Overview
- Headquarters
- San Rafael, CA
- Average Client Assets
- $2.9 million
- SEC CRD Number
- 148565
Fee Structure
Primary Fee Schedule (MERITAS WEALTH MANAGEMENT ADV PART 2A MARCH 2026)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $2,000,000 | 1.00% |
| $2,000,001 | $5,000,000 | 0.75% |
| $5,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.40% |
Minimum Annual Fee: $10,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $42,500 | 0.85% |
| $10 million | $67,500 | 0.68% |
| $50 million | $227,500 | 0.46% |
| $100 million | $427,500 | 0.43% |
Clients
- HNW Share of Firm Assets
- 80.54%
- Total Client Accounts
- 949
- Discretionary Accounts
- 949
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
Additional Brochure: MERITAS WEALTH MANAGEMENT ADV PART 2A MARCH 2026 (2026-03-27)
View Document Text
ITEM 1: COVER PAGE
3950 Civic Center Drive, Suite 210
San Rafael, CA 94903
Tel: (415) 300-4560
Fax: (415) 524-4842
245 Foss Creek Circle
Healdsburg, CA 95448
Tel: (707) 508-4600
Fax: (415) 524-4842
www.MeritasWealth.com
Form ADV, Part 2A Firm Brochure
March 19, 2026
This Firm Brochure (Brochure) provides information about the qualifications and business
practices of Meritas Wealth Management, LLC. If you have any questions about the contents of
this Brochure, please contact us at (415) 300-4560, or by email at Kacy@MeritasWealth.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.
is also available on
Any reference to or use of the terms “registered investment adviser” or “registered,” does not
imply that Meritas Wealth Management, LLC, or any person associated with Meritas Wealth
Management, LLC has achieved a certain level of skill or training. Additional information about
Meritas Wealth Management, LLC
the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Meritas Wealth Management,
LLC is 148565.
ITEM 2: MATERIAL CHANGES
The purpose of this page is to inform you of material changes to our brochure. If you are
receiving this brochure for the first time, this section may not be relevant to you.
Meritas Wealth Management, LLC (“Meritas”) reviews and updates our brochure at least
annually to make sure that it remains current. Since our previous annual update in March 2025,
we updated Item 5 to reflect that we have raised our annual minimum fee to $10,000 from
$7,500. We have raised our maximum hourly rate to $500 from $350.
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ITEM 3: TABLE OF CONTENTS
ITEM 1: COVER PAGE .........................................................................................................................1
Form ADV, Part 2A Firm Brochure ................................................................................................1
ITEM 2: MATERIAL CHANGES ..............................................................................................................2
ITEM 3: TABLE OF CONTENTS..............................................................................................................3
ITEM 4: ADVISORY BUSINESS ..............................................................................................................6
Firm Description ....................................................................................................................................... 6
Fiduciary Duty....................................................................................................................................... 6
Types of Advisory Services ....................................................................................................................... 7
Asset Management .............................................................................................................................. 7
Financial Planning ................................................................................................................................. 7
Consulting ............................................................................................................................................. 8
Tailored Relationships .......................................................................................................................... 8
Wrap Fee Programs .................................................................................................................................. 8
Assets Under Management ...................................................................................................................... 8
ITEM 5: FEES AND COMPENSATION ....................................................................................................8
Types of Compensation ............................................................................................................................ 8
Asset Management Fees ...................................................................................................................... 8
Financial Planning Fees ........................................................................................................................ 9
Method of Billing ...................................................................................................................................... 9
Asset Management Fee Billing ............................................................................................................. 9
Financial Plan Billing ........................................................................................................................... 10
Consulting/Retainer ........................................................................................................................... 10
Other Fees and Costs .............................................................................................................................. 10
Refund of Prepaid Advisory Fees ....................................................................................................... 10
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................ 10
ITEM 7: TYPES OF CLIENTS ................................................................................................................ 11
Account Minimum .................................................................................................................................. 11
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................. 11
Methods of Analysis and Investment Strategies .................................................................................... 11
General Investment Strategies ........................................................................................................... 11
Methods of Analysis; Sources of Information ........................................................................................ 12
Types of Investments ............................................................................................................................. 13
Risk of Loss ............................................................................................................................................. 13
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General Risks ...................................................................................................................................... 13
Risk of Loss, Certain Higher-Risk Securities ............................................................................................ 14
Cash Balances in Client Accounts ....................................................................................................... 14
Financial Planning Risk ....................................................................................................................... 14
ITEM 9: DISCIPLINARY INFORMATION ............................................................................................... 15
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................... 15
Financial Industry Activities .................................................................................................................... 15
Unaffiliated Service Provider .................................................................................................................. 15
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ......................................................................................................................................... 15
Code of Ethics ......................................................................................................................................... 15
Participation or Interest in Client Transactions ...................................................................................... 15
Personal Trading ..................................................................................................................................... 16
ITEM 12: BROKERAGE PRACTICES ..................................................................................................... 16
Selecting Brokerage Firms ...................................................................................................................... 16
Directed Brokerage ................................................................................................................................. 17
Best Execution .................................................................................................................................... 17
Research and Other Benefits ............................................................................................................. 17
Order Aggregation .................................................................................................................................. 18
ITEM 13: REVIEW OF ACCOUNTS ...................................................................................................... 18
Periodic Reviews ..................................................................................................................................... 18
Asset Management Clients ................................................................................................................ 18
Review Triggers .................................................................................................................................. 19
Financial Planning Clients ................................................................................................................... 19
Regular Reports ...................................................................................................................................... 19
Asset Management Clients ................................................................................................................ 19
Financial Planning Clients ................................................................................................................... 19
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ................................................................ 19
Other Compensation .............................................................................................................................. 20
ITEM 15: CUSTODY ........................................................................................................................... 20
ITEM 16: INVESTMENT DISCRETION .................................................................................................. 20
Discretionary Authority for Trading ....................................................................................................... 20
Limited Power of Attorney ................................................................................................................. 21
ITEM 17: VOTING CLIENT SECURITIES ................................................................................................ 21
Proxy Voting ....................................................................................................................................... 21
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Class Actions ....................................................................................................................................... 21
ITEM 18: FINANCIAL INFORMATION ................................................................................................. 21
PRIVACY INFORMATION .................................................................................................................... A
Summary: About Meritas Wealth Management, LLC
Meritas provides personalized, confidential financial planning and investment management to
individuals, pension and profit sharing plans, trusts, and small businesses. Advice is provided
through consultation with the client and may include determination of financial objectives and
life goals, identification of financial problems, cash flow management, tax planning, insurance
review, investment management, education funding, retirement planning, and estate planning.
Meritas is strictly a fee-only financial planning and investment management firm. The firm does
not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other
commissioned products. Meritas is not affiliated with entities that sell financial products or
securities. No commissions or finder’s fees in any form are accepted.
Meritas does not act as a custodian of client assets. The client always maintains asset control.
Meritas places trades for clients under a limited power of attorney. Other professionals (e.g.,
lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed
basis. Known actual and potential conflicts of interest will be disclosed to the client.
More information regarding Meritas is found in the pages that follow. Additional information,
including articles and newsletters prepared by Meritas advisors, as well as “Frequently Asked
Questions,” can be found at www.MeritasWealth.com.
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ITEM 4: ADVISORY BUSINESS
Firm Description
Meritas Wealth Management, LLC, (“Meritas”) was founded in December 2008. Gregg E. Clarke,
CFP® and Kenneth C. “Kacy” Gott, CFP® are the principal owners of the firm. Additionally, Tiffani
R. Clarke holds a minority ownership interest.
Fiduciary Duty
Registered investment advisers are considered fiduciaries under federal law. Our fiduciary duty
carries with it an obligation to act in the best interest of our clients pursuant to a relationship of
trust and confidence. It encompasses a duty of care and a duty of loyalty.
Duty of Care
The duty of care includes, among other things:
1. the duty to provide advice that is in the best interest of the client;
2. the duty to seek best execution of a client’s transactions where the adviser has the
responsibility to select broker-dealers to execute client trades; and
3. the duty to provide advice and monitoring over the course of the relationship.
The duty to provide advice suitable to each client based on a reasonable understanding of the
client’s objectives is a critical component of the duty of care. Providing suitable advice includes
making a reasonable inquiry into the client’s financial situation, investment experience, and
financial goals and then updating this information as necessary throughout the course of the
relationship to reflect the client’s changing objectives over time and adjusting the advice we
provide to reflect any changed circumstances.
When Meritas has the responsibility to select broker-dealers to execute client trades in
discretionary accounts, we seek to trade such that the client’s total cost or proceeds in each
transaction are the most favorable under the circumstances. In doing so, we consider the full
range and quality of a broker’s services and so the determinative factor is not necessarily the
lowest possible commission cost but whether the transaction represents the best qualitative
execution. Moreover, we periodically and systematically evaluate the execution we receive on
behalf of our clients.
Our duty of care includes an obligation to provide advice and monitoring at a frequency that is
in the best interest of the client, taking into account the scope of the agreed relationship. This
scope is indicated by the duration and nature of the services as outlined in each client’s
advisory arrangement and extends to all personalized advice provided to clients.
Duty of Loyalty
Meritas adheres to a duty of loyalty where we seek to serve the best interests of our clients and
never subordinate the interests of our clients to our own. Simply put, Meritas cannot place its
own interests ahead of the interests of our clients. In observance of this duty, we must make
full and fair disclosure to clients of all material facts relating to the advisory relationship.
Further, we also seek to eliminate or at least expose through full and fair disclosure all conflicts
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of interest which might incline Meritas, consciously or unconsciously, to render advice that is
not disinterested. We believe that in order for disclosure to be full and fair, it should be
sufficiently specific so that each client is able to understand the material fact or conflict of
interest and make an informed decision whether to provide consent. Consequently, we provide
this ADV 2A brochure to all prospective clients at or before entering into a contract so that they
can use the information within to decide whether or not to enter into an advisory relationship.
Types of Advisory Services
Asset Management
Meritas creates an Investment Policy Statement (“IPS”) for each client. The IPS includes a
‘target’ model portfolio designed to reach the financial goals of the client within the acceptable
risk tolerance and investment time frame established by the client. The creation of the IPS will
be based upon the client’s stated investment objectives, risk tolerance, and financial
circumstances. A model portfolio includes the percentage of each asset class allocation within
the account, and the individual asset selection representing each asset class. To implement the
client’s IPS, the asset allocation program will focus on investing client assets primarily in mutual
funds, including index funds. Investments may also include exchange-traded funds (ETFs), and
some individual equities and/or fixed-income positions, all subject to any client-imposed
investment restrictions.
The percentage allocation in each asset class will be maintained through rebalancing the
account when any asset classes become out of balance with the ‘target’ model portfolio by
approximately 20 percent. This 20 percent rebalance ‘trigger’ is not automatic, however, and is
subject to the discretion of Meritas based on the following circumstances: current market
forces, client cash flow needs, client-directed positions/restrictions, and client tax situation. At
no time will Meritas change the allocation percentage of asset classes in a client model
portfolio without prior approval of the client. Meritas does retain the discretion, however, to
change the individual asset selections when Meritas feels that an alternative asset would be a
better choice for the client. This decision can be based on asset administration fees,
performance, tax efficiency, or change in asset management personnel or style, or other
circumstances.
Financial Planning
Meritas provides advice in the form of a Financial Plan. Generally, clients purchase financial
planning services in tandem with our asset management services. Clients receive a written
financial plan providing the client with detailed analyses and recommendations designed in an
effort to help them achieve their stated financial goals and objectives. In general, we seek to
address all or part of the following areas in the financial plan:
Goals and objectives
Net worth
Cash flow planning
Tax planning review
College funding
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Risk management and insurance planning
Retirement planning
Investment planning
Estate planning
Meritas gathers information through in-depth personal interviews. Information gathered
generally includes a client’s current financial status, future life goals, and attitudes towards risk.
Related documents supplied by the client, including a questionnaire completed by the client,
are carefully reviewed by Meritas, and a written report is prepared. Should a client choose to
implement the recommendations contained in the plan, Meritas suggests the client work
closely with his/her attorney, accountant, insurance agent, mortgage broker, and/or
investment advisor. Implementation of financial plan recommendations is entirely at the
client’s discretion. Clients may choose but are not required to have Meritas assist with financial
plan implementation, including investment management services, for which Meritas receives
additional compensation, as described below in Item 5 – Fees and Compensation.
Consulting
Additionally, Meritas provides advice on non-securities matters. This advice may include
analysis of the insurance needs of the client, analysis of real estate currently owned or to be
acquired by the client, and analysis of feasibility regarding the sale or the purchase of business
concerns and other tangible assets.
Tailored Relationships
In general, advisory services are tailored to meet the needs of individual clients. The goals and
objectives for each client are documented in our client relationship management system.
Investment policy statements are created that reflect the stated goals and objectives. Clients
may impose restrictions on investing in certain securities or types of securities. Agreements
cannot be assigned without client consent.
Wrap Fee Programs
Meritas does not manage accounts as part of a wrap fee or bundled program.
Assets Under Management
Meritas manages client assets in discretionary accounts on a continuous and regular basis. As of
December 31, 2025, the total amount of assets under our management was $618,946,502.
ITEM 5: FEES AND COMPENSATION
Types of Compensation
Asset Management Fees
Meritas bases its asset management fees on a percentage of the client’s assets under
management. The portfolio value of the assets is based on the market value of all securities and
cash in the client’s accounts as of the last trading day of each calendar quarter. Meritas, in its
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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.) Meritas generally
requires a minimum annual fee of $10,000 per client, which we may waive at our discretion.
Assets Under Management
The first $2,000,000
The next $3,000,000
The next $5,000,000
On amount over $10,000,000
Annual Fee %
1.00%
0.75%
0.50%
0.40%
Family Plan Fee Schedule
Accounts for the benefit of clients who are part of the same family may be aggregated for the
purpose of calculating the advisory fee. The determination of ‘same’ family will be determined
at the discretion of Meritas.
All fees described above are negotiable. Some accounts are under different fee schedules
honoring prior agreements.
Financial Planning Fees
Fixed fees for financial planning services are negotiated on an individual basis between Meritas
and the client. Factors used in determining the cost of a financial plan include the complexity
and nature of the client’s circumstances and the overall scope of the plan. We structure
financial plans using hourly and/or fixed fees, which typically total between $4,000 and $7,000
for a comprehensive financial plan. Our hourly rate ranges between $175 - $500/hr. depending
on the personnel we deem necessary to complete the client’s project(s). We quote all
estimated rates and/or fees after the complimentary initial client meeting.
Method of Billing
Asset Management Fee Billing
Advisory fees are payable quarterly in advance at the beginning of each calendar quarter. We
charge one fourth of the annual fee each quarter based on the market value of the client’s
portfolio as of the last business day of the prior calendar quarter. For new clients, the first
payment is a combination of (1) the following quarter’s payment in advance, as described
above, and (2) a pro-rata calculation based on all deposits made during the initial partial
quarter. To accommodate historical fee arrangements of an acquired RIA, Meritas also bills
some accounts in arrears. Such accounts are generally billed using an average daily balance
methodology. Advisory fees are generally deducted from a designated client account to
facilitate billing. The client must consent in advance to direct debiting of their investment
account.
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Financial Plan Billing
Half of the agreed-upon fee is customarily due when the draft financial plan is delivered. The
remainder of the fee is due when the final financial plan is presented to the client.
Consulting/Retainer
Fees for consulting services are generally billed on retainer. We also utilize a retainer for some
accounts that do not meet our minimum annual fee, as described under Asset Management
Fees in this item, above.
Other Fees and Costs
In addition to the management fees set forth above, clients are subject to some or all of the
following costs and expenses:
Assets Transferred into Account(s)
Clients are charged transaction costs associated with the sale of any securities, which are
transferred into their accounts. Investments subject to charges include, but are not limited to,
exchange listed securities, individual bonds, mutual funds (including ETFs), limited partnerships,
and employee stock options.
Account Costs
All fees charged by Meritas are separate and distinct from any fees and expenses charged by
any mutual funds or exchange-traded fund to their shareholders. These fees and expenses are
described in each such fund’s prospectus.
Custodial Fees
All costs and expenses of maintaining custody of client assets with qualified custodians are
charged to the account.
Trading Costs
Client pays transaction fees (ticket charges), which are typically charged by the custodian on a
transaction-by-transaction basis.
Transaction Costs
Client pays all commissions, bid-ask spreads, mark-ups, and similar transaction costs incurred in
connection with the purchase and sale of individual securities.
Refund of Prepaid Advisory Fees
A client agreement can be canceled by either party, for any reason, upon receipt of written
notice and will be effective thirty (30) days after receipt of written notice. Upon termination of
any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid
fees will be due and payable.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
Meritas does not use a performance-based fee structure because of the potential conflict of
interest. Performance-based fees are fees based on a share of capital gains on or capital
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appreciation of the assets of a client. 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.
ITEM 7: TYPES OF CLIENTS
Meritas generally provides investment advice to individuals, pension and profit-sharing plans,
trusts, and small businesses.
Account Minimum
There is no investment account minimum to secure the services of Meritas. However, Meritas
generally requires a minimum annual fee, as described above in Item 5 – Fees and
Compensation.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES
AND RISK OF LOSS
Methods of Analysis and Investment Strategies
General Investment Strategies
Meritas provides each client’s chosen investment strategy and its implementation utilizing a
variety of security types: primarily mutual funds. Clients of Meritas receive the benefit of
Meritas’ developed investment philosophies and strategies, research and due diligence,
account monitoring, and personal financial planning recommendations. Meritas’ Investment
Committee establishes the overall investment strategies employed by the firm, reviews the
brokerage firms we recommend to our clients, and approves the particular investments used by
advisors of our firm. Academic research, investment information, and certain proprietary
analyses are drawn upon by Meritas, in order to provide investment advisory services.
Each of Meritas’ asset management clients receives a written Investment Policy Statement
(IPS), which sets forth a recommended strategic asset allocation. Specific no-load (no
commissions or 12b-1 fees) mutual funds and other investment products and securities
consistent with the IPS are then recommended to the client. Clients’ portfolios are then
periodically monitored, and changes to investment portfolios are implemented at our
discretion, when appropriate. A disciplined approach to rebalancing is employed in order to
maintain asset class exposures within desired risk tolerance ranges, subject to variances
permitted for market fluctuations, tax reduction, tax planning, or other variables.
In designing investment plans for clients, Meritas relies upon the information supplied by the
client and the client’s other professional advisors. Such information generally pertains to the
client’s financial situation, estate planning, tax planning, risk management planning, short-term
and long-term lifetime financial goals and objectives, investment time horizon, and perceived
current tolerance for risk. This information becomes the basis for the strategic asset allocation
plan, which we believe will meet the client’s stated long-term personal financial goals.
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The strategic asset allocation provides for investments in those asset classes, which Meritas
believes (based on historical data and Meritas’ proprietary analysis) could potentially possess
attractive combinations of return, risk, and correlation over the long-term. A substantial
amount of academic research has revealed to Meritas that strategic asset allocation is
determinative of the majority of the expected long-term gross returns of investors’ portfolios.
Meritas’ selection of asset classes is driven by research on global asset classes by academics at
the University of Chicago Booth Graduate School of Business, the Center for Research in
Security Prices, Dartmouth College, and other academic and research institutions.
The investment advice that Meritas provides is based upon long-term investment strategies,
which incorporate the principles of Modern Portfolio Theory. The utilization of several different
asset classes as part of an investor’s portfolio is emphasized. Meritas allocates and diversifies
the client’s assets among various asset classes and then among individual investments,
following the IPS approved by the client.
Meritas’ investment approach is firmly rooted in our belief that markets are fairly efficient
(although not always rational), and that investors’ gross returns are determined principally by
asset allocation decisions. A focus is provided on developing and implementing globally
diversified portfolios, principally through the use of low-expense and tax-efficient passively
managed stock mutual funds that are generally available only to institutional investors and
clients of advisers who are granted access to such funds.
Investment policy and overall portfolio weightings as between equities and fixed income
investments are based upon each client’s needs and desires, perceived risk tolerance, the need
to assume various risks, and investment time horizon. The portfolios of clients then generally
follow models designed by Meritas to fit the overall weightings of equities (stocks, stock mutual
funds, etc.) and fixed income investments (notes, bonds, bond funds, CDs, etc.) in an investor’s
portfolio. For other clients, the investment portfolio’s strategic asset class allocation is
customized to meet the specific circumstances of a client, the presence of investments in 401(k)
or other accounts, as well as a perception of the client’s understanding of the fundamental
forces affecting risk and return in the capital markets.
Methods of Analysis; Sources of Information
Our security analysis is based upon a number of factors including those derived from
commercially available software technology, securities rating services, general economic and
market and financial information, due diligence reviews, and specific investment analyses that
clients may request. The main sources of information include commercially available
investment information and evaluation services, financial newspapers and journals, academic
white papers, and periodicals. Prospectuses, statements of additional information, other issuer-
prepared information, and data aggregation services (Morningstar Advisor, etc.) are also
utilized.
Investment Committee members and advisors also attend various investment and financial
planning conferences.
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Research is also received from consultants, including financial economists affiliated with
Dimensional Funds Advisors (DFA) and other firms. DFA provides historical market analysis,
risk/return analysis, and continuing education services.
Types of Investments
Each client typically receives an investment portfolio, which consists mainly of no-load stock
and bond mutual funds. The passively managed stock mutual funds offered by Dimensional
Funds Advisors (DFA) are generally recommended. DFA mutual funds offer broad
diversification, and most are structured for low turnover, so as to substantially lessen the
transaction costs incurred by mutual funds and ETFs as they trade securities within the fund.
Consequently, we believe the DFA stock mutual funds’ total fees and costs to be generally
lower than the total fees and expenses incurred by most other stock mutual funds (including
many ETFs and index funds) when comparing funds in the same asset classes.
Some investment portfolios also include individual fixed income investments (bonds, CDs, etc.)
and/or bond funds. For clients with a substantial fixed income allocation, Meritas generally
recommends a combination of bond funds and individual fixed income investments, with
recommended actual investments dependent upon Meritas’ views of the risk/return
relationship for various forms of fixed income investments or bond funds. Meritas also relies on
the assistance of a third-party service provider for input regarding individual bond selections.
Some client portfolios also include individual equity securities, but these are generally part of
clients’ investment holdings prior to becoming a client of Meritas.
New clients’ existing investments are evaluated in light of the desired investment policy
objectives. We work with new clients to develop a plan to transition from a client’s existing
portfolio to the desired portfolio. Investment advice may be offered on any investments held by
a client at the start of the advisory relationship. Each client’s portfolio holdings and strategic
asset allocation are then monitored periodically, taking into account the cash flow needs of the
client. Review meetings with clients are held periodically regarding their investment assets
under advisement and other personal financial planning issues, as described in Item 13 –
Review of Accounts, below.
Risk of Loss
General Risks
Investing in securities involves a risk of loss that clients should be prepared to bear. The
investment recommendations seek to limit risk through broad global diversification in equities
(through broadly diversified stock mutual funds) and investment in high quality fixed income
securities or diversified bond funds. However, the investment methodology will still subject the
client to declines in the value of their portfolios, which can at times be dramatic.
Given the long-term nature of the expected equity premium (i.e., the additional expected
return for investing in the overall stock market, relative to less “risky” U.S. Treasury bills), we
believe that Meritas’ investment philosophy is best suited for investors who desire a buy and
rebalance strategy for a substantial portion of their funds. Meritas’ stock mutual fund strategies
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are usually appropriate for clients possessing an investment time horizon of a minimum of ten
years, and preferably even longer. Even then, investing is inherently uncertain as to future
returns. While both macro-economic and microeconomic risks are evaluated, for the purpose of
weighing risks and returns and for the computation of the expected returns of various asset
classes (for use in financial planning decision-making), Meritas does not generally engage in
market-timing activities.
Risk of Loss, Certain Higher-Risk Securities
Certain securities recommended, such as U.S. and International small cap value and mid cap
value stock mutual funds, U.S. small cap and micro-cap mutual funds, Emerging Market stock
funds and similar pooled investment vehicles inside variable annuities, possess higher levels of
volatility (as individual asset classes within a portfolio). Meritas may employ these securities as
part of an overall strategic asset allocation for a client, and when such is undertaken, Meritas
possesses a reasonable belief that the risk-return relationship for these securities will likely be
beneficial for the investor over the long-term.
Cash Balances in Client Accounts
Cash in clients’ investment accounts is typically swept into the bank or money market mutual
fund accounts of the custodial broker (i.e., TD Ameritrade Institutional) daily. Meritas discusses
with each client, during review conferences and at other times, upcoming cash flow needs and
seeks to plan with the client accordingly to meet those needs. While it is not the practice to
encourage clients to maintain a large amount of cash in their accounts, such may be
undertaken at the request of the client, to facilitate billing of Meritas’ periodic fees, or for other
reasons. Upon request of a client, cash balances will be maintained for temporary or short-term
purposes.
Should the client desire a “cash reserve account,” Meritas will assist the client to establish a
separate, non-managed cash reserve account, which is typically not monitored thereafter by
Meritas. Meritas then seeks to review with the client, during periodic conferences, whether any
funds are needed to restore cash reserves. Meritas excludes separate accounts established for
cash reserve purposes in the calculation of Meritas’ assets under advisement and excludes the
value of cash reserve accounts from a client’s fee calculations.
Financial Planning Risk
The financial planning tools Meritas uses to create financial plans for clients rely on various
assumptions, such as estimates of inflation, risk, economic conditions, and rates of return on
security asset classes. All return assumptions use asset class returns, not returns of actual
investments, and do not include fees or expenses that clients would pay if they invested in
specific products.
Financial planning software is only a tool used to help guide Meritas and the client in
developing an appropriate plan, and we cannot guarantee that clients will achieve the results
shown in the plan. Results will vary based on the information provided by the client regarding
the client’s assets, risk tolerance, and personal information. Changes to the program’s
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underlying assumptions or differences in actual personal, economic, or market outcomes
generally result in different results for the client.
Clients should carefully consider the assumptions and limitations of the financial planning
software as disclosed on the financial planning reports and should discuss the results of the
plan with us before making any changes in their investment or financial planning program. If
the financial plan includes recommendations for investing in securities, you should understand
that investing in securities involves risk of loss, and you should be prepared to bear that risk.
ITEM 9: DISCIPLINARY INFORMATION
Registered Investment Advisers are required to disclose all material facts regarding any legal or
disciplinary events of their firm or certain management personnel, which would be material to
your evaluation of Meritas or the integrity of Meritas’ management of your investment
portfolio.
Meritas and its employees have not been involved in any legal or disciplinary events.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATIONS
Financial Industry Activities
Meritas is not involved in any other financial industry activities.
Unaffiliated Service Provider
We utilize the services of a third party firm for operational and trading support services. The
confidentiality of client information is maintained under the terms of the services agreement.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN
CLIENT TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
Meritas has adopted a Code of Ethics, to which all employees are bound to adhere. The Code
sets forth the expectations of Meritas with respect to standards of conduct, fiduciary duties,
protection of nonpublic information, required compliance with federal securities regulations,
required reporting of personal trading, pre-approval of participation in any initial public offering
or private placement, required reporting of violations of the Code to the Chief Compliance
Officer, and required written acknowledgement of receipt of the Code by personnel. A copy of
the Code of Ethics is available to clients and prospective clients upon request.
Participation or Interest in Client Transactions
Meritas has adopted a Code of Ethics and an Employee Trading Policy, which prohibits Meritas
or its associated persons from personally usurping a benefit from a client or benefiting
economically from Meritas’ services to a client. This policy requires associated persons to
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report certain of their securities transactions in order for Meritas to monitor trading activity
preventing associated persons from benefiting economically from client investment
recommendations.
Meritas or an associated person generally buys or sells securities for its/his/her own account
that are also recommended to clients. For example, an associated person of Meritas can be
invested in the same mutual fund that is also recommended to a client. As noted above,
Meritas has adopted policies and procedures preventing Meritas or its associated persons from
usurping a benefit from a client or benefiting as a result of any advisory services provided to a
client. Further, Meritas is obligated to recommend suitable investments to clients and, if
implementing a client’s financial plan, to seek the best execution of client transactions. Clients
should also be aware that personal securities transactions for any associated person of Meritas
may be similar or inconsistent with the investment advice given to its clients.
Personal Trading
The Chief Compliance Officer of Meritas is Kacy Gott. He is responsible for supervising
employee trades. His trades are supervised by Gregg Clarke. The personal trading reviews are
performed as controls to confirm 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 small mutual fund trades or exchange-traded fund trades, we believe that our
personal trades in these types of securities do not affect the broader securities markets.
ITEM 12: BROKERAGE PRACTICES
Selecting Brokerage Firms
Meritas does not have any affiliation with brokerage firms. Specific custodian
recommendations are made to clients based on their need for such services. Meritas
recommends custodians based on our perception of the integrity and financial responsibility of
the firm and the best execution of orders at reasonable commission rates. Meritas uses
research and trading services furnished by brokers with respect to the securities markets, the
economy, particular industries, individual issues, and similar topics having broad applications to
client accounts. Meritas uses research and trading services for the benefit of all Meritas clients,
including clients whose securities transactions are not affected by the broker providing such
services.
Meritas recommends that clients establish brokerage accounts with the registered broker-
dealer and custodian Charles Schwab & Co., Inc. (“Schwab”), Member FINRA/SIPC to maintain
custody of clients’ assets and to effect trades in their accounts. Schwab services provided to
Meritas clients include delivery of quarterly account statements (generally, monthly). Meritas is
independently owned and operated, and is not affiliated with Schwab. Schwab provides
Meritas with computer software services whereby Meritas can place orders and obtain up-to-
date reviews of client accounts. Schwab also provides Meritas with access to its institutional
trading and custody services, which are typically not available to Schwab retail investors.
Schwab’s services include brokerage, custody, research, and access to mutual funds and other
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investments that are otherwise generally available only to institutional investors or would
require a significantly higher minimum initial investment.
Directed Brokerage
Once a client has established an account with a custodian, transactions entered in the account
will also be executed through the client’s custodian. Meritas will not allow clients to direct
Meritas to use a broker-dealer other than their account custodian for the purpose of executing
individual transactions.
Not all investment advisers require their clients to trade through specific brokerage firms. By
requiring clients to use their custodial broker, Meritas believes we can more effectively manage
the client’s portfolio, achieve favorable execution of client transactions, and overall lower the
costs to the portfolio. While Meritas generally utilizes the client’s custodial broker to execute
trades, we can still use other brokers to execute trades for client accounts when we believe
that it would be in the client’s best interest.
Client accounts will always be held in the name of the client and never in Meritas’ name.
Meritas does not receive fees or commissions from any of these arrangements. However, we
receive other benefits, as described in Research and Other Benefits, below.
Best Execution
Meritas periodically reviews the execution of trades at the custodian on a sample basis in an
effort to seek best execution for our clients. The review is documented in Meritas’ books &
records. Trading fees charged by the custodians are also reviewed on a periodic basis. Meritas
does not receive any portion of the trading fees.
Research and Other Benefits
Meritas receives research and trading software from Schwab because client assets are
custodied at Schwab. While this arrangement presents a conflict, we believe that our selection
of Schwab as a custodian for clients is not affected by this nominal benefit.
Schwab also makes available to Meritas other products and services that benefit Meritas but
may not benefit its clients’ accounts. Some of these other products and services assist Meritas
in managing and administering clients’ accounts. These include software and other technology
that provide access to client account data (such as trade confirmations and account
statements); facilitate trade execution (and allocation of aggregated trade orders for multiple
client accounts); provide research, pricing information and other market data; facilitate
payment of Meritas’ fees from its clients’ accounts; and assist with back-office functions,
recordkeeping and client reporting. Many of these services are generally used to service all or a
substantial number of Meritas’ accounts, including accounts not maintained at Schwab.
Schwab makes available to Meritas other services intended to help Meritas manage and further
develop its business enterprise. These services include consulting, publications and conferences
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on practice management, information technology, business succession, regulatory compliance,
and marketing. In addition, Schwab may make available, arrange and/or pay for these types of
services rendered to Meritas by independent third parties. Schwab sometimes discounts or
waives fees it would otherwise charge for some of these services or pay all or a part of the fees
of a third party providing these services to Meritas.
Dimensional Funds Advisors (DFA) also provides direct benefits to us, which include but are not
limited to attendance at educational conferences & study groups, educational materials,
investment analysis software, and funding toward Meritas’ client appreciation events and
speakers for the events.
Our decision to utilize the above providers could potentially be based in part on the benefit to
Meritas of the availability of some of the foregoing products and services and not solely on the
nature, cost or quality of custody and brokerage services provided by DFA or Schwab, which
would create a conflict of interest. However, as a fiduciary, Meritas endeavors to act in its
clients’ best interests, and we believe that use of DFA funds and recommendations that clients
maintain their assets in accounts at Schwab is in the best interests of our clients and primarily
support our selection of DFA/Schwab by the scope, quality, and price of DFA/Schwab’s services
(see Selecting Brokerage Firms, above) and not DFA/Schwab’s services that benefit only us.
Meritas also receives research information and online software tools from DFA, PIMCO,
Vanguard, and Barclay’s iShares Companies. All clients benefit from the research provided from
these firms and we believe that the selection of these fund companies is not affected by this
nominal benefit.
Order Aggregation
Mutual funds are priced once daily. As the daily price is the same for each investor, we have no
opportunity to obtain better pricing through aggregating mutual funds even if we place trades
of the same fund for multiple clients within a single order. Additionally, the broker-
dealer/custodians charge each account an individual transaction fee for mutual funds trades
regardless of whether we aggregate or not. This prevents us from lowering trading costs for
mutual funds through aggregation. However, for ETFs, we aggregate (combine) client orders
when we believe this may be advantageous to our clients. Aggregating trades has the potential
to benefit clients by purchasing or selling in larger blocks in an attempt to take advantage of
better pricing, and when applicable, lower trading costs.
ITEM 13: REVIEW OF ACCOUNTS
Periodic Reviews
Asset Management Clients
Client accounts are reviewed quarterly and compared to the client’s Investment Policy
Statement (IPS). This review compares the current positions of the portfolio with the target
model approved by the client. Clients may request additional reviews at their discretion.
Reviews may also be triggered by political, economic, and market circumstances and/or a
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change in the client’s individual circumstances. Gregg Clarke, Kacy Gott, Principals, and
Jacqueline K. Remar and Jennifer Bahi, Financial Planners, conduct all account reviews.
Review Triggers
Other conditions that may trigger a review are changes in the tax laws, new investment
information, and changes in a client's own situation.
Financial Planning Clients
Financial Planning client accounts will not be reviewed beyond the initial scope of the Financial
Plan. Financial Planning clients may request additional reviews for a fee. Gregg Clarke, Kacy
Gott, Principals, and Jacqueline K. Remar and Jennifer Bahi, Financial Planners, will conduct
such reviews.
Regular Reports
Asset Management Clients
Meritas will provide clients with a quarterly report in conjunction with the quarterly review
process. The report includes statements summarizing account activity, current positions, and
performance analysis. Accompanying the report will be Meritas’ review and market
commentary. The client will also receive statements typically monthly and at least quarterly
from their custodian(s).
Financial Planning Clients
Financial planning clients will not receive reports beyond the initial scope of the Financial Plan.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
Meritas sometimes refers clients to unaffiliated professionals for specific needs, such as
insurance, mortgage brokerage, real estate sales, estate planning, legal, and/or tax/accounting
services. In turn, these professionals sometimes refer clients to Meritas for investment
management/financial planning needs. We do not have any arrangements with individuals or
companies that we refer clients to, and we do not receive any compensation for these referrals.
However, it could be concluded that Meritas is receiving an indirect economic benefit from this
practice, as the relationships are mutually beneficial. For example, there could be an incentive
for us to recommend services of firms who refer clients to Meritas.
Meritas only refers clients to professionals we believe are competent and qualified in their
field, but it is ultimately the client’s responsibility to evaluate the provider, and it is solely the
client’s decision whether to engage a recommended firm. Clients are under no obligation to
purchase any products or services through these professionals, and Meritas has no control over
the services provided by another firm. Clients who choose to engage these professionals will
sign a separate agreement with the other firm. Fees charged by the other firm are separate
from and in addition to fees charged by Meritas.
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If the client desires, Meritas will work with these professionals or the client’s other advisors
(such as an accountant or attorney) to help ensure that the provider understands the client’s
financial plan/investments and to coordinate services for the client. Meritas does not share
information with an unaffiliated professional unless first authorized by the client.
Other Compensation
Meritas does not receive any compensation for any recommendations it makes to other
professionals.
ITEM 15: CUSTODY
Meritas has “limited” custody of some of our clients’ funds or securities when the clients
authorize us to deduct our management fees directly from the client’s account. A qualified
custodian (generally Schwab) holds clients’ accounts. Clients will receive statements directly
from their custodian at least quarterly. The statements will reflect the client’s funds and
securities held at the custodian as well as any transactions that occurred in the account,
including the deduction of Meritas’ fee. Meritas encourages clients to review statements
received from custodians and contact us with any questions. Although we generally
recommend a custodian, the client may choose their own. Some mutual fund shares are held by
the mutual fund’s transfer agent.
Meritas is also deemed to have limited custody of clients’ funds or securities when clients have
standing authorizations with their custodian to move money from a client’s account to a third-
party (“SLOA”) and under that SLOA authorize us to designate the amount or timing of transfers
with the custodian. The SEC has set forth a set of standards intended to protect client assets in
such situations, which we follow.
In some instances, Meritas has “full” custody of certain client assets when we access their
accounts using the client's online credentials. Meritas has put controls in place, in compliance
with federal rules, to protect clients’ assets over which we have custody. An independent
qualified custodian (generally a broker-dealer, bank, trust company, or other financial
institution) holds each client’s assets – Meritas does not act as custodian for any client. The
custodian, at least quarterly, sends account statements directly to the client or client’s
independent representative. In addition, an independent accountant conducts annual surprise
examinations of client accounts over which Meritas has full custody.
ITEM 16: INVESTMENT DISCRETION
Discretionary Authority for Trading
Meritas manages client assets on a discretionary basis. Meritas 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. Discretionary trading authority facilitates placing trades in
client accounts on client’s behalf.
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Limited Power of Attorney
A limited power of attorney is a trading authorization for this purpose. Clients sign a limited
power of attorney so that Meritas can execute the trades that are consistent with client’s
Investment Policy Statement.
ITEM 17: VOTING CLIENT SECURITIES
Proxy Voting
Meritas does not accept or have the authority to vote client securities. Meritas will not be
deemed to have proxy voting authority solely as a result of providing advice or information
about a particular proxy vote to a client. Clients will receive their proxies or other solicitations
directly from their custodian or a transfer agent.
Class Actions
Meritas does not instruct or give advice to clients on whether or not to participate as a member
of class action lawsuits and will not automatically file claims on the client’s behalf. However, if a
client notifies us that they wish to participate in a class action, we will provide the client with
any transaction information pertaining to the client’s account needed for the client to file a
proof of claim in a class action.
ITEM 18: FINANCIAL INFORMATION
Meritas does not have any financial impairment that precludes the firm from meeting
contractual commitments to clients. A balance sheet is not required to be provided because
Meritas does not serve as a custodian for client funds or securities, and does not require
prepayment of fees for more than $1,200 and six months or more in advance. Meritas has
never been the subject of a bankruptcy proceeding.
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PRIVACY INFORMATION
FACTS WHAT DOES MERITAS WEALTH MANAGEMENT, LLC (MERITAS)
DO WITH YOUR PERSONAL INFORMATION?
Why?
Financial companies choose how they share your personal information. Federal law
gives consumers the right to limit some but not all sharing. Federal law also requires
us to tell you how we collect, share, and protect your personal information. Please
read this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on the product or
service you have with us. This can include:
Investment holdings, investment experience and account transactions
Social Security Number, and financial information
Financial goals and financial history
When you are no longer our client, we continue to share your information as
described in this notice.
How?
All financial companies need to share clients’ personal information to run their
everyday business. In the section below, we list the reasons financial companies can
share their clients’ personal information; the reasons Meritas chooses to share; and
whether you can limit this sharing.
Reasons we can share your personal
information
Does Meritas
share?
Can you limit
this sharing?
Yes
NO
For our everyday business purposes -
such as to process your transactions, maintain
your account(s), respond to court orders and
legal investigations
Yes
NO
For our marketing purposes - to offer our
products and services to you
No
We Don’t Share
For joint marketing with other financial
companies
No
No
For our affiliates everyday business
purposes - information about your transactions
and experiences
No
We Don’t Share
For our affiliates everyday business
purposes - information about your
creditworthiness
For nonaffiliates to market to you
No
We Don’t Share
Questions? Call (415) 300-4560 or email Alyx@MeritasWealth.com
Who we are
Meritas Wealth Management, LLC (“Meritas”).
Who is providing this notice?
What we do
How does Meritas protect my
personal information?
To protect your personal information from unauthorized
access and use, we use security measures that comply with
federal law. These measures include computer safeguards
and secured files and buildings.
We collect your personal information, for example, when
you:
How does Meritas collect my
personal information?
When you open an account or transfer assets to us
Seek financial or advice about your investments
Provide account statements or other documents to
us
Complete securities transactions
Make deposits or withdrawals from your account
Federal law gives you the right to limit only:
Why can’t I limit all sharing?
Sharing for affiliates’ everyday business –
information about your creditworthiness
Affiliates from using your information to market to
you
Sharing for nonaffiliates to market to you.
(State laws and individual companies may give you
additional rights to limit sharing.)
California regulations require an affirmative opt-in
before information can be shared with nonaffiliated
third parties; an opt-out for sharing amongst
affiliates; and a self-addressed envelope with pre-
paid postage if there are not at least two free ways
to respond (e.g., toll-free telephone or website)
State laws and individual companies may give you
additional rights to limit sharing.
Definitions
Affiliates
Companies related by common ownership or control. They
can be financial and nonfinancial companies.
Meritas does not have any affiliates
Nonaffiliates
Companies not related by common ownership or control.
They can be financial and nonfinancial companies.
Nonaffiliates we share with can include account
custodians and other financial services
companies providing services on your behalf
Joint Marketing
A formal agreement between nonaffiliated financial
companies that together market financial products or
services to you.
Meritas does not have any such agreements in
place.