View Document Text
Firm Brochure
(Part 2A of Form ADV)
Melia Wealth LLC
5424 S Memorial Drive – Bldg E
Tulsa, OK 74145
PHONE: 918-794-9290
FAX: 866-414-0136
EMAIL: greg@meliagroup.com
WEBSITE: www.meliagroup.com
This brochure provides information about the qualifications and business
practices of Melia Wealth LLC. Being registered as a registered investment
adviser does not imply a certain level of skill or training. If you have any
questions about the contents of this brochure, please contact us at: 918-794-
9290, or by email at: greg@meliagroup.com. The information in this brochure
has not been approved or verified by the United States Securities and
Exchange Commission, or by any state securities authority.
Additional information about Melia Wealth Advisory Group LLC (IARD#
145402) is available on the SEC’s website at www.adviserinfo.sec.gov
November 12, 2025
1
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
This update is in accordance with the annual filing updates for investment advisors. Since
the last update on March 31, 2025, the firm’s Chief Compliance Officer (CCO) has been
updated to reflect Greg Melia as the CCO.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
2
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Table of Contents
Item 2: Material Changes ...................................................................................................................... 2
Annual Update ....................................................................................................................................................... 2
Material Changes since the Last Update ...................................................................................................... 2
Full Brochure Available ...................................................................................................................................... 2
Item 3: Table of Contents ...................................................................................................................... 3
Item 4: Advisory Business .................................................................................................................... 6
Firm Description ................................................................................................................................................... 6
Types of Advisory Services ............................................................................................................................... 6
Client Tailored Services and Client Imposed Restrictions ................................................................... 6
Wrap Fee Programs ............................................................................................................................................. 6
Client Assets under Management ................................................................................................................... 6
Item 5: Fees and Compensation .......................................................................................................... 6
Method of Compensation and Fee Schedule .............................................................................................. 6
Client Payment of Fees ........................................................................................................................................ 7
Additional Client Fees Charged ....................................................................................................................... 7
Prepayment of Client Fees ................................................................................................................................ 7
External Compensation for the Sale of Securities to Clients ............................................................... 7
Item 6: Performance-Based Fees ....................................................................................................... 7
Sharing of Capital Gains ..................................................................................................................................... 7
Item 7: Types of Clients ......................................................................................................................... 8
Description .............................................................................................................................................................. 8
Account Minimums .............................................................................................................................................. 8
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................... 8
Methods of Analysis ............................................................................................................................................. 8
Investment Strategy ............................................................................................................................................ 8
Security Specific Material Risks ...................................................................................................................... 8
3
Item 9: Disciplinary Information ....................................................................................................... 9
Criminal or Civil Actions .................................................................................................................................... 9
Administrative Enforcement Proceedings ................................................................................................. 9
Self-Regulatory Organization Enforcement Proceedings ..................................................................... 9
Item 10: Other Financial Industry Activities and Affiliations ................................................. 10
Broker-Dealer or Representative Registration ...................................................................................... 10
Futures or Commodity Registration .......................................................................................................... 10
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest .... 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ..................................................................................................................................................... 10
Code of Ethics Description ............................................................................................................................. 10
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest ................................................................................................................................................................... 11
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest ................................................................................................................................................................... 11
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest ..................................................................................................... 11
Item 12: Brokerage Practices ............................................................................................................ 12
Factors Used to Select Broker-Dealers for Client Transactions ...................................................... 12
Aggregating Securities Transactions for Client Accounts ................................................................. 12
Item 13: Review of Accounts .............................................................................................................. 12
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved ............................................................................................................................................... 12
Review of Client Accounts on Non-Periodic Basis ................................................................................ 13
Content of Client Provided Reports and Frequency ............................................................................ 13
Item 14: Client Referrals and Other Compensation ................................................................... 13
Economic Benefits Provided to the Advisory Firm from External Sources and
Conflicts of Interest .......................................................................................................................................... 13
Advisory Firm Payments for Client Referrals ........................................................................................ 13
Item 15: Custody .................................................................................................................................... 13
Account Statements .......................................................................................................................................... 13
Automatic Fee Withdrawal ............................................................................................................................ 13
Item 16: Investment Discretion ........................................................................................................ 14
4
Discretionary Authority for Trading .......................................................................................................... 14
Item 17: Voting Client Securities ...................................................................................................... 14
Proxy Votes .......................................................................................................................................................... 14
Item 18: Financial Information ......................................................................................................... 14
Balance Sheet ....................................................................................................................................................... 14
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients ................................................................................................................................. 14
Bankruptcy Petitions during the Past Ten Years .................................................................................. 15
5
Item 4: Advisory Business
Firm Description
Melia Wealth LLC (“MW”) was founded in 2009. Greg Scott Melia is a 100% owner. Greg
Melia is the Chief Compliance Officer.
Types of Advisory Services
MW provides investment supervisory services, also known as asset management services.
ASSET MANAGEMENT
MW offers discretionary direct asset management services to advisory clients. MW will
offer clients ongoing portfolio management services through determining individual
investment goals, time horizons, objectives, and risk tolerance. Investment strategies,
investment selection, assets allocation, portfolio monitoring and the overall investment
program will be based on the above factors. The client will authorize MW discretionary
authority to execute selected investment program transactions as stated within the
Investment Advisory Agreement.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities.
Agreements may not be assigned without client consent.
Wrap Fee Programs
MW does not participate in wrap fee programs.
Client Assets under Management
As of March 31, 2025, MW has approximately $509,547,471 of client assets under
management on a discretionary basis and none on a non-discretionary basis.
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
Client agrees to pay Melia a monthly “management fee” for investment advisory and
management services received under this Agreement. Lesser fees for comparable services
may be available elsewhere. No portion of the management fee will be based upon capital
gains or capital appreciation. The management fee will be .0833% of the “Ending Value”
reported on the CHARLES SCHWAB & CO., INC. Monthly Account Statement. Client agrees
to authorize Custodian to pay Melia management fees directly from Account, (CHARLES
SCHWAB & CO., INC. Institutional Standard Account Application box 9 “Fee Deduction and
Payment Authorization”). Management fee transactions are reported on the monthly
account statements provided by the Custodian.
6
For Example: The account statement ending value for Nov 1-30 is $897,000.97
The November Management Fee is $897,000.97 x.000833= $747.20
Client agrees to direct $747.20 to be deducted from the account in
December and the transaction will be reported on the December 1-31
Account Statement.
Client may incur charges imposed directly at the asset level. Melia does not share in any
portion of these fees charged at the asset level. Any fees charged to Client by the Custodian
(brokerage commissions, custodial fees, services charges, stock transfer fees, transactions
fees, and other similar charges incurred in connection with Account transactions) are
exclusive of, and in addition to, Melia’s compensation. Melia does not share in any portion
of the fees assessed by the Custodian.
Client Payment of Fees
Investment management fees are deducted from accounts monthly, in arrears, meaning
that fees are deducted on or after the first business day of the subsequent month. Fees are
deducted from client account to facilitate payment. Fees deducted are reflected on the
custodial account statement. The client must consent in advance to direct debiting of
management fees from their account.
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may include mutual fund transactions
fees, postage and handling and miscellaneous fees (fee levied to recover costs associated
with fees assessed by self-regulatory organizations). MW, in its sole discretion, may waive
its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria
(e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated
future additional assets, dollar amounts of assets to be managed, related accounts, account
composition, negotiations with clients, etc.).
For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
MW does not bill in advance.
External Compensation for the Sale of Securities to Clients
MW does not receive any external compensation for the sale of securities to clients, nor do
any of the investment advisor representatives of MW.
Item 6: Performance-Based Fees
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
MW does not use a performance-based fee structure because of the 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 to the client.
7
Item 7: Types of Clients
Description
MW generally provides investment advice to individuals, pension and profit sharing
plans, trusts, estates, or charitable organizations, corporations or business entities.
Client relationships vary in scope and length of service.
Account Minimums
MW requires a $100,000 minimum to open an account. MW may at their sole discretion
waive the minimum account size.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include fundamental analysis, technical analysis, and
cyclical analysis. Investing in securities involves risk of loss that clients should be prepared
to bear. Past performance is not a guarantee of future returns.
Fundamental analysis involves evaluating a stock using real data such as company
revenues, earnings, return on equity, and profits margins to determine underlying value
and potential growth. Technical analysis involves evaluating securities based on past prices
and volume. Cyclical analysis involves analyzing the cycles of the market.
The main sources of information include financial newspapers and magazines, research
materials prepared by others, corporate rating services, annual reports, prospectuses, and
filings with the Securities and Exchange Commission.
Investment Strategy
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 or Risk Tolerance that documents their objectives
and their desired investment strategy.
Other strategies may include long-term purchases, short-term purchases and trading.
Security Specific Material Risks
Fundamental analysis may involve interest rate risk, market risk, business risk, and
financial risk. Risks involved in technical analysis are inflation risk, reinvestment risk, and
market risk. Cyclical analysis involves inflation risk, market risk, and currency risk.
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment
risks and should discuss these risks with MW:
•
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
8
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 buy more
than 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 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.
Item 9: Disciplinary Information
Criminal or Civil Actions
The firm and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
The firm and its management have not been involved in administrative enforcement
proceedings.
Self-Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in legal or disciplinary events
related to past or present investment clients.
9
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Neither MW nor any of its employees are registered representatives of a broker-dealer.
Futures or Commodity Registration
Neither MW nor its employees are registered or has an application pending to register as a
futures commission merchant, commodity pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Managing Member Greg Melia is an insurance agent with Melia Advisory Group. 30% or
less of Mr. Melia’s time is spent in this practice. From time to time, he will offer clients
advice or products from those activities.
These practices represent conflicts of interest because it gives Mr. Melia an incentive to
recommend products based on the commission amount received. This conflict is mitigated
by disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of
the client first and clients are not required to purchase any products. Clients have the
option to purchase these products through another insurance agent of their choosing.
Mr. Melia also has non-financial industry affiliated businesses as the owner of Melia
Properties LLC; a real estate holding and leasing company. Mr. Melia collectively spends
less than 10% of his time on this activity.
Mr. Melia is also owner of Melia Holdings LLC which has minority interest in non-financial
industry related private companies with no conflict of interest. Less than 5% of his time is
spent in this business. This business does not offer any services to the public, therefore,
there is no conflict of interest.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
MW does not utilize the services of Third Party Money Managers to manage client accounts.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
The employees of MW have committed to a Code of Ethics (“Code”). The purpose of our
Code is to set forth standards of conduct expected of MW employees and addresses conflicts
that may arise. The Code defines acceptable behavior for employees of MW. The Code
reflects MW and its supervised persons’ responsibility to act in the best interest of their
client.
One area which the Code addresses is when employees buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our clients. We do not
allow any employees to use non-public material information for their personal profit or to
use internal research for their personal benefit in conflict with the benefit to our clients.
10
MW’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other employee, officer or director of MW
may recommend any transaction in a security or its derivative to advisory clients or engage
in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
MW’s Code is based on the guiding principle that the interests of the client are our top
priority. MW’s officers, directors, advisors, and other employees have a fiduciary duty to
our clients and must diligently perform that duty to maintain the complete trust and
confidence of our clients. When a conflict arises, it is our obligation to put the client’s
interests over the interests of either employees or the company.
to clients, or who have access
The Code applies to “access” persons. “Access” persons are employees who have access to
non-public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
making securities recommendations
to such
recommendations that are non-public.
The firm will provide a copy of the Code of Ethics to any client or prospective client upon
request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
MW and its employees do not recommend to clients securities in which we have a material
financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
MW and its employees may buy or sell securities that are also held by clients. In order to
mitigate conflicts of interest such as front running of client trades, employees are required
to disclose all reportable securities transactions as well as provide MW with copies of their
brokerage statements.
The Chief Compliance Officer of MW is Greg Melia. He reviews all employee trades each
quarter. 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 over
employee transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
MW does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of
interest exist. However, employees may buy or sell securities at the same time they buy or
sell securities for clients. In order to mitigate conflicts of interest such as front running,
employees are required to disclose all reportable securities transactions as well as provide
MW with copies of their brokerage statements.
The Chief Compliance Officer of MW is Greg Melia. He reviews all employee trades each
quarter. The personal trading reviews ensure that the personal trading of employees does
11
not affect the markets and that clients of the firm receive preferential treatment over
employee transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
MW may recommend the use of a particular broker-dealer or may utilize a broker-dealer
of the client's choosing. MW will select appropriate brokers based on a number of factors
including but not limited to their relatively low transaction fees and reporting ability. MW
relies on its broker to provide its execution services at the best prices available. Lower fees
for comparable services may be available from other sources. Clients pay for any and all
custodial fees in addition to the advisory fee charged by MW.
• Directed Brokerage
In circumstances where a client directs MW to use a certain broker-dealer, MW still
has a fiduciary duty to its clients. The following may apply with Directed Brokerage:
MW's inability to negotiate commissions, to obtain volume discounts, there may be a
disparity in commission charges among clients, and conflicts of interest arising from
brokerage firm referrals.
• Best Execution
Investment advisors who manage or supervise client portfolios on a discretionary
basis have a fiduciary obligation of best execution. The determination of what may
constitute best execution and price in the execution of a securities transaction by a
broker involves a number of considerations and is subjective. Factors affecting
brokerage selection include the overall direct net economic result to the portfolios,
the efficiency with which the transaction is effected, the ability to effect the
transaction where a large block is involved, the operational facilities of the broker-
dealer, the value of an ongoing relationship with such broker and the financial
strength and stability of the broker. The firm does not receive any portion of the
trading fees.
• Soft Dollar Arrangements
MW does not receive any soft dollar benefits.
Aggregating Securities Transactions for Client Accounts
MW is authorized in its discretion to aggregate purchases and sales and other transactions
made for the account with purchases and sales and transactions in the same securities for
other Clients of MW. All clients participating in the aggregated order shall receive an
average share price with all other transaction costs shared on a pro-rated basis.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed annually by Becky Benanzer and Greg Melia, Chief
Compliance Officer. Account reviews are performed more frequently when market
12
conditions dictate. Financial Plans are considered complete when recommendations are
delivered to the client and a review is done only upon request of client.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of clients accounts are changes in the tax laws,
new investment information, and changes in a client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by the Advisor’s custodian. Client receives confirmations of
each transaction in account from Custodian and an additional statement during any month
in which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and
Conflicts of Interest
MW does not receive any economic benefits from external sources.
Advisory Firm Payments for Client Referrals
MW may from time to time provide a small, non-cash token of appreciation to current clients
who refer new clients to us. These thank-you gifts are nominal in value and are not tied to the
opening of an account or the amount of assets the referred client brings to our firm. These
gestures are given solely as a courtesy and are not intended as compensation for solicitation or
marketing services.
MW does not have any formal referral arrangements with unaffiliated third parties, and we do
not compensate any person or entity for client referrals. In addition, MW does not receive any
economic benefit (such as sales awards or other prizes) from any non-client third party in
connection with providing investment advice to our clients.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly.
MW is deemed to have constructive custody solely because advisory fees are directly
deducted from client’s account by the custodian on behalf of MW.
Automatic Fee Withdrawal
a) The authorization or agreement will be limited to withdrawing contractually agreed
upon investment adviser fees as authorized in the Investment Advisory Agreement.
b) The frequency of fee withdrawal will be monthly.
c) The custodian of the account will be advised in writing of the limitation of MW's access
to the account. This requirement may be satisfied by furnishing to the custodian a copy
13
of this agreement.
d) The custodian will provide the client, not less than quarterly, a statement indicating
all amounts disbursed from the account including, separately, the amount of advisory
fees paid. This may be contained in the custodian's regular periodic report to the client.
Item 16: Investment Discretion
Discretionary Authority for Trading
MW accepts discretionary authority to manage securities accounts on behalf of clients. MW
has 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. However, MW
consults with the client prior to each trade to obtain concurrence if a blanket trading
authorization has not been given.
The client approves the custodian to be used and the commission rates paid to the
custodian. MW does not receive any portion of the transaction fees or commissions paid by
the client to the custodian on certain trades.
Item 17: Voting Client Securities
Proxy Votes
MW votes proxies on behalf of clients for securities held in their managed accounts, unless
otherwise agreed upon in writing. MW has adopted written policies and procedures
designed to ensure that MW votes proxies in the best interest of its clients and to address
any potential conflicts of interest that may arise in the voting process.
MW’s proxy voting policy is guided by the principle of maximizing the long-term economic
value of client investments. MW considers factors such as the long-term performance of the
issuer, the independence and effectiveness of the board of directors, executive
compensation, and the alignment of management interests with those of shareholders.
MW maintains records of all proxy votes cast, including the rationale for any vote that
involves a potential conflict of interest. Clients may obtain a copy of MW’s complete proxy
voting policies and procedures upon request. Clients may also request information about
how MW voted proxies on their behalf by contacting MW at the address or phone number
on the cover page of this brochure.
Clients may choose to retain the right to vote proxies themselves, in which case MW will
not vote those proxies and will not provide advice regarding those votes.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because MW does not serve as a custodian
for client funds or securities and MW does not require prepayment of fees of more than
$1200 per client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
14
Commitments to Clients
MW has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our clients.
Bankruptcy Petitions during the Past Ten Years
Neither MW nor its management has had any bankruptcy petitions in the last ten years.
15