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Item 1 | Cover Page
Meira Wealth
121 Alhambra Plaza
Suite 1000
Coral Gables, FL 33134
Telephone: 305-670-4440
Facsimile: 305-670-4448
www.meirawealth.com
advisors@meirawealth.com
August 30, 2025
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Meira Wealth If you
have any questions about the contents of this brochure, please contact us at 305-670-4440. 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 Meira Wealth is available on the SEC's website at www.adviserinfo.sec.gov.
Meira Wealth is a registered investment adviser. Registration with the United States Securities and
Exchange Commission or any state securities authority does not imply a certain level of skill or training.
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Item 2 | Summary of Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when
information becomes materially inaccurate. If there are any material changes to an adviser's
disclosure brochure, the adviser is required to notify you and provide you with a description of
the material changes.
Since our last annual updating amendment filing, dated March 22, 2024, we have updated our
brochure to remove reference to National Advisors Trust Co. as Linda Lubitz Boone, CFP® is no
longer a shareholder of National Advisors Trust Co. We have also added additional language
describing the alternative investments we may recommend and the risks associated with those
investments. Reference to Parametric has also been removed as none of our client accounts are
currently managed by Parametric.
Additionally, our brochure was updated on August 30, 2025 to reflect a change in Meira Wealth’s
ownership. The firm was previously owned by both Linda Lubitz Boone and Jorge Padilla and is
currently owned solely by Mr. Padilla through Ikigai Wealth PA.
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Item 3 | Table of Contents
Item 1: Cover Page..............................................................................................................................1
Item 2: Summary of Material Changes................................................................................................2
Item 3: Table of Contents.....................................................................................................................3
Item 4: Advisory Business....................................................................................................................4
Item 5: Fees and Compensation..........................................................................................................8
Item 6: Performance Based Fees and Side-By-Side Management...................................................11
Item 7: Types of Clients......................................................................................................................11
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss.............................................11
Item 9: Disciplinary Information...........................................................................................................17
Item 10: Other Financial Activities and Affiliations.............................................................................17
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.......17
Item 12: Brokerage Practices.............................................................................................................18
Item 13: Review of Accounts.............................................................................................................20
Item 14: Client Referrals and Other Compensation...........................................................................21
Item 15: Custody................................................................................................................................21
Item 16: Investment Discretion..........................................................................................................22
Item 17: Voting Client Securities........................................................................................................23
Item 18: Financial Information............................................................................................................23
Item 19: Requirements for State-Registered Advisor........................................................................23
Item 20: Additional Information...........................................................................................................23
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Item 4 | Advisory Services
Description of Services and Fees
The firm was founded in 1997 as Linda S. Lubitz, CFP®, PA (the legal entity name) dba (doing
business as) Meira Wealth. We are a privately held independent Registered Investment Advisor
firm with our office in Coral Gables, Florida. Ikigai Wealth PA, an entity 100% owned by Jorge
Padilla, President and CEO of Meira Wealth, owns 100% of Meira Wealth’s stock.
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services
to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Meira
Wealth and the words "you", "your", “they” and "client" refer to you as either a client or
prospective client of our firm.
financial
objectives,
identification of
financial
problems,
We provide personalized, confidential financial planning and investment management services
to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, and
small businesses. Advice is provided through consultation with the client and may include the
cash flow
determination of
management, tax planning, insurance review, investment management, education funding
planning, retirement planning, charitable planning and estate planning.
Our initial meeting, normally in person but may be by telephone (or virtually), is free of charge
and is considered an exploratory interview to determine the extent to which financial planning
and investment management advice may be beneficial to you and appropriate for us.
Financial Planning Services
Our financial plans are designed to be broad-based in nature. Generally, in keeping with the
scope of the planning engagement, we provide you with a written plan, which reviews your
current situation and recommends actions consistent with your financial and personal goals. A
fee based on the adjusted Net Worth of the client is charged and included in the Client Advisory
Agreement.
The financial plan may include, but is not limited to: a net worth statement; a cash flow
statement; a review of investment accounts, including reviewing asset allocation and providing
repositioning recommendations; strategic tax planning; a review of retirement accounts and
plans including recommendations; a review of insurance policies and recommendations for
changes, if necessary; one or more retirement scenarios; estate planning review and
recommendations; and education planning with funding recommendations. We may also
provide hourly consulting on specific topics as requested.
General investment advice is provided as part of a financial plan. Implementation of the
recommendations is at your discretion.
No legal or accounting, or property/casualty insurance advice is given. The financial planning
written report is a service separate from specific securities recommendations and on-going
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supervision of investments. Unless otherwise agreed to in the Client Advisory Agreement,
there will be no ongoing investment management after the financial plan is completed. You may
use our services for the written report and/or ongoing fee-only investment management.
Our Financial Planning services end at the termination of the Client Advisory Agreement
financial planning contractual period. Should a financial planning-only client wish to get periodic
updates, they will be charged an appropriate fee for the services provided.
For our ongoing Investment Management clients, updates to their financial plan are provided
either as part of their ongoing annual fee or for an additional fee if appropriate.
Our clients acknowledge that:
• Any financial planning is based solely on the accuracy and completeness of the
information provided by them.
• Any projections or other information generated during the financial planning process
• Are hypothetical in nature,
• Do not reflect actual investment results, and
• Do not guarantee any future results.
Our client must promptly notify our firm if their financial situation, goals, objectives, or needs
change. They are under no obligation to act on our financial planning recommendations.
Should they choose to act on any of our recommendations, they are not obligated to
implement the financial plan through any of our other investment advisory services. Moreover,
they may act on our recommendations by placing securities transactions with any brokerage
firm.
Investment Management Services
Most Financial Planning clients choose to have our firm manage their investments in order to
obtain ongoing in-depth financial advice. The Client Advisory Agreement section pertaining to
Investment Management Services will be executed when we are retained for ongoing
investment management. Investment advice is provided and based upon the mutually signed
Investment Policy Statement. We select investments based upon your Investment Policy
Statement.
The scope of work and fee for the Client Advisory Agreement is provided to you in writing prior to
the start of the relationship. The Investment Management Services relationship includes
periodic reporting, usually quarterly, of your investment values, investment policy target
allocation vs. actual, asset class diversification, individual security selection, best efforts at
rebalancing to the target Investment Policy Statement allocation ranges, tax-loss harvesting,
tax reporting and periodic meetings with you to review these and other items.
If you participate in our discretionary Investment Management Services, we require you to grant
our firm discretionary authority to manage your account. Discretionary authorization will allow
us to determine the specific securities, and the amount of securities, to be purchased or sold
for your account without your approval prior to each transaction. Discretionary authority is
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granted by the Client Advisory Agreement you sign with our firm and the appropriate custodial
and/or trading authorization forms. You may limit our discretionary authority (for example, limiting
the types of securities that can be purchased for your account) by providing our firm with your
restrictions and guidelines in writing. We will use our best efforts to honor your requests but
cannot guarantee we will be able to.
Courtesy Accounts
As an accommodation for clients and others, from time to time, Meira Wealth may allow clients
to establish an account (“Courtesy Account”) under a separate Meira Wealth’s Master Account
at Schwab. Before Meira Wealth agrees to such an account, the account holder must sign a
written Courtesy Account Agreement which sets forth the terms and conditions under which the
Courtesy Account must operate.
These conditions include but are not limited to the following:
i. Meira Wealth will not have any fiduciary or other responsibility with respect to assets held
in any such Courtesy Account.
ii. Meira Wealth has no responsibility to monitor, trade, or report on assets held in the
iii.
Courtesy Account; and
Assets held in the Courtesy Account will not be included in Meira Wealth’s Investment
Advisory fee calculations.
Types of Investments
Assets are invested primarily in no-load mutual funds and exchange-traded funds, usually
through custodians or fund companies. Investments may also include equities (stocks),
corporate debt securities, commercial paper, certificates of deposit, municipal securities,
investment company securities (no-load variable annuities, and mutual funds shares), U.S.
government securities, options contracts, futures contracts, business development companies
(BDCs) and interests in partnerships. Initial public offerings (IPOs) are typically not available
through our firm.
We may recommend and invest in non-liquid and non-publicly traded companies such as
private debt or equity firms, mutual funds with limited liquidity (commonly called Interval Funds),
and real estate investments with limited liquidity. Due diligence will be performed by our
advisory team with the assistance of an outside consultant before such recommendations are
made. These investment recommendations may not be suited for every client and will only be
suggested to clients who meet a specific financial and risk profile, and if required by the
investment company, to clients who qualify as accredited investors and/or qualified
purchasers. Under these circumstances, we will act as the advisor and we may use a
custodian like Charles Schwab & Co., Inc., Fidelity Brokerage Services, LLC, or a similar
company to custody the investment and comply with the required financial reporting and
disclosures.
You may request that we refrain from investing in a particular security or certain types of
securities. These restrictions will be documented in our mutually signed Investment Policy
Statement. We will use our best efforts to honor your requests but cannot guarantee we will be
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able to do so.
Certain aspects of our investment operations are performed by Advisor Logistics LLC. The
administration of, and access to, their wealth management platform as well as advisor portal is
utilized by Meira Wealth for a fee, without an impact to clients. Assistance in trading and
rebalancing Meira Wealth designed models is carried out by Advisor Logistics LLC per Meira
Wealth specifications. Additionally, we utilize MTO Financial Services to assist with client fee
calculations and client fee debiting administration. Client personal information is accessible by
Advisor Logistics and MTO Financial Services in order to provide these services. As dictated
by our agreement with each of these firms, “each party agrees to retain in confidence at all
times and to require its employees, consultants, Platform Providers, Technology Providers,
professional representatives and agents to retain in confidence all Confidential Information in
connection with the Agreement.”
General - Advisory Services to Retirement Plans and Plan Participants
We offer various levels of advisory and consulting services to employee benefit plans ("Plan")
and to the Trustee(s) of such plans (“Trustees”). The services are designed to assist plan
sponsors in meeting their management and fiduciary obligations to Participants under the
Employee Retirement Income Securities Act (“ERISA”). Pursuant to adopted regulations of the
U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the
person who has the authority to engage us as an investment adviser to the Plan) with a written
statement of the services we provide to the Plan, the compensation we receive for providing
those services, and our status (which is described below).
The services we provide to your Plan are described above under the Investment Management
Services heading, and in our Client Advisory Agreement. Our compensation for these services
is described below, at Item 5, and in the Client Advisory Agreement. We do not reasonably
expect to receive any other compensation, direct or indirect, for the services we provide to the
Plan or Trustee, unless the plan sponsor directs us to deduct our fee from the plan or directs
the plan record-keeper to issue payment for our fee out of the plan. If we receive any other
compensation for such services, we will (i) offset the compensation against our stated fees, and
(ii) we will promptly disclose the amount of such compensation, the services rendered for such
compensation and the payer of such compensation to you.
Status
In providing services to the Plan and Trustee, our status is that of an investment adviser
registered under the Investment Advisers Act of 1940, and we are not subject to any
disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting
either as a non-discretionary fiduciary of the Plan as defined in Section 3(21) under ERISA, or
as a discretionary fiduciary of the plan as defined in Section 3(38) under ERISA.
Assets Under Management
As of 12/31/2024, we manage $279,561,070 in client assets on a discretionary basis.
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Item 5 | Fees and Compensation
We are strictly a fee-only financial planning and investment management firm. We do not sell
any investment products, such as annuities, insurance, stocks, bonds, mutual funds, limited
partnerships, or other commissioned products that pay our firm any compensation. No
commissions in any form are accepted. No finder’s fees or referral fees are accepted. We
receive compensation only from our clients.
Financial Planning Services
Typically, the fees we charge for Financial Planning are separate from our Investment
Management Services. The Financial Planning fee is based upon a percentage of an
adjusted Net Worth for billing purposes as articulated in the table below. Fifty percent (50%) of
the planning fee is due to commence the relationship with the remaining balance due upon
the completion and delivery of the plan. Our minimum financial planning fee is $2,000.
Net Worth
First $2,000,000
Next $3,000,000
Next $5,000,000
Amounts of $10,000,000
Financial Planning Fee
.20% of Net Worth ($2,000 minimum fee)
.10% of Net Worth
.05% of Net Worth
.03% of Net Worth
Methodology to Calculate Net Worth (for Financial Plan Fee Billing Purposes)
What's Included
•
•
•
•
•
•
•
•
•
•
•
Cash and deposits
Investments (non-retirement accounts)
Retirement accounts
Annuities (or the cash surrender value)
NET value of investment real estate (using publicly available sources such as
Zillow, Trulia, or tax assessed value)
529 plans/UTMA Accounts
HSA (Health Savings Accounts) accounts (value of investment holdings)
Stock compensation - vested value
Private notes / loans
All other liabilities or loans (outside of real estate mortgages)
Life insurance cash surrender value
•
What’s Not Included
•
•
Primary residence
Private or family business •
Pension benefit
Immediate annuity
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Terminating Planning Engagements
A client may terminate the Client Advisory Agreement at any time by providing written notice to
our firm. The client will incur a pro-rata charge for services rendered prior to the termination of
the agreement. If there are pre-paid advisory fees that we have not yet earned, the client will
receive a prorated refund of those fees.
For clients solely electing to receive a one-time financial plan, upon the completion of the
financial plan, the delivery of the Financial Planning Services by Meira Wealth is considered
complete and the Client Advisory Agreement is terminated. Unless extended in writing, the
Agreement for Financial Planning Services will terminate no later than 18 months after signing.
Investment Management Services
Our fee for Investment Management Services is based on a percentage of your assets we
manage according to the following fee schedule:
Assets Under Management
Annual Fee
First $2,000,000
@ 1.0% ($5,000 minimum Annual Fee)
Next $3,000,000
@ 0.7%
Next $5,000,000
@ 0.4%
Amounts above $10,000,000
@ 0.25%
The Investment Management fee can be influenced by several factors including the
composition of the account, the nature of the account, the existence of related accounts, the
source of the account, the complexity of the account and when the account was established,
and as a result, may change. Current client relationships may exist where the fees are higher or
lower than the fee schedule above. Occasionally, various related client accounts may be
grouped together to qualify for reduced advisory fees. This is typically referred to as
"household aggregate" billing.
Generally, our annual Investment Management fee is billed and payable quarterly in advance
based on the gross value of a client account on the last business day of the previous quarter.
We reserve the right to bill an additional fee if more than $50,000 in assets are added to the
accounts during a quarter or adjust the fee if at least $50,000 in assets are withdrawn during a
quarter. When a new account is implemented during a quarter, Meira Wealth will prorate the
fee and bill in arrears on such new account at the time of the initial quarterly billing. Although
the Client Advisory Agreement is an ongoing agreement and constant adjustments are
required, the length of service is at the client’s discretion. A client may terminate the Client
Advisory Agreement at any time by notifying our firm in writing. We may terminate the Client
Advisory Agreement at any time by notifying a client in writing. The Client shall be responsible
for Investment Management Fees up to and including the effective date of termination. Meira
Wealth will refund any unearned, prepaid fees based on the number of days remaining in the
quarter from the day following the effective date of termination to the end of the quarter. For
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every resigned account, we confirm the action to a client via a letter. These fees are either
reimbursed directly into the client account or by a company check made payable to the
account holder.
We will deduct our fee directly from the client account through the qualified custodian holding
your funds and securities. It may be possible to pay our fees directly by check, however, there
may be an administrative fee assessed for this method of payment. We will deduct our advisory
fee only when written authorization permitting the fees to be paid directly from an account has
been given. Further, the qualified custodian will deliver an account statement to the client at
least quarterly. These account statements will show all disbursements from the account. All
statements should be reviewed for accuracy by the client. A calculation of this fee is available
to the client, upon request.
Past Due Accounts
We reserve the right to stop work on any account that is more than 60 days overdue. In
addition, we reserve the right to terminate any financial planning engagement where a client
has willfully concealed, has refused to provide pertinent information about financial situations
when necessary and appropriate, or does not respond to our inquiries in a timely fashion, in
our judgment, to providing proper financial advice. Any unused portion of fees collected in
advance will be refunded within 30 days.
Additional Fees and Expenses
As part of our Investment Management Services, we may invest, or recommend investing in
mutual funds and exchange traded funds. The fees that a client pays to our firm for Investment
Management Services are separate and distinct from the fees and expenses charged by mutual
funds or exchange traded funds (described in each fund's prospectus) to their shareholders.
These fees will generally include a management fee and other fund expenses. A client may
also incur transaction charges and/or brokerage fees when purchasing or selling securities.
These charges and fees are typically imposed by the broker-dealer or custodian through whom
the account transactions are executed. We do not share in any portion of the brokerage
fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the
total cost a client may incur, they should review all the fees charged by mutual funds,
exchange-traded funds, our firm, and others. For information on our brokerage practices,
please refer to the Brokerage Practices section of this brochure.
If it is determined that a client portfolio shall contain corporate debt or other types of over-the-
counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or
dealer on the other side of the transaction that is built into the purchase price of the
security. Meira Wealth does not share in any such compensation.
As a general rule, we do not trade client accounts on margin; however, at the request of the
client for a short-term cash needs situation or to cover checks written on the account when cash
is not available, we will do so. Each client must sign a separate margin agreement with the
custodian before margin is extended to that client account. As a convenience to our clients, we
generally will open a margin account feature on their non-retirement account. Fees for advice
and execution on these securities are based on the total asset value of the account, which
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includes the value of the securities purchased on margin. While a negative amount may show
on a client’s statement for the margined security as the result of a lower net market value, the
amount of the Investment Management fee is based on the absolute market value. This
creates a conflict of interest where we have an incentive to encourage the use of margin to
create a higher market value and therefore receive a higher fee. The use of margin may also
result in interest charges in addition to all other fees and expenses associated with the security
involved.
Item 6 | Performance-based Fees and Side-by-Side Management
We do not accept performance-based fees or participate in side-by-side management.
Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged
performance-based fees. Performance-based fees are fees that are based on a share of capital
gains or capital appreciation of a client's account. Our ongoing advice fees are calculated as
described in the Investment Management section above and are not charged on the basis of a
share of capital gains or capital appreciation of, the funds in your advisory account because of
the potential conflict of interest. Performance-based compensation may create an incentive for
the adviser to recommend an investment that may carry a higher degree of risk.
Item 7 | Types of Clients
Description
We generally provide investment advice to individuals, pension and profit-sharing plans, trusts,
estates, charitable organizations, corporations, or business entities.
Account/Fee Minimums
The minimum account size for Investment Management Services is $500,000 of assets under
management, which equates to an annual fee of $5,000. When an account falls below
$500,000 in value, the minimum annual fee of $5,000 is typically charged. We have the
discretion to waive the account minimum. Accounts of less than $500,000 may be set up
when we, and the client, anticipate the client will add additional funds to the accounts bringing
the total to $500,000within a reasonable time. Other exceptions may apply to employees of
our firm and their relatives, or relatives of existing clients.
The minimum fee for Financial Planning services is $2,000 and is negotiable based on the
complexity associated with the client's situation.
Item 8 | Methods of Analysis, Investment Strategies and Risk of Loss
Our Methods of Analysis
Security analysis methods may include fundamental and/or technical analysis. In addition,
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suitable categories of investments are selected in accordance with the clients’ attitudes about
risk and their need for capital appreciation or income production. Within each category,
individual investments whose characteristics are most consistent with the particular objectives
for which the category was chosen are selected. Risk factors of the different investments are
considered, particularly in light of the clients’ willingness to assume short-term volatility risk.
The main sources of information include financial publications, research materials provided by
other investment institutions, corporate rating services, annual reports, prospectuses, and
company press releases. We also have a contract with an outside consulting firm, Helios, to
provide advice on portfolio construction and specific security selection.
Other sources of information that we may use include Y Charts information, our custodians’
research platforms, Advisor Intelligence, and other internet sources.
Investment Strategies
Our client’s portfolios are managed using a combination of both active and passive
management styles, based on the belief that while passive (index-based) investment
management is well-diversified and effective in some parts of the markets, not all parts of all
markets are well suited to the passive approach. In those areas we deem as less efficient, we
may pick investments that have successful track records in these areas. Our clients need to
understand that the results may range from above to below market results based on the skill of
selection as well as the overall performance of the markets. Modern Portfolio Theory, as
recognized by the 1990 Nobel Prize, will be the philosophical foundation for how the portfolio
will be structured and how subsequent decisions will be made. The underlying concepts of
Modern Portfolio Theory include:
• Investors are risk averse. The only acceptable risk is that which is adequately
compensated by potential portfolio returns.
• Markets are efficient. It is virtually impossible to anticipate the future direction of the
market as a whole or of any individual security. It is, therefore, unlikely that any portfolio
will succeed in consistently "beating the market."
• The design of the portfolio as a whole is more important than the selection of any
particular security within the portfolio. The appropriate allocation of capital among asset
classes (stocks, bonds, cash, etc.) will have far more influence on long-term portfolio
results than the selection of individual securities. Investing for the long term (preferably
longer than ten years) becomes critical to investment success because it allows the long-
term characteristics of the asset classes to surface.
• For a given risk level, an optimal combination of asset classes will maximize returns.
Diversification helps reduce investment volatility. The proportional mix of asset classes
determines the long-term risk and return characteristics of the portfolio as a whole.
Portfolio risk can be decreased by increasing diversification of the portfolio and by
lowering the correlation of market behavior among the asset classes selected.
(Correlation is the statistical term for the extent to which two asset classes move in
tandem or opposition to one another.)
• Investing globally helps to minimize overall portfolio risk due to the imperfect correlation
between economies of the world. Investing globally has also been shown historically to
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enhance portfolio returns, although there is no guarantee that it will do so in the future.
• Stocks/Stock funds offer the potential for higher long-term investment returns than cash
or fixed income/bond/CD investments. Stocks are also more volatile in their
performance. Investors seeking higher rates of return must increase the proportion of
stocks in their portfolio, while at the same time accepting greater variation of results
(including occasional declines in value).
• Picking individual securities and timing the purchase or sale of investments in the
attempt to "beat the market" are highly unlikely to increase long-term investment
returns; they also can significantly increase portfolio operating costs. Such practices are,
therefore, to be avoided.
Given these tenets, the underlying approach to managing client accounts shall be to optimize
the risk-return relationship appropriate to their needs and goals. Client Investment Policies will
be diversified globally employing a variety of asset classes. Mutual funds or managed portfolios
will be employed to implement the portfolio and the chosen asset classes will be periodically
re-balanced to maintain a more consistent risk/reward profile.
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time. Each client executes
an Investment Policy Statement that documents their objectives and their desired investment
strategy.
Other strategies may include long-term purchases, short-term purchases, and, in limited
circumstances, margin transactions.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not
represent or guarantee that our services or methods of analysis can or will predict future results,
successfully identify market tops or bottoms, or insulate clients from losses due to market
corrections or declines. We cannot offer any guarantees or promises that your financial goals
and objectives will be met. Past performance is not a guaranteed indication of future
performance.
Our investment approach routinely keeps the risk of loss in mind. Investors face the following
investment risks:
• Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate.
For example, when interest rates rise, yields on existing bonds become less attractive,
causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
political, economic and social conditions may trigger market events.
• Inflation Risk: When any type of inflation is present, a dollar today will not buy as much
as a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
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exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to
fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding oil
and then refining it, a lengthy process, before they can generate a profit. They carry a
higher risk of profitability than an electric company, which generates its income from a
steady stream of customers who buy electricity no matter what the economic
environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties are
not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations
may result in bankruptcy and/or a declining market value.
Tax Considerations
As a result of revised IRS regulations, custodians and broker-dealers began reporting the cost
basis of equities acquired in client accounts on or after January 1, 2011. Your custodian will
default to the First-In, First-Out (FIFO) accounting method for calculating the cost basis of your
investments. You are responsible for contacting your tax advisor to determine if this accounting
method is the right choice for you. If your tax advisor believes another accounting method is
more advantageous, please provide written notice to our firm immediately and we will alert
your account custodian of your individually selected accounting method. Please note that
decisions about cost-basis accounting methods will need to be made before trades settle, as
the cost-basis method cannot be changed after settlement.
Recommendation of Particular Types of Securities
As disclosed under the Investment Strategies section in this brochure, we invest assets primarily
in no-load mutual funds and exchange-traded funds; however, we may recommend other
types of investments as appropriate for you such as non-liquid and non-publicly traded
companies, interval funds, and limited liquidity real estate investments. Each type of security
has its own unique set of risks associated with it and it would not be possible to list here all of
the specific risks of every type of investment. 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 it.
Traditional Investment Strategies: The majority of clients’ portfolios are invested in mutual
funds and exchange traded funds (ETFs). Mutual funds and ETFs are professionally managed
collective investment systems that pool money from many investors and invest in stocks,
bonds, short-term money market instruments, other mutual funds, other securities or any
combination thereof. The fund will have a manager that trades the fund's investments in
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accordance with the fund's investment objective. While mutual funds and ETFs generally
provide diversification, risks can be significantly increased if the fund is concentrated in a
particular sector of the market, primarily invests in small cap or speculative companies, uses
leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of
security (i.e., equities) rather than balancing the fund with different types of securities.
Exchange traded funds differ from mutual funds since they can be bought and sold throughout
the day like stock and their price can fluctuate throughout the day. The returns on mutual funds
and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds
are "no load" and charge no fee to buy into, or sell out of the fund, other types of mutual funds do
charge such fees which can also reduce returns. Mutual funds can also be "closed end" or
"open end". So-called "open end" mutual funds continue to allow in new investors indefinitely
whereas "closed end" funds have a fixed number of shares to sell which can limit their
availability to new investors.
Alternative Investment Strategies: We believe that alternative investment strategies can add
valuable diversification benefits to portfolios that may not be obtained through investments in
only mutual funds and ETFs. Where appropriate, we present certain clients with opportunities
to invest in alternative strategies. These opportunities are not available to all clients and are
based on several factors, including but not limited to, a client’s sophistication, risk tolerance
and qualifications, net worth, investment objectives, and amount of assets in client account(s).
Alternative investments often are speculative, typically have higher fees than traditional
investments, often include a high degree of risk and are appropriate only for eligible, long-term
investors who are willing to forgo liquidity and put capital at risk for an indefinite period of time.
They may be highly illiquid and can engage in leverage and other speculative practices that
may increase volatility and risk of loss. Alternative investments involve complex tax structures,
tax inefficient investing, and delays in distributing important tax information. Individual funds
have specific risks related to their investment programs that will vary from fund to fund.
Investors should consult their own tax and legal advisors as we do not provide tax or legal
advice. We recommend or otherwise invest in the following alternative investments:
Private Funds: Private Funds are offered only to Accredited Investors as defined by
Rule 501 of Regulation D and/or Qualified Clients as defined by Rule 205-3 under the
Investment Advisers Act of 1940, which impose net worth or assets under management
minimums. These investments include, among others, hedging strategies, real estate
equity, private lending, and private equity. These investments, unlike stocks and bonds
that are regularly traded, can experience illiquidity and pricing inconsistencies. As a
consequence, and in compliance with existing regulations, private funds require a client’s
approval before any investment is made. Any client who subscribes, or proposes to
subscribe, for an investment in a private fund must be able to bear the risks involved and
must meet the fund’s suitability requirements. Some or all alternative investment
programs may not be suitable for certain investors. No assurance can be given that a
private fund’s investment objectives will be achieved. Private fund investments are
speculative and involve a substantial degree of risk, including a total loss of principal.
Private funds are generally highly illiquid, with each private fund investment having
varying degrees of illiquidity depending on the type of fund and its underlying
investments. There is generally no secondary market for a private fund, and none should
be expected to develop. Additionally, there are restrictions on withdrawal/redemption and
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transferring interests in a private fund, so investors may not have access to capital on
demand. The processes and strategies for the private funds we recommend are
disclosed in each private fund’s offering documents. A fund’s concentration in a certain
sector and lack of diversification across other sectors present risks specific to its strategy
and should be carefully considered. Risks specific to each private fund are outlined in
each fund’s offering documents and should be reviewed by the client prior to investment.
Interval Funds: An interval fund is a type of investment company that periodically offers
to repurchase its shares from shareholders. Shareholders are not required to accept
these offers and sell their shares back to the fund. Although classified as closed-end
funds, they are very different from traditional closed-end funds in that:
Their shares typically do not trade on the secondary market. Instead, their
shares are subject to periodic repurchase offers by the fund at a price based
on net asset value.
They are permitted to (and many interval funds do) continuously offer their
shares at a price based on the fund’s net asset value.
An interval fund will make periodic repurchase offers to its shareholders, generally every
three, six or twelve months, as disclosed in the fund’s prospectus and annual report.
Interval funds may have limits (or “gates”) on the total amount of shares that can be
repurchased at a given date, often for as little as 5% of outstanding shares. If more
shares are tendered for redemption than the allowable limit, shareholders will not be able
to sell all of the shares they desire at that particular opening.
Investing in interval funds involve a high degree of risk. In particular, interval funds are
suitable only for investors who can bear the risks associated with the limited liquidity of
the funds and should be viewed as a long-term investment. Limited liquidity is provided to
shareholders only through the interval funds’ quarterly repurchase offers for as little as
5% of the Fund’s shares outstanding at net asset value. There is no guarantee that
shareholders will be able to sell all of the shares they desire in a quarterly repurchase
offer. An interval fund’s investments are also subject to liquidity and other risks, as
described in more detail below. Given the lack of secondary market, the infrequent
nature of the offers to buy back shares, and the liquidity gates (or re-purchase limits),
shareholders should consider the shares of interval funds to be illiquid.
Non-Liquid and Non-Publicly Traded Companies: Non-publicly traded companies are
businesses not listed on a national securities exchange. These companies can include
private equity investments and other direct or indirect positions in privately held entities
(collectively, “private investments”). Because these companies do not trade on a public
market, they often lack a readily available secondary market. As a result, these
investments may involve higher risk and require a long-term investment horizon.
Private investments typically lack an active secondary market, making it difficult to buy or
sell shares on short notice. Investors may need to hold their positions for several years,
often until a liquidity event (e.g., sale, merger, or initial public offering) occurs. Valuing
private, illiquid companies is inherently more subjective than valuing publicly traded
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securities. Valuations often rely on assumptions, third-party appraisals, or internal models
and may not reflect what an investor would actually receive if the position were sold.
Overestimates or underestimates can significantly affect reported performance and
investors’ decisions. Private investments can offer the potential for above-market returns,
although such returns are never guaranteed.
Real Estate Investment Trust (REIT): A Real Estate Investment Trust (REIT) is a
company that owns, manages, or finances income-producing real estate. Because REITs
pool funds to invest in real estate, they can offer diversification relative to other asset
classes. However, they also carry specific risks relating to the real estate market, interest
rates, and economic conditions. REIT performance can be influenced by factors affecting
the real estate market, such as property values, rental demand, vacancy rates, and local
or regional economic conditions. A downturn in any of these areas can negatively impact
REIT earnings and share prices. REIT share prices and yields may be sensitive to
changes in interest rates. Rising interest rates can make REITs less attractive to
investors seeking income and increase borrowing costs for REITs, potentially reducing
profitability and dividend distributions. Many REITs use borrowed funds to acquire
properties or mortgage assets. While leverage can enhance returns in favorable market
conditions, it may also amplify losses if property values or rental income decline.
Additionally, if a REIT is highly leveraged, rising rates or tighter credit conditions could
negatively impact its ability to refinance existing debt. Some REITs, particularly
non-traded, non-listed or private REITs, may have limited liquidity. Shares may not trade
on an exchange, making it difficult for investors to sell their interests at a given time or
price. In contrast, publicly traded REITs usually offer daily liquidity, although market
prices can fluctuate.
Item 9 | Disciplinary Information
Neither our firm nor any of our employees have any reportable disciplinary information.
Item 10 | Other Financial Industry Activities and Affiliations
Neither our firm nor our related persons are affiliated with any of the following types of firms.
broker-dealer, municipal securities dealer, or government securities dealer or
broker
investment company or other pooled investment vehicle (including a mutual fund,
closed-end investment company, unit investment trust, private investment
company or “hedge fund,” and offshore fund)
other investment adviser or financial planner
futures commission merchant, commodity pool operator, or commodity trading
advisor
lawyer or law firm
banking or thrift institution
accountant or accounting firm
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insurance company or agency
real estate broker or dealer
sponsor or syndicator of limited partnerships
pension consultant
Item 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal
Training
Description of Our Code of Ethics
The employees of our firm have committed to a Code of Ethics that is available for review by
clients and prospective clients upon request. The Code is designed to ensure that the high
ethical standards long maintained by our firm continue to be applied. The purpose of the Code is
to preclude activities which may lead to or give the appearance of conflicts of interest, insider
trading and other forms of prohibited or unethical business conduct. The excellent name and
reputation of our firm continues to be a direct reflection of the conduct of each employee.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number or email address on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm has any material financial interest in
client transactions beyond the provision of investment advisory services as disclosed in this
brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we
recommend to you or securities in which you are already invested. A conflict of interest exists
in such cases because we have the ability to trade ahead of you and potentially receive more
favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that
neither our firm nor persons associated with our firm shall have priority over your account in
the purchase or sale of securities.
The Chief Compliance Officer of our firm is Linda Lubitz Boone, CFP®. She reviews all
employee trades each quarter. Her trades are reviewed by another qualified person with the
firm. The personal trading reviews ensure that the personal trading of employees does not affect
the markets, and that clients of the firm receive preferential treatment. Since most employee
trades are in mutual fund trades, the trades do not affect the securities markets.
Item 12 | Brokerage Practices
Selecting Brokerage Firms
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We do not have any affiliation with custodians or product sales firms. Specific custodian
recommendations are made to clients based on their need for such services. We believe
that the recommended custodian provides quality execution services for you at competitive
prices. Price is not the sole factor we consider in evaluating best execution. We also consider
the quality of the brokerage services provided by the recommended custodian, including the
value of the firm's reputation, execution capabilities, commission rates, and responsiveness to
our clients and our firm. In recognition of the value of the services the recommended custodian
provides, you may pay higher commissions and/or trading costs than those that may be
available elsewhere. Typically, accounts are established at Charles Schwab & Co. or Fidelity
Brokerage Services, LLC. Clients’ accounts at other custodians may also be managed.
Best Execution
We review the execution of trades at each custodian periodically. Trading fees charged by the
custodians are also reviewed on an annual basis. Because the majority of our trades are in
mutual funds, only a small proportion are in traded securities. We do not receive any portion of
the trading fees.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore the client’s account to
the position it should have been in had the trading error not occurred. Depending on the
circumstances, corrective actions may include canceling the trade, adjusting an allocation,
and/or reimbursing the account.
Research and Other Benefits
fees deducted directly from client
accounts,
We maintain agreements with Charles Schwab & Co., Inc., Fidelity Brokerage Services, LLC
(FSB), National Financial Services LLC (NFS), American Funds, JPMorgan, Charles Schwab
Trust Company, TIAA Cref, and Nationwide to provide institutional services to our clients.
While there is no direct linkage between the investment advice given and affiliation with these
organizations, economic benefits are received which would not be received if our firm did not
give investment advice to clients and use the services of these organizations. These benefits
include: receipt of duplicate client confirmations and bundled duplicate statements, access to a
trading desk serving institutional service participants exclusively, ability to have investment
management
access to an electronic
communications network for client order entry and account information, receipt of compliance
publications, and access to mutual funds which generally require significantly higher minimum
initial investments or are generally available only to institutional investors. The benefits
received from these organizations may or may not depend upon the amount of transactions
directed to, or amount of assets custodied by the organization. Periodically, employees of the
firm may participate in vendor, mutual fund or custodian sponsored paid-for educational
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conferences. We may also take advantage of certain group discounts on publications and
investment research that is available through the institutional service units. Webcasts are also
made available, which cover investment management, practice management, compliance, and
marketing updates. Additionally, during the year, we may sponsor various client educational
events and seminars, where investment strategies and market conditions, among other topics,
are discussed. Periodically, we may co- sponsor these events with mutual fund companies or
custodians with which we have a business relationship.
The selection of any company as a custodian for clients is not affected by this nominal benefit.
Compensation for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.
Directed Brokerage
In limited circumstances, and at our discretion, some clients may instruct our firm to use one or
more particular brokers for the transactions in their accounts. If you choose to direct our firm to
use a particular broker, you should understand that this might prevent our firm from effectively
negotiating brokerage commissions on your behalf. This practice may also prevent our firm
from obtaining favorable net price and execution. Thus, when directing brokerage business,
you should consider whether the commission expenses, execution, clearance, and
settlement capabilities that you will obtain through your broker are adequately favorable in
comparison to those that we would otherwise obtain for you.
Block Trades
Typically, we do not combine multiple orders for shares of the same securities purchased for
advisory accounts we manage (this practice is commonly referred to as "block trading")
because we invest primarily in mutual funds which do not trade in blocks. Block trade
aggregation is determined when purchases or sells for a large number of shares across multiple
clients’ accounts may have an impact on the security’s daily trading volume.
With respect to certain types of securities, pricing may differ based on market conditions on
the day of trading. Additionally, fees and/or transaction costs differ based on account types
and custodians.
Mutual Fund Share Classes
Mutual funds are sold with different share classes, which carry different cost structures. Each
available share class is described in the mutual fund's prospectus. When we purchase, or
recommend the purchase of, mutual funds for a client, we select the share class that is
deemed to be in the client’s best interest, taking into consideration cost, tax implications, and
other factors. When the fund is available for purchase at net asset value, we will purchase, or
recommend the purchase of, the fund at net asset value. We also review the mutual funds
held in accounts that come under our management to determine whether a more beneficial
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share class is available, considering cost, tax implications, and the impact of contingent
deferred sales charges.
Item 13 | Review of Accounts
Account Reviews
Account reviews are performed on a periodic basis in consultation with the client, at least
annually, by the advisor who works with each client. Account reviews may be performed more
frequently when market conditions dictate (e.g., market moving events). Other conditions that
may trigger a review are changes in the tax laws, new investment information, and changes in
a client's own situation.
Regular Reports
Account reviewers are all Certified Financial Planning Practitioners. They are instructed to
consider the client's current security positions and the likelihood that the performance of each
security will contribute to the investment objectives of the client.
Clients receive periodic communications on at least an annual basis. Client Advisory Agreement -
Investment Management clients receive written quarterly updates. The written updates may
include a portfolio statement, market commentary, performance for specified periods, client
notification, market returns and an asset allocation chart.
Clients also receive monthly statements directly from the custodian. These statements can be
received in either paper format or electronic format, as elected by the client.
Item 14 | Client Referrals and Other Compensation
Incoming Referrals
We have been fortunate to receive many client referrals over the years. The referrals come from
current clients, estate planning attorneys, accountants, employees, personal friends of
employees and other similar sources. Our firm does not compensate outside referring parties
for these referrals. We do compensate our employees for referrals.
Referrals Out
We do not accept referral fees or any form of remuneration from other professionals when a
prospect or client is referred from our firm.
Other Compensation
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Please refer to the Brokerage Practices section above for disclosures on research and other
benefits we may receive resulting from our relationship with the custodians we recommend.
Item 15 | Custody
Our clients’ fees are debited directly from our independent custodians’ account(s) for the
payment of our advisory fees. This ability to deduct our advisory fees from our clients' accounts
causes our firm to exercise limited custody over their funds or securities. We do not have
physical custody of any of our clients' funds and/or securities. Our clients will receive account
statements from the independent, qualified custodian(s) holding their funds and securities at
least quarterly. The account statements from our clients' custodian(s) will indicate the amount of
our advisory fees deducted from their account(s) each billing period. Account statements
should be reviewed carefully for accuracy. We will also provide a notice to our clients reflecting
the amount of the advisory fee deducted from their account.
Our clients should compare our notices with the statements from their account custodian(s) to
reconcile the information reflected on each statement. Slight discrepancies may be a result of
timing on recording of dividends or interest. If you have any questions regarding account
statements, or if a statement was not received from the custodian, please contact us directly at
the telephone number on the cover page of this brochure.
Standing Letters of Authorization, Wire Transfer and/or Check-Writing Authority
Our firm, or persons associated with our firm, may disburse funds from client accounts to one
or more third parties designated, in writing, by the client without obtaining written client
consent for each separate, individual transaction, as long as the client has provided us with
written authorization to do so via the Custodian’s SLOA Form. Such written authorization is
known as a Standing Letter of Authorization (SLOA). An adviser with authority to conduct such
third-party money movements has access to the client's assets and therefore has custody of
the client’s assets in any related accounts. However, our firm is not subjected to the
requirement for an annual surprise audit, as we otherwise would be by reason of having
custody, providing we meet the following safe harbor provisions:
1. We provide a written, signed instruction to the qualified custodian that includes the third
party’s name and address or account number at a custodian;
2. We are authorized, in writing, to direct transfers to the third party either on a specified
schedule or from time to time;
3. Our qualified custodians verify our authorization (e.g., signature review) and provide a
transfer of funds notice to us promptly after each transfer;
4. We can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at
the same address as us; and
7. Our qualified custodian sends us, in writing, an initial notice confirming the instruction and
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We hereby confirm that we meet the above criteria.
Item 16 | Investment Discretion
Discretionary Authority for Trading
We accept discretionary authority to manage securities accounts on behalf of clients. We have
the authority to determine, without obtaining specific client consent, the securities to be bought
or sold, and the amount of the securities to be bought or sold in accordance with the client’s
Investment Policy Statement.
The client approves the custodian to be used and will pay transaction and other fees charged
directly by the custodian. We do not receive any portion of the transaction fees or commissions
paid by the client to the custodian on certain trades.
Discretionary trading authority facilitates placing trades in clients’ accounts on their behalf so
that we may promptly implement the investment policy that they have approved in writing.
Limited Power of Attorney
A limited power of attorney is a trading authorization for this purpose. The client signs a limited
power of attorney so that we may execute the trades that the client has approved.
Item 17 | Voting Client Securities
We will not vote proxies on behalf of client advisory accounts. Clients are expected to vote their
own proxies. In most cases, a client will receive proxy materials directly from the account
custodian.
Item 18 | Financial Information
Our firm does not have any financial condition or impairment that would prevent us from
meeting our contractual commitments to you. We do not take physical custody of client funds
or securities, or serve as trustee or signatory for client accounts, and we do not require the
prepayment of more than $1,200 in fees six or more months in advance of services provided.
We have not filed a bankruptcy petition at any time in the past ten years. Therefore, we are not
required to include a financial statement with this brochure.
Item 19 | Requirements for State-Registered Advisers
This item is not applicable. We are registered with the U.S. Securities and Exchange
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Commission.
Item 20 | Additional Information
Business Continuity Plan
General
We have a Business Continuity Plan (the Plan) in place that provides detailed steps to mitigate
and recover from the loss of office space, communications, services or key people.
Disasters
The Business Continuity Plan covers natural disasters such as snowstorms, hurricanes,
tornados, and flooding. The Plan covers man-made disasters such as loss of electrical power,
loss of water pressure, fire, bomb threat, nuclear emergency, chemical event, biological event,
fibernet communications line outage, Internet outage, railway accident and aircraft accident.
Electronic files are backed up daily and archived offsite.
Alternate Offices
Alternate offices are identified to support ongoing operations in the event the main office is
unavailable. It is our intention to contact all clients within five days of a disaster that dictates
moving or working out of an alternative office location.
Information Security Program
Information Security
We make best efforts to ensure that our client personal and confidential information will be
kept confidential. A confidentiality agreement is included in our practice to work toward this
end. Our Policies and Procedures Manual includes an Information Security Program outlining
the precautions our firm takes to protect this information.
eMoney Advisor Platform
including Excluded Assets.
Meira Wealth does not
Meira Wealth may provide its clients with access to an online platform hosted by “eMoney
Advisor” (“eMoney”). The eMoney platform allows a client to view their complete asset
allocation,
provide investment
management monitoring, or implementation services for the Excluded Assets. Therefore, we
shall not be responsible for the investment performance of the Excluded Assets. The client
may choose to engage us to manage some or all of the Excluded Assets pursuant to the terms
and conditions of a Client Advisory Agreement between Meira Wealth and the client. The
eMoney platform also provides access to other types of information, including financial
planning concepts, which should not, in any manner whatsoever, be construed as services,
advice, or recommendations provided by Meira Wealth. We shall not be held responsible for
any adverse results a client may experience if the client engages in financial planning or other
functions available on the eMoney platform without our assistance or oversight.
Class Action Lawsuits
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We do not determine if securities held by you are the subject of a class action lawsuit or whether
you are eligible to participate in class action settlements or litigation nor do we initiate or
participate in litigation to recover damages on your behalf for injuries as a result of actions,
misconduct, or negligence by issuers of securities held by you. We do not provide advice as to
your participation in any legal action.
Questions
Meira Wealth’s Chief Compliance Officer, Linda Lubitz Boone, CFP®, remains available to
address any question that a client or prospective client may have regarding the above
disclosures, conflicts of interest and other arrangements. She may be reached at 305.670.4440
and linda@meirawealth.com.
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