Overview
Assets Under Management: $474 million
Headquarters: LOS GATOS, CA
High-Net-Worth Clients: 106
Average Client Assets: $4 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Clients
Number of High-Net-Worth Clients: 106
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 98.10
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 679
Discretionary Accounts: 679
Regulatory Filings
CRD Number: 288098
Last Filing Date: 2025-03-05 00:00:00
Website: https://librawealth.com
Form ADV Documents
Additional Brochure: LIBRA WEALTH DISCLOSURE BROCHURE AND SUPPLEMENT (2025-08-20)
View Document Text
Libra Wealth LLC
Form ADV Part 2A – Disclosure Brochure
Effective: August 20, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Libra Wealth LLC (“Libra” or the “Advisor”). If you have any questions about the content of this
Disclosure Brochure, please contact the Advisor at (408) 721-1633.
Libra is a registered investment advisor located with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about Libra to assist you in determining whether to retain the Advisor.
Additional information about Libra and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 288098.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
www.librawealth.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Libra. For convenience, the Advisor has combined these documents into a single disclose document.
Libra believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide its you with complete and accurate information at all times. Libra encourages all
current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with
the Advisor.
Material Changes
The following material changes have been made to this disclosure brochure since the last annual amendment
filing on March 11, 2024:
● The Advisor utilizes Donor Advised Funds through Charles Schwab and are no longer offering them
through Fidelity. Item 4 has been updated respectively.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs.
You may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 288098. You may also
request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (408) 721-1633.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 2
www.librawealth.com
Item 3 – Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Business
A. Firm Information
B. Advisory Services Offered
C. Client Account Management
D. Wrap Fee Programs
E. Assets Under Management
Item 5 – Fees and Compensation
A. Fees for Advisory Services
B. Fee Billing
C. Other Fees and Expenses
D. Advance Payment of Fees and Termination
E. Compensation for Sales of Securities
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
B. Risk of Loss
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
B. Personal Trading with Material Interest
C. Personal Trading in Same Securities as Clients
D. Personal Trading at Same Time as Client
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
B. Aggregating and Allocating Trades
Item 13 – Review of Accounts
A. Frequency of Reviews
B. Causes for Reviews
C. Review Reports
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Libra
B. Compensation for Client Referrals
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Form ADV Part 2B – Brochure Supplement
Form ADV Part 2B – Brochure Supplement
Form ADV Part 2B – Brochure Supplement
Form ADV Part 2B – Brochure Supplement
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Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
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www.librawealth.com
Item 4 – Advisory Business
A. Firm Information
Libra Wealth LLC (“Libra” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”) under the laws of
California. Libra was founded in March 2017, and is owned and operated by Mark F. Astrinos (Chief Executive
Officer and Chief Compliance Officer). This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by Libra.
B. Advisory Services Offered
Libra offers investment advisory and financial planning services to individuals, high net worth individuals, trusts,
and estates (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Libra’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Wealth Management (Personal CFO) Services
Libra typically offers Clients its wealth management services, which include a broad range of proactive financial
planning and consulting services in connection with ongoing discretionary management of investment portfolios.
In certain circumstances, Libra may provide investment management or financial planning services as a stand-
alone engagement. Each of these services are described in more detail below.
Investment Management Services – Libra provides customized investment advisory solutions for its Clients either
as a component of wealth management, or pursuant to a stand-alone investment management agreement.
Typically investment management services are provided on a discretionary basis. Libra works closely with each
Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to
create a portfolio strategy.
Libra structures portfolios for Clients according to the Client’s risk tolerance, financial situation, investment
objectives, and immediate need for liquidity. Portfolios are primarily designed around low-cost, diversified mutual
funds and exchange-traded funds (“ETFs”). The Advisor may retain other types of investments from the Client’s
legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified
between the Advisor and the Client.
Libra’s investment philosophy is based upon Modern Portfolio Theory and other academic research including the
three-factor Model (see Item 8 for details). The Advisor implements its strategies primarily through the use of low-
cost, passively managed mutual funds (such as those offered by Vanguard and Dimensional Fund Advisors) as
well as ETFs. These mutual funds and ETFs follow a passive asset class investment philosophy. Diversification,
cost, and tax efficiency are all important factors in determining which funds to use and how they are implemented
for a Client’s account(s). The Advisor may utilize individual fixed-income securities, options, and other types of
securities, as appropriate for a particular client. Clients are assessed a transaction fee by the Custodian. Please
see Item 5.B.
Libra’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. Libra
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and
risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on
the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 4
www.librawealth.com
Libra evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Libra may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Libra may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement. Libra may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s]
in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
At no time will Libra accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Financial Planning Services – Libra also offers financial planning services to Clients either as a component of
wealth management or pursuant to a written financial planning agreement. The areas of financial planning that
Libra may address include: retirement planning, cash flow and debt management, income tax planning,
insurance needs analysis, estate planning, employee benefits, college savings, financial goal setting, and
investment analysis. Financial planning services may cover several areas of a Client’s financial situation,
depending on their goals, objectives, financial situation and specific needs. Financial planning services may
include the preparation of a written financial plan or simply involve rendering advice on a specific area of need.
Any advice rendered to the Client will typically include general recommendations for a course of activity or
specific actions to be taken by the Client. Libra may also refer Clients to an accountant, attorney or other
specialist, as appropriate for their unique situation. Libra does not receive compensation for these referrals.
Engagements will typically start with a discovery meeting with the Client to gain an understanding of
the overall planning goals, financial situation of the Client and other pertinent factors. Additional meetings will
be conducted to explore certain areas of the Client’s financial situation in greater depth and to discuss findings,
recommendations, and potential action steps based on the Advisor’s analysis.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for wealth
management services or for additional financial planning services as it would increase the amount of fees paid to
the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an
ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the
Advisor, the Client is under no obligation to implement the transaction through the Advisor.
Donor Advised Fund Services (Schwab) – The Advisor also provides the Schwab Charitable Donor Advised
Fund (“DAF”) to Clients via Schwab Charitable, a web-based interface and administrative solution for charitable
giving to philanthropic vehicles via the Schwab Charitable Fund (“SCF”), an IRS approved philanthropic vehicle
established for the purpose of managing charitable donations contributed by or on behalf of donor clients. The
DAF allows the Advisor to actively manage assets that have been donated to and are owned by SCF, while
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 5
www.librawealth.com
charging an investment management fee. However, Libra does not charge an investment management fee for
use of the Donor Advised Services. The Advisor’s DAF participation is in conjunction with approval by the SCF
Investment Committee for the Advisor to operate as an advisory manager on the platform. The Schwab
Charitable Fund is an independent company and unaffiliated with the Advisor.
C. Client Account Management
Prior to engaging Libra to provide advisory services, each Client is required to enter into a wealth management
agreement or a financial planning agreement with the Advisor that defines the terms, conditions, authority and
responsibilities of the Advisor and the Client. These services may include:
● Establishing an Investment Strategy – Libra, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
● Asset Allocation – Libra may develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – Libra may develop a portfolio for the Client that is intended to meet the stated
●
goals and objectives of the Client.
Investment Management and Supervision – Libra may provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Libra does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by Libra.
E. Assets Under Management
As of December 31, 2024, Libra manages $473,688,568 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Compensation for wealth management services provided by Libra are paid quarterly, in advance of each
calendar quarter, pursuant to the terms of the wealth management agreement. The Advisor charges a fixed
annual fee ranging up to $50,000 for its wealth management services, which is determined on a case-by-case
basis. Factors considered in setting the fixed-fee generally include the complexity of the Client’s financial
situation, level of investable assets, and estimated time involved. Other factors considered include the number of
household members, number and type of accounts, life stage, business interests, real estate ownership, trust
arrangements, etc. Fixed fees are intended to be competitive with what the Client might expect to pay under an
“assets under management” (AUM) approach (assuming all investable assets were managed).
Due to the detailed nature of the work the Advisor does for Clients, fees for wealth management services will
vary depending on the scope and complexity of the services to be provided. As such, fees may be lower or
higher than those charged by other investment advisors for similar investment management or financial planning
services. Fees may be negotiable at the sole discretion of the Advisor. Material changes in a Client’s situation
may result in a change in the Advisor’s fee. Throughout the relationship, it is anticipated that the Advisor will
periodically review the fixed-fee for each Client and update it to remain commensurate with factors such as the
Client’s financial situation, level of investable assets, and estimated time involved. The Client will be notified of
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 6
www.librawealth.com
any fee changes in writing, and if the result is a fee increase it must be acknowledged by the Client in writing
before taking effect.
The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to
the end of the first quarter. All securities held in accounts managed by Libra will be independently valued by the
Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuations.
In all cases, the Advisor’s fees are exclusive of, and in addition, to any applicable securities transaction and
custody fees, and other related costs and expenses described in Item 5.C. below, which may be incurred by the
Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs and does not
receive compensation by other parties recommended for the implementation of recommendations made by the
Advisor.
Investment Management Services
Compensation for investment management services provided by Libra are paid quarterly, in advance of each
calendar quarter, pursuant to the terms of the investment management agreement. The Advisor charges a fixed
annual fee ranging from $3,000 to $15,000 for its investment management services, which is determined on a
case-by-case basis. Factors considered in setting the fixed-fee generally include the complexity of the Client’s
financial situation, level of investable assets, and estimated time involved. Fees may be negotiable at the sole
discretion of the Advisor.
Financial Planning Services
Libra offers initial financial planning services for a fixed fee ranging up to $10,000 per engagement. If a Client
chooses to engage the Advisor for ad-hoc financial planning services after the completion of the initial plan, the
Advisor will charge an hourly fee at a rate ranging from $60 to $350 per hour. Fixed and hourly financial planning
fees may be negotiable at the sole discretion of the Advisor based on the nature and complexity of the services
to be provided, the time involved, and the overall relationship with the Advisor.
In the case of hourly engagements, if requested, the Advisor will attempt to estimate the total time involved under
a financial planning agreement, but cannot guarantee the number of hours that will be involved, as there are
many unknown variables.
B. Fee Billing
Wealth Management Services
Wealth management fees will typically be deducted from the Client’s account[s] at the Custodian. The Advisor
shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s
account[s] at the beginning of each quarter. Except for partial billing periods, the amount due will be the quarterly
rate (annual rate divided by 4). Clients will be provided with a statement, at least quarterly, from the Custodian
reflecting deduction of the wealth management fees. It is the responsibility of the Client to verify the accuracy of
these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this
responsibility. Clients provide written authorization permitting advisory fees to be deducted by Libra to be paid
directly from their account[s] held by the Custodian as part of the wealth management agreement and separate
account forms provided by the Custodian.
Investment Management Services
Investment management fees will typically be deducted from the Client’s account[s] at the Custodian. The
Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s
account[s] at the beginning of each quarter. Except for partial billing periods, the amount due will be the quarterly
rate (annual rate divided by 4). Clients will be provided with a statement, at least quarterly, from the Custodian
reflecting deduction of the investment management fees. It is the responsibility of the Client to verify the accuracy
of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this
responsibility. Clients provide written authorization permitting advisory fees to be deducted by Libra to be paid
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 7
www.librawealth.com
directly from their account[s] held by the Custodian as part of the investment management agreement and
separate account forms provided by the Custodian.
Financial Planning Services
Initial financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon
deliverable[s]. Ad-hoc financial planning fees are invoiced in arrears and are due upon receipt.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Libra, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution and
custody fees charged by the Custodian, if applicable. The Advisor’s recommended Custodian does not charge
securities transaction fees for ETF and equity trades in Client account, but typically charges for mutual funds and
other types of investments. The fees charged by Libra are separate and distinct from these custody and
execution fees.
In addition, all fees paid to Libra for wealth management services or financial planning services are separate and
distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees
and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay
management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and
account reporting), and a possible distribution fee. A Client may be able to invest in similar products directly,
without the services of Libra, but would not receive the services provided by Libra which are designed, among
other things, to assist the Client in determining which products or services are most appropriate for each Client’s
financial situation and objectives. The Client should review both the fees charged by the fund[s] and the fees
charged by Libra to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for
additional information.
D. Advance Payment of Fees and Termination
Wealth Management Services
Libra is compensated for its wealth management services in advance of the quarter in which advisory services
are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance
written notice to the other party. The Client may also terminate the wealth management agreement within five (5)
business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will
incur charges for bona fide wealth management services rendered to the point of termination and such fees will
be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth
management fees from the effective date of termination to the end of the quarter. The Client’s wealth
management agreement with the Advisor is non-transferable without the Client’s prior consent.
Investment Management Services
Libra is compensated for its investment management services in advance of the quarter in which advisory
services are rendered. Either party may terminate the investment management agreement, at any time, by
providing advance written notice to the other party. The Client may also terminate the investment management
agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-
day period, the Client will incur charges for bona fide investment management services rendered to the point of
termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any
unearned, prepaid investment management fees from the effective date of termination to the end of the quarter.
The Client’s investment management agreement with the Advisor is non-transferable without the Client’s prior
consent.
Financial Planning Services
Libra is compensated for its initial financial planning services upon completion of the engagement deliverable[s].
For ad-hoc financial planning services, Libra is compensated in arrears. Either party may terminate the financial
planning services agreement, at any time, by providing advance written notice to the other party. The effective
termination date shall be the date written notice is received, unless a different future date is specified in the
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 8
www.librawealth.com
written notice or otherwise agreed upon. The Client may also terminate the financial planning agreement within
five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the
Client will incur charges for bona fide financial planning services rendered to the point of termination and such
fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on
the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of
the engagement scope completed by the Advisor. The Client’s financial planning agreement with the Advisor is
non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Libra does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
Libra does not charge performance-based fees for its wealth management services. The fees charged by Libra
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held
by any Client.
Libra does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a
hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
Libra offers investment advisory services to individuals, high net worth individuals, trusts, and estates. Libra
generally does not impose a minimum account size for establishing a relationship.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Libra’s investment philosophy is based primarily on Modern Portfolio Theory (“MPT”) and the Fama-French
Three-Factor Model (“Three-Factor Model”).
MPT focuses on risk-adjusted returns and diversification in constructing portfolios. Libra also incorporates the
findings of Nobel Laureate Eugene F. Fama of the University of Chicago and Kenneth R. French of Dartmouth
University, who together identified risk factors associated with stock market returns (market, size, value) and
other risk factors associated with fixed income returns (term and default). The Fama-French Multi-Factor Model
has demonstrated that the vast majority (more than 90%) of the returns of a portfolio were based on
diversification and further suggesting that stock selection and market timing should not be a focus of the
investment decision making process.
Libra primarily employs fundamental, technical, and other analysis methods in developing investment strategies
for its Clients. Research and analysis from Libra is derived from numerous sources, including financial media
companies, third-party research materials, Internet sources, and review of company activities, including annual
reports, prospectuses, press releases and research prepared by others.
As noted above, Libra generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. Libra will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Libra may also
buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the
fundamentals of the security, sector or asset class.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 9
www.librawealth.com
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Libra will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis
may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals
or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of an ETF is subject to market risk, including the possible loss of principal. The price of the
ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a
trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have
a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market
movements and may dissociate from the index being tracked by the ETF or the price of the underlying
investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF
purchased or sold a short time later.
Mutual Fund Risks
The performance of a mutual fund is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Real Estate Investment Trusts (“REITs”)
Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks
associated with investing in the real estate industry in general. For Example, equity REITs may be affected by
changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by
the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-
liquidation. REITs are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may
decline).
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 10
www.librawealth.com
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Libra or Mr. Astrinos. Libra values the trust
Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any
advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are
available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the
Advisor’s firm name or CRD#288098. Clients may also research the background of Mark F. Astrinos by
searching with his Individual CRD# 6035365.
Item 10 – Other Financial Industry Activities and Affiliations
The sole business of Libra is to provide investment advisory services to its Clients. Neither Libra nor its Advisory
Persons are involved in other business endeavours. Libra does not maintain any affiliations with other firms,
other than contracted service providers to assist with the servicing of its Client’s accounts.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Libra has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with Libra (“Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Libra
and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation
of Libra’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general
principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of
interest. To request a copy of the Code, please contact us at (408) 721-1633.
B. Personal Trading with Material Interest
Libra allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Libra does not allow its Supervised Persons to purchase or sell securities that
are sold on behalf of Clients. Libra does not act as principal in any transactions. In addition, the Advisor does not
act as the general partner of a fund, or advise an investment company. Libra does not have a material interest in
any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Libra allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Libra does not allow its Supervised Persons to purchase or sell securities that
are sold on behalf of Clients. Owning the same securities that are recommended to Clients presents a conflict of
interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted
above, the Advisor has adopted the Code to address insider trading (material non-public information controls);
gifts and entertainment; outside business activities and personal securities reporting. When trading for personal
accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to
act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms
than Client trades, or by trading based on material non-public information. This risk is mitigated by requiring
reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer
(“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of
material, non-public information.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 11
www.librawealth.com
D. Personal Trading at Same Time as Client
While Libra allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. Libra,
nor any of its Supervised Persons, may purchase for themselves or for other Clients of Libra, securities that are
sold on behalf of a Client. At no time will Libra, or any Supervised Person of Libra, transact in any security
to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Libra does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize Libra to direct trades to the Custodian as agreed upon in the wealth management agreement.
Further, Libra does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-
by-trade basis.
Where Libra does not exercise discretion over the selection of the Custodian, it may recommend the Custodian
to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and
will not incur any extra fee or cost associated with using a custodian not recommended by Libra. However, the
Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Libra may
recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged
to the Client, services made available to the Client, its reputation and/or the location of the Custodian’s offices.
Libra will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a
FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. Libra
maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits. Please see
Item 14 – Client Referrals and Other Compensation below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an
advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange
for research and other services. Libra does not participate in soft dollar programs sponsored or
offered by any broker-dealer/custodian. However, the Advisor receives certain economic
benefits from the Custodian. Please see Item 14 below.
2. Brokerage Referrals – Libra does not receive any compensation from any third party in connection with
the recommendation for establishing an account.
3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis”, where Libra will place
trades within the established account[s] at the Custodian designated by the Client. Further, all Client
accounts are traded within their respective account[s]. The Advisor will not engage in any principal
transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with
other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]).
Libra will not be obligated to select competitive bids on securities transactions and does not have an
obligation to seek the lowest available transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favourable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. Libra will execute its transactions through the
Custodian as directed by the Client.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 12
www.librawealth.com
Libra may aggregate orders in a block trade or trades when securities are purchased or sold through the
Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full
at the same price or time, the securities actually purchased or sold by the close of each business day must be
allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be
done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Mr. Astrinos, Principal and
Chief Compliance Officer of Libra. These reviews encompass a number of factors, including, but not limited to,
account performance, risk, and suitability. Formal reviews are generally conducted at least annually or more
frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Libra if changes occur in the
Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews
may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor will,
when deemed appropriate, also provide Clients with periodic written reports regarding their holdings, allocations,
and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Libra
Libra is a fee-only advisory firm, which, in all circumstances, is compensated solely by the Client. Libra does
not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third
party. Libra may refer Clients to various third parties to provide certain financial services necessary to meet the
goals of its Clients. Likewise, Libra may receive referrals of new Clients from a third-party. In neither instance
does Libra give or receive compensation for referrals.
Participation in Institutional Advisor Platform
Libra has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like Libra. As a registered investment advisor
participating on the Schwab Advisor Services platform, Libra receives access to software and related support
without cost because the Advisor renders investment management services to Clients that maintain assets at
Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all, services
provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put
the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a
custodian creates a conflict of interest since these benefits can influence the Advisor's recommendation of Schwab
over a custodian that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 13
www.librawealth.com
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds
and other investments without having to adhere to investment minimums that might be required if the Client were
to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but
may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Libra that
may not benefit the Client, including: educational conferences and events, financial start-up support, consulting
services and discounts for various service providers. Additionally, Schwab has agreed to pay for certain services
rendered by third parties for which the Advisor would otherwise have to pay. This amount is covered once the
value of Client assets in accounts at Schwab reaches a certain size. Clients do not pay more for assets maintained
at Schwab as a result of these arrangements. However, the Advisor does benefit from the arrangement because
the cost of these services would otherwise be borne directly by the Advisor. Access to these services and financial
support creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest.
Libra believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Clients
should consider these conflicts of interest when selecting a custodian.
B. Compensation for Client Referrals
Libra does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client
referrals.
Item 15 – Custody
Libra does not accept or maintain custody of any Client accounts, except for the limited circumstances outlined
below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction
of advisory fees, all Clients for whom Libra exercises discretionary authority must hold their assets with a
"qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and
securities and must instruct Libra to utilize that Custodian for securities transactions on their behalf. Clients are
encouraged to review statements provided by the Custodian and compare to any reports provided by Libra to
ensure accuracy, as the Custodian does not perform this review. For more information about custodians and
brokerage practices, see Item 12 – Brokerage Practices.
Money Movement Authorization - For instances where Clients authorize Libra to move funds between their
accounts, Libra and the Custodian have implemented safeguards to ensure that all money movement activities
are conducted strictly in accordance with the Client’s documented instructions.
Item 16 – Investment Discretion
Libra manages accounts with discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed
to by Libra. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such
authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable
limitations to such authority. All discretionary trades made by Libra will be in accordance with each Client's
investment objectives and goals.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 14
www.librawealth.com
Item 17 – Voting Client Securities
Libra does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting. For assistance, please contact Libra directly.
Item 18 – Financial Information
Neither Libra, nor its management, have any adverse financial situations that would reasonably impair the ability
of Libra to meet all obligations to its Clients. Neither Libra, nor Mr. Astrinos, have been subject to a bankruptcy or
financial compromise. Libra is not required to deliver a balance sheet along with this Disclosure Brochure as the
Advisor does not collect fees of $1,200 or more for services to be performed six months or more in the future.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 15
www.librawealth.com
Form ADV Part 2B – Brochure Supplement
for
Mark F. Astrinos, CPA/PFS, CFP®, RLP®
Chief Executive Officer and Chief Compliance Officer
Effective: August 20, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Mark F. Astrinos, CPA/PFS, CFP®, RLP® (CRD# 6035365) in addition to the information contained in the Libra
Wealth LLC (“Libra” or the “Advisor”, CRD# 288098) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the content of the Libra Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at (408) 721-1633.
Additional information about Mr. Astrinos is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6035365.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 16
www.librawealth.com
Item 2 – Educational Background and Business Experience
Mark F. Astrinos, CPA/PFS, CFP®, RLP® born in 1983, is dedicated to advising Clients of Libra as the Chief
Executive Officer and Chief Compliance Officer. Mr. Astrinos also earned a Bachelor of Science in Accounting
from Santa Clara University in 2005. Additional information regarding Mr. Astrinos’ employment history is
included below.
Employment History:
Chief Executive Officer and Chief Compliance Officer, Libra Wealth LLC
Partner and Financial Planner, Chamberlain Financial Planning & Wealth Management
Wealth Advisor, Vista Wealth Management, LLC
Certified Public Accountant, Burr, Pilger, Mayer
Certified Public Accountant, Deloitte & Touche, LLLP
03/2017 to Present
01/2018 to 12/2020
05/2012 to 02/2017
07/2010 to 01/2012
09/2005 to 07/2010
Information about Professional Designations:
CERTIFIED FINANCIAL PLANNER™, CFP®
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfil the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered
in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s
ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to
real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional
Conduct. The Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial planning services
in the best interests of their clients.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 17
www.librawealth.com
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP®
Board’s enforcement process, which could result in suspension or permanent revocation of their
CFP® certification.
Certified Public Accountant (CPA)
CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the
education, experience and testing requirements for licensure as a CPA generally include minimum college
education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting),
minimum experience levels (most states require at least one year of experience providing services that involve
the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of
which must be achieved under the supervision of or verification by a CPA), and successful passage of the
Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of 40
hours of continuing professional education (CPE) each year (or 80 hours over a two year period or 120 hours
over a three year period). Additionally, all American Institute of Certified Public Accountants (AICPA) members
are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity,
objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict
exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public
interest when providing financial services. The vast majority of state boards of accountancy have adopted the
AICPA’s Code of Professional Conduct within their state accountancy laws or have created their own.
Personal Financial Specialist (PFS)
The PFS credential demonstrates that an individual has met the minimum education, experience and testing
required of a CPA in addition to a minimum level of expertise in personal financial planning. To attain the PFS
credential, a candidate must hold an unrevoked CPA license, fulfil 3,000 hours of personal financial planning
business experience, complete 80 hours of personal financial planning CPE credits, pass a comprehensive
financial planning exam and be an active member of the AICPA. A PFS credential holder is required to adhere to
AICPA’s Code of Professional Conduct, and is encouraged to follow AICPA’s Statement on Responsibilities in
Financial Planning Practice. To maintain their PFS credential, the recipient must complete 60 hours of financial
planning CPE credits every three years. The PFS credential is administered through the AICPA.
Registered Life Planner® (RLP®)
This designation is administered by the Kinder Institute of Life Planning that denotes an advisor with advanced
training in client relationship skills and holistic financial advice. RLPs learn a structured client interview process
that gives them a greater ability to discover a client’s values, purpose, and life goals—even those that may be
closely-guarded. This allows RLPs to develop financial recommendations and strategies that better serve the
client’s long-term interests. RLPs must complete the following three step curriculum for initial certification:
1. Two-day workshop: The Seven Stages of Money Maturity
2. Five-day workshop: Advanced EVOKE™ Training
3. Six-month mentorship that includes further EVOKE™ training through case studies, peer reviews and
support, group conference calls led by experienced RLP mentors, and one-on-one guidance from
experienced RLP mentors.
There are biannual CEU requirements to maintain certification. Planners must also adhere to Kinder Institute’s
code of ethics standards.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Astrinos. Mr. Astrinos has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Astrinos.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 18
www.librawealth.com
As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Astrinos.
However, the Advisor encourages Clients to independently view the background of Mr. Astrinos on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 6035365.
Item 4 – Other Business Activities
Mr. Astrinos is dedicated to the investment advisory activities of Libra’s Clients. Mr. Astrinos does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Astrinos is dedicated to the investment advisory activities of Libra’s Clients. Mr. Astrinos does not receive any
additional compensation.
Item 6 – Supervision
Mr. Astrinos serves as the Chief Executive Officer and Chief Compliance Officer of Libra. Mr. Astrinos can be
reached at (408) 721-1633.
Libra has implemented a Code of Ethics an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of Libra. The CCO or delegate, in its supervision of Supervised
Persons of the Adviser, reviews advice provided to Clients for best interest and suitability. Further, Libra is
subject to regulatory oversight by various agencies. These agencies require registration by Libra and its
Supervised Persons. As a registered entity, Libra is subject to examinations by regulators, which may be
announced or unannounced. Libra is required to periodically update the information provided to these agencies
and to provide various reports regarding the business activities and assets of the Advisor.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 19
www.librawealth.com
Form ADV Part 2B – Brochure Supplement
for
Johanna S. Adleson
Financial Planner
Effective: August 20, 2025
Boise, Idaho
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Johanna S. Adleson (CRD# 5263358) in addition to the information contained in the Libra Wealth LLC (“Libra” or
the “Advisor”, CRD# 288098) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or
if you have any questions about the contents of the Libra Disclosure Brochure or this Brochure Supplement,
please contact us at (408) 721-1633.
Additional information about Mrs. Adleson is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 5263358.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 20
www.librawealth.com
Item 2 – Educational Background and Business Experience
Johanna S. Adleson, born in 1981, is dedicated to advising Clients of Libra as a Financial Planner. Mrs. Adleson
earned a Business Administration & Economics from St. Mary's College in 2003. Additional information regarding
Mrs. Adleson’s employment history is included below.
Employment History:
Financial Planner, Libra Wealth LLC
Financial Advisor, Aspen Capital Management
Financial Advisor, Vista Wealth Mmgt
Portfolio Associate, Morgan Stanley
05/2021 to Present
01/2020 to 05/2021
08/2013 to 09/2018
11/2006 to 08/2013
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mrs. Adleson. Mrs. Adleson has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mrs. Adleson.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mrs. Adleson.
However, we do encourage you to independently view the background of Mrs. Adleson on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual
CRD# 5263358.
Item 4 – Other Business Activities
Mrs. Adleson is dedicated to the investment advisory activities of Libra’s Clients. Mrs. Adleson does not have any
other business activities.
Item 5 – Additional Compensation
Mrs. Adleson is dedicated to the investment advisory activities of Libra’s Clients. Mrs. Adleson does not receive
any additional forms of compensation.
Item 6 – Supervision
Mrs. Adleson serves as a Financial Planner of Libra and is supervised by Mark Astrinos, the Chief Executive
Officer and Chief Compliance Officer. Mr. Astrinos can be reached at (408) 721-1633.
Libra has implemented a Code of Ethics, which is an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Libra. The CCO or delegate, in its supervision of
Supervised Persons of the Adviser, reviews advice provided to Clients for best interest and suitability. Further,
Libra is subject to regulatory oversight by various agencies. These agencies require registration by Libra and its
Supervised Persons. As a registered entity, Libra is subject to examinations by regulators, which may be
announced or unannounced. Libra is required to periodically update the information provided to these agencies
and to provide various reports regarding the business activities and assets of the Advisor.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 21
www.librawealth.com
Form ADV Part 2B – Brochure Supplement
for
Christine M. White, CFP®, CPWA®
Financial Planner
Effective: August 20, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Christine M. White, CFP®, CPWA® (CRD# 6429853) in addition to the information contained in the Libra Wealth
LLC (“Libra” or the “Advisor”, CRD# 288098) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Libra Disclosure Brochure or this
Brochure Supplement, please contact us at (408) 721-1633.
Additional information about Mrs. White is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6429853.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 22
www.librawealth.com
Item 2 – Educational Background and Business Experience
Christine M. White, CFP®, CPWA®, born in 1988, is dedicated to advising Clients of Libra as a Financial Planner.
Mrs. White earned a Bachelor of Science in Health Promotion & Fitness Management from Rowan University in
2010. Mrs. White also earned a Master of Science in Kinesiology from Temple University in 2012. Additional
information regarding Mrs. White’s employment history is included below.
Employment History:
Financial Planner, Libra Wealth LLC
Financial Planner, Gill Capital Partners
Registered Representative, Securities America Inc
Investment Advisor, Townsend & Associates Inc
Agent, Penn Mutual Life Insurance Company
Manager, Vida Fitness
01/2024 to Present
05/2021 to 01/2024
01/2016 to 04/2021
01/2016 to 04/2021
12/2014 to 01/2016
01/2013 to 11/2014
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED
FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real-world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of
their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 23
www.librawealth.com
Certified Private Wealth Advisor™ (“CPWA®”)
The CPWA® designation signifies that an individual has met initial and on-going experience, ethical, education,
and examination requirements for the professional designation, which is centered on private wealth management
topics and strategies for high-net-worth clients. Prerequisites for the CPWA® designation are: A Bachelor’s
degree from an accredited college or university or one of the following designations or licenses: CIMA®, CIMC®,
CFA®, CFP®, ChFC®, or CPA® license; have an acceptable regulatory history as evidenced by FINRA Form U-4
or other regulatory requirements and five years of professional client-centered experience in financial services or
a related industry. CPWA® designees have completed a rigorous educational process that includes self-study
requirements, an in-class education component, and successful completion of a comprehensive examination.
CPWA® designees are required to adhere to IMCA’s Code of Professional Responsibility and Rules and
Guidelines for the use of the Marks. CPWA® designees must report 40 hours of continuing education credits,
including two ethics hours every two years to maintain the certification. The designation is administered through
the Investment Management Consultants Association™ (IMCA®).
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mrs. White. Mrs. White has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mrs. White.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mrs. White.
However, we do encourage you to independently view the background of Mrs. White on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
6429853.
Item 4 – Other Business Activities
Mrs. White is dedicated to the investment advisory activities of Libra’s Clients. Mrs. White does not have any
other business activities.
Item 5 – Additional Compensation
Mrs. White is dedicated to the investment advisory activities of Libra’s Clients. Mrs. White does not receive any
additional forms of compensation.
Item 6 – Supervision
Mrs. White serves as a Financial Planner of Libra and is supervised by Mark Astrinos, the Chief Executive Officer
and Chief Compliance Officer. Mr. Astrinos can be reached at (408) 721-1633.
Libra has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of Libra. Further, Libra is subject to regulatory oversight by various
agencies. These agencies require registration by Libra and its Supervised Persons. As a registered entity, Libra
is subject to examinations by regulators, which may be announced or unannounced. Libra is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 24
www.librawealth.com
Form ADV Part 2B – Brochure Supplement
for
Stephen M. Moorman, CFP®
Financial Planner
Effective: August 20, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Stephen M. Moorman, CFP® (CRD# 7282455) in addition to the information contained in the Libra Wealth LLC
(“Libra” or the “Advisor”, CRD# 288098) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Libra Disclosure Brochure or this Brochure
Supplement, please contact us at (408) 721-1633.
Additional information about Mr. Moorman is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7282455.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 25
www.librawealth.com
Item 2 – Educational Background and Business Experience
Stephen M. Moorman, CFP®, born in 1989, is dedicated to advising Clients of Libra as a Financial Planner. Mr.
Moorman earned his Bachelor's Degree from University of Oklahoma in 2013. Additional information regarding
Mr. Moorman’s employment history is included below.
Employment History:
Financial Planner, Libra Wealth LLC
Wealth Manager, Consolidated Portfolio Review Corp
Registered Representative, Vanderbilt Securities, LLC
Registered Client Services, PlanMember Securities Corporation
Client Services, Hattig Financial
07/2025 to Present
01/2023 to 06/2025
08/2022 to 06/2025
12/2020 to 08/2022
07/2020 to 12/2020
CERTIFIED FINANCIAL PLANNER® Professional
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 the other certification marks (the “CFP Board
Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has
licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or
regulation requires financial planners to hold the CFP® certification. You may find more information about the
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. CFP Board implemented the bachelor’s degree or
higher requirement in 2007 and the financial planning development capstone course requirement in
March 2012. Therefore, a CFP® professional who first became certified before those dates may not have
earned a bachelor’s or higher degree or completed a financial planning development capstone course.
● 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
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 26
www.librawealth.com
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 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.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Moorman. Mr. Moorman has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Moorman.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Moorman.
However, we do encourage you to independently view the background of Mr. Moorman on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 7282455.
Item 4 – Other Business Activities
Mr. Moorman is dedicated to the investment advisory activities of Libra’s Clients. Mr. Moorman does not have
any other business activities.
Item 5 – Additional Compensation
Mr. Moorman is dedicated to the investment advisory activities of Libra’s Clients. Mr. Moorman does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Moorman serves as a Financial Planner of Libra and is supervised by Mark Astrinos, the Chief Compliance
Officer. Mr. Astrinos can be reached at (408) 721-1633.
Libra has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of Libra. Further, Libra is subject to regulatory oversight by various
agencies. These agencies require registration by Libra and its Supervised Persons. As a registered entity, Libra
is subject to examinations by regulators, which may be announced or unannounced. Libra is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 27
www.librawealth.com
Privacy Policy
Effective: August 20, 2025
Our Commitment to You
Libra LLC (“Libra” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients
(also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy
Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. Libra (also referred to as "we", "our"
and "us”) protects the security and confidentiality of the personal information we have and implements controls to
ensure that such information is used for proper business purposes in connection with the management or
servicing of our relationship with you.
Libra does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and reasonable business purposes in connection with the servicing and management of our
relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information [including other institutions]
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Account applications and forms
Investment questionnaires and suitability
documents
Transactional information with us or others
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 28
www.librawealth.com
receive from us.
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including
but not limited to: processing transactions; general account
maintenance; responding to regulators or legal investigations; and credit
reporting.
No
Not Shared
Marketing Purposes
Libra does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where Libra or the
client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
Yes
Yes
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
No
Not Shared
Information About Former Clients
Libra does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
State-specific Regulations
California
In response to a California law, to be conservative, we assume accounts with California
addresses do not want us to disclose personal information about you to non-affiliated third
parties, except as permitted by California law. We also limit the sharing of personal information
about you with our affiliates to ensure compliance with California privacy laws.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter
the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting the Advisor at (408) 721-1633.
Libra Wealth LLC
16185 Los Gatos Blvd, Suite 205
Los Gatos, CA 95032
Phone: (408) 721-1633
Page 29
www.librawealth.com