency or foreign financial regulatory authority.
Other Business Activities
Clint Thomas is not engaged in any other investment-related business and does not receive compensation in
connection with any business activity outside of Integrity Wealth Solutions, LLC.
Additional Compensation
Clint Thomas receives no additional compensation for any investment related services outside of the work
performed for Integrity Wealth Solutions.
Supervision
The individual responsible for monitoring Clint Thomas’ advisory activities is Justina Welch, Co-Owner and Chief
Compliance Officer of Integrity Wealth Solutions. Justina Welch is responsible for ensuring that Clint Thomas
adheres to all required regulations regarding the activities of an Investment Adviser Representative, as well as all
policies and procedures outlined in the firm’s Code of Ethics and compliance manual. Justina Welch may be
reached at 303.716.5777
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Part 2B of Form ADV Brochure Supplement for:
Justina Welch
Integrity Wealth Solutions
4725 S. Monaco Street, Suite 335
Denver, CO 80237
Phone: 303.716.5777
justina@integrity-wealth.com
March 4, 2025
This brochure supplement provides information about Justina Welch that supplements the Integrity Wealth
Solutions Part 2A of form ADV Firm Brochure. You should have received a copy of that brochure, if you did not or
have questions on the brochure, please contact us at 303.716.5777 and a copy will be provided to you.
Additional information about Justina is available at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. The CRD number for Justina Welch is 3276656.
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Educational Background and Business Experience
Name: Justina Welch
DOB: 2/3/1976
Education and Training
Bachelor of Science, Business Administration, Finance - University of Colorado, 1998
Master of Business Administration, Corporate Financial Management - University of Colorado, 2010
Certified Financial Planner (CFP®), 2013
CERTIFIED FINANCIAL PLANNER™ (CFP®)
I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards,
Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™ professional or a CFP®
professional, and I may use these and CFP Board’s other certification marks (the “CFP Board Certification Marks”).
CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold CFP®
certification. You may find more information about CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To
become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program.
The coursework covers the financial planning subject areas CFP Board has determined are necessary
for the competent and professional delivery of financial planning services, as well as a comprehensive
financial plan development capstone course. A candidate may satisfy some of the coursework
requirement through other qualifying credentials.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal financial
planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for
CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
to remain certified and maintain the right to continue to use the CFP Board Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to
CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of
the client, at all times when providing financial advice and financial planning. CFP Board may sanction
a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional's services. A client who seeks a similar commitment should obtain a written engagement
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that includes a fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education hours every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up
with developments in financial planning. Two of the hours must address the Code and Standards.
Business Background
From August 2016 to present, Justina is a Principal and Co-Owner of Integrity Wealth Solutions
From 2012 to July 2016, Justina was a Financial Consultant with M.J. Smith & Associates.
From 2011 to 2012, Justina was an Investment Counselor with Fisher Investments.
From 1996 to 2011, Justina was the Vice President of Hofgard & Co, Inc. and Hofgard Insurance, a financial
services consulting firm.
Disciplinary Information
Justina Welch has no record of any disciplinary event with the SEC, any other federal regulatory agency, state
regulatory agency or foreign financial regulatory authority.
Other Business Activities
Justina Welch is not engaged in any other investment-related business and does not receive compensation in
connection with any business activity outside of Integrity Wealth Solutions, LLC.
Additional Compensation
Justina Welch receives no additional compensation for any investment related services outside of the work
performed for Integrity Wealth Solutions.
Supervision
As Chief Compliance Officer, Justina Welch is responsible for supervising all activities of the Firm. Justina Welch
adheres to and is bound by all firm policies and procedures outlined in the firm’s Code of Ethics and Compliance
Manual. Justina Welch may be reached at 303.716.5777.
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