View Document Text
Form ADV Part 2A
Firm Brochure
February 13, 2026
This Brochure provides
information about the
qualifications and business
practices of J.P. Davis, Inc. dba
NRG Wealth Management. If you
have any questions about the
contents of this Brochure, please
contact us at 520-818-7822, or
via email at jack@nrgwm.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.
J.P. Davis, Inc. dba NRG Wealth
Management is a SEC registered
investment advisory firm.
Registration of an investment
advisory firm does not imply a
particular level of skill or
training.
J.P. Davis, Inc. dba NRG Wealth
Management
IARD#289548
Additional information about J.P.
Davis, Inc. dba NRG Wealth
Management is also available on
the SEC’s website at
www.adviserinfo.sec.gov.
12115 North Oracle Road, Suite 151
Oro Valley, Arizona 85737
(520) 818-7822
Jack@nrgwm.com
www.nrgwm.com
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 our Firm Brochure. This Item discusses only specific material
changes that are made to this Brochure and provides our clients with a summary of such changes.
Material Changes since the Last Update
Since the last updating amendment filed on January 31, 2025, no material changes have occurred.
Full Brochure and Additional Information
Full Brochure and additional information about J.P. Davis, Inc. dba NRG Wealth Management are
available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides
information about any persons affiliated with us who are registered or are required to be registered
as investment adviser representatives (“IAR”).
2
NRG Wealth Management
ITEM 3
Table of Contents
1
2
ITEM 1
Cover Page ...........................................................................................................................................................
3
ITEM 2
Material Changes ...............................................................................................................................................
4
ITEM 3
Table of Contents ...............................................................................................................................................
6
ITEM 4
Advisory Business .............................................................................................................................................
9
ITEM 5
Fees and Compensation .................................................................................................................................
9
ITEM 6
Performance-Based Fees and Side-By-Side Management .................................................................
9
ITEM 7
Types of Clients ..................................................................................................................................................
10
ITEM 8
Methods of Analysis, Investment Strategies, and Risk of Loss .........................................................
11
ITEM 9
Disciplinary Information .............................................................................................................................
11
ITEM 10 Other Financial Activities and Affiliations ............................................................................................
12
ITEM 11 Code of Ethics, Participation in Client Transactions and Personal Trading ............................
13
ITEM 12 Brokerage Practices .......................................................................................................................................
1
ITEM 13 Review of Accounts ........................................................................................................................................
ITEM 14 Client Referrals and Other Compensation ............................................................................................
14
4
14
ITEM 15 Custody ...............................................................................................................................................................
14
ITEM 16
Investment Discretion ..................................................................................................................................
ITEM 17 Voting Client Securities ................................................................................................................................
ITEM 18
Financial Information ................................................................................................................................... 15
3
NRG Wealth Management
ITEM 4
Advisory Business
FIRM INFORMATION
J.P. Davis, Inc. dba NRG Wealth Management (“NRG,” “we,” “us,” “our”), a corporation formed in April
2003, is an SEC-registered investment advisory firm located in Oro Valley, Arizona.
PRINCIPAL OWNERS
On March 31, 2022, NRG is owned and controlled by John Paul Davis. Mr. Davis is its President and
Chief Compliance Officer.
INVESTMENT ADVISORY SERVICES
Portfolio Management Services:
NRG offers ongoing portfolio management services based on the individual circumstances of each
client. Based upon the client’s investment risk tolerance, NRG creates an Investment Policy Statement
which outlines the client’s Investor Life Cycle, Goal(s), Time Horizon, Liquidity Needs, Tax
Constraints, and Unique Circumstances. From this information, NRG constructs a portfolio that
matches the client’s specific situation. Portfolio management services include, but are not limited to,
the following:
•
Investment strategy
•
Personal investment policy
•
Asset allocation
•
Asset selection
•
Risk tolerance
•
Regular portfolio monitoring
NRG evaluates the current investments of each client with respect to their risk tolerance levels and
time horizon. NRG will request discretionary authority from clients in order to select securities and
execute transactions without permission from the client prior to each transaction. Risk tolerance
levels and all suitability information is maintained using online software and will be reviewed at least
every two years.
is
to seek
fair and equitable allocation of
NRG seeks to execute portfolio management decisions that are made in accordance with the fiduciary
duties owed to its clients and without consideration of NRG’s economic, investment, or other financial
interests. To meet its fiduciary obligations, NRG attempts to avoid, among other things, investment
or trading practices that systematically advantage or disadvantage certain client portfolios, and
investment
accordingly, NRG’s policy
opportunities/transactions among its clients to avoid favoring one client over another over time. It
is NRG’s policy to allocate investment opportunities and transactions it identifies as being
Financial Guidance Services:
appropriate and prudent among its clients on a fair and equitable basis over time.
NRG’s Financial Guidance Services are generally delivered through the Blueprint, which includes, but
is not necessarily limited to, the following services (not all services are offered or applicable to all
clients):
Cash Out! Values exercise. Help create a clearly defined set of priorities focusing on the intent
and purpose of client resources, including money. The exercise is designed to help improve
financial life decisions.
4
NRG Wealth Management
Lifestyle/Legacy goals. Determine and record a specific set of goals the client would like to
accomplish regarding their financial future and legacy.
Financial goals review and analysis.
Record and deliver projections regarding aspects of the client’s future financial lives,
including the viability of financial plan through Monte Carlo simulation, investment
withdrawal rate, cash flow tables, investment growth rates, and estate value projections.
A net worth summary.
A portfolio snapshot.
Asset allocation recommendations.
Online portal to access bespoke financial reports and summaries on demand.
NRG offers modular planning services designed to meet an individual’s specific needs. Modular
planning most often will be charged on an hourly basis. These services may include one or more of
the following:
Cash flow management
Investment management recommendations for non-supervised assets (i.e., 401ks)
Retirement planning
Insurance needs analysis
Education cost planning
Estate planning (not including document preparation)
Tax planning (not including tax preparation and filing)
Loss of spouse planning
We will summarize our services in a written plan, which will typically include general
recommendations for a course of action or specific actions to be taken by the client. Implementation
of the recommendations will be at the client’s discretion.
5
NRG Wealth Management
CLIENT INVESTMENT OBJECTIVES/RESTRICTIONS
NRG provides a tailored program for each client. This will include an interview session to get to know
the client’s specific needs and requirements, as well as a plan that will be executed by NRG on behalf
of the client. NRG may use model allocations together with a specific set of recommendations for each
client based on their personal restrictions, needs, and targets. On a case by case basis, our clients may
impose restrictions on investing in certain securities or types of securities in accordance with their
values or beliefs. However, if the restrictions prevent us from properly servicing the client’s account,
or if the restrictions would require us to deviate from our standard suite of services, we reserve the
right to end the relationship.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interest ahead
of yours. WRAP FEE PROGRAMS
ASSETS UNDER MANAGEMENT
NRG does not participate in, recommend, or offer wrap fee programs.
ITEM 5
As of December 31, 2025, NRG managed $241,392,789 in AUM on a discretionary basis and $576,450
Fees and Compensation
in AUM on a non-discretionary basis.
PORTFOLIO MANAGEMENT ONLY FEES
Total Assets Under Management
Annual Fees
Minimum Fee (<$30,000)
$360.00
$30,000 - $1,000,000
1.25%
$1,000,001 - $2,000,000
1.15%
$2,000,001 – $5,000,000
0.85%
$5,000,001 - $10,000,000
0.75%
$10,000,001 – And Up
Negotiable
6
NRG Wealth Management
FINANCIAL GUIDANCE ONLY FEES
Total Assets Under Advisement*
Annual Fees
Minimum Fee (<$3,500,000)
$10,000
$3,500,000 – $5,000,000
0.30%
$5,000,001 - $10,000,000
0.20%
Alternative Financial Guidance Fee Schedule (Hourly / Fixed Fee)
$10,000,001 – And Up
Negotiable
Hourly
$450 per hour
Minimum fixed fee
$2,500
*AUA = Assets under advisement. Generally computed as all investable assets.
The fee is generally negotiable and calculated using the value of the assets in the account on the last
business day of the prior billing period. Financial guidance fees can be paid using a percent of total assets
under advisement or on a fixed schedule.
COMBINED SERVICES (PORTFOLIO MANAGEMENT & FINANCIAL GUIDANCE) FEES
Total Assets Under Management
Annual Fees
NRG may combine portfolio management services and financial guidance services for a combined
fee. The fee schedule is as follows:
Minimum Fee (<$625,000)
$10,000
$625,000 - $1,000,000
1.60%
$1,000,001 - $2,000,000
1.40%
$2,000,001 – $5,000,000
1.00%
$5,000,001 - $10,000,000
0.85%
$10,000,001 – And Up
Negotiable
The advisory fee is calculated using the value of the assets in the Account on the last business day of
the prior billing period.
These fees are generally negotiable, and the final fee schedule is attached as Exhibit II of the
Investment Advisory Contract.
7
NRG Wealth Management
FEE BILLING & PAYMENT
Our asset-based portfolio management fees are annual fees and may be negotiable. Asset-based
portfolio management fees are paid quarterly in advance. Payments are due on the first day of the
calendar quarter and are based on the account’s asset value as of the last business day of the prior
calendar quarter multiplied by the applicable annual rate and divided by four (4). The fee for the
subsequent quarter is billed and payable within ten (10) days after the end of the prior quarter, based
on the value of the Client’s account on the last business day of that quarter. We will deduct our asset-
based management fee only when in receipt of your written authorization by executing an investment
advisory agreement permitting the fees to be paid directly from your account.
Fees for our ongoing asset-based financial guidance services are calculated using the value of the
assets under advisement on the last business day of the prior billing period.
Financial guidance fees may be assessed by assets under management, on an hourly basis, or on a
fixed fee basis. An estimate for total hours will be determined at the start of the relationship in order
to determine whether hourly guidance or project-based guidance is in the client’s best interest. One-
time/hourly financial guidance fees will be payable upon completion of the financial plan or the
rendering of consulting. One-time/hourly financial guidance fees are generally paid via check unless
other arrangements have been made.
Clients are responsible for all third-party fees (i.e., custodian fees, mutual fund fees, transaction fees,
etc.). These fees are separate and distinct from the fees and expenses charged by NRG.
TERMINATION OF AGREEMENT
Either party may terminate the investment advisory agreement by providing 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 up to and including the effective date of termination.
For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees
collected in advance minus the daily rate* times the number of days elapsed in the billing period up
to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-
based fee rate by 365.)
Notwithstanding the above, if we do not deliver the appropriate disclosure statement to you at least
48 hours prior to you entering into any written or oral advisory contract with this us, then you have
the right to terminate the contract without penalty within five (5) business days after entering into
the contract.
OTHER COMPENSATION FOR THE SALE OF SECURITIES TO CLIENTS
Neither NRG nor its supervised persons accept any compensation for the sale of investment products,
including asset-based sales charges or service fees from the sale of mutual funds.
8
NRG Wealth Management
ITEM 6
Performance-Based Fees and Side-By-Side
Management
ITEM 7
We do not charge any performance-based fees, which are fees based on a share of capital gains on or
Types of Clients
capital appreciation of your assets.
We provide our investment advisory services to:
Individuals
High Net Worth Individuals
ITEM 8
There is no minimum account size required, but each service has a minimum fee which may be waived by
Methods of Analysis, Investment Strategies, and
NRG in its discretion.
Risk of Loss
METHODS OF ANALYSIS
Modern Portfolio Theory
We use various methods of analysis and investment strategies, including the following:
– Modern portfolio theory (MPT) is a risk-averse theory that involves the
construction of portfolios to maximize and optimize expected return based on a given level of market
risk, emphasizing that risk is an inherent part of higher reward. According to the theory, it’s possible
to construct an “efficient frontier” of optimal portfolios offering the maximum possible expected
return for a given level of risk.
MPT tries to understand the market as a whole and measure market risk in an attempt to reduce the
inherent risks of investing in the market. However, with every financial investment strategy, there is
a risk of a loss of principal. Not every investment decision will be profitable, and there can be no
Quantitative analysis
guarantee of any level of performance.
– Quantitative analysis deals with measurable factors as distinguished from
qualitative considerations such as the character of management or the state of employee morale, such
as the value of assets, the cost of capital, historical projections of sales, and so on.
Investment strategies using quantitative models may perform differently than expected as a result
of, among other things, the factors used in the models, the weight placed on each factor, changes from
the factors’ historical trends, and technical issues in the construction and implementation of the
models.
INVESTMENT STRATEGIES
When formulating investment advice or managing client assets, we will use the following investment
Long-Term Strategy
strategies. There are inherent risks associated with each of these strategies.
– A long-term strategy may not take advantage of short-term gains or may
9
NRG Wealth Management
Core and Satellite
experience more volatility over the life of the portfolio.
– NRG’s core and satellite approach to portfolio construction is a methodology
used to combine evidence-based, low turnover mutual funds (core) with smaller holdings of
individual stocks, actively managed funds, or alternative investments (satellite). This approach seeks
to establish a risk-controlled portfolio while also seeking to secure some prospects of
outperformance. Not every investment decision will be profitable, and there can be no guarantee of
any level of performance.
Your accounts are managed separately with your underlying investment strategies, restrictions, or
investment limitations defined within the investment management agreement.
POTENTIAL RISKS
Investing involves different levels of risk that can result in loss of any profits and/or principal you
have not realized. We manage your account in a manner consistent with your pre-determined risk
tolerance and suitability profile. However, we cannot guarantee that our efforts will be successful.
Investing involves the assumption of risk, including:
Investing in securities involves the risk of loss clients should be prepared to bear.
Financial Risk:
which is the risk that the companies we recommend to you perform poorly, which
Market Risk:
affect the price of your investment.
which is the risk that the stock market will decline, decreasing the value of the
Inflation Risk:
securities we recommend to you with it.
which is the risk that the rate of price increases in the economy deteriorates the
Political and Governmental Risk:
returns associated with the stock.
which is the risk that the value of your investment will be affected
Interest Rate Risk:
by the introduction of new laws or regulations.
which is the risk that the value of the investments we recommend to you will fall
Call Risk:
if interest rates rise.
which is the risk that your investment will be called or purchased back from you when
Default Risk:
conditions are favorable to the bond issuer and unfavorable to you.
which is the risk that issuer is unable to pay the contractual interest or principal on the
Manager Risk:
investment promptly or at all.
which is the risk that an actively managed mutual fund’s investment adviser will fail
Industry Risk:
to execute the fund’s stated investment strategy.
ITEM 9
which is the risk that a group of stocks in a single industry will decline in price due to
adverse developments in that industry, decreasing the value of mutual funds that are significantly
Disciplinary Information
invested in that industry.
As of the date of this brochure, we have not been subject to any disciplinary, legal, or regulatory
events related to past or present investment clients. There has been no disciplinary, legal, or
regulatory events related to us or any of our management persons.
10
NRG Wealth Management
Other Financial Activities and Affiliations
ITEM 10
FINANCIAL INDUSTRY ACTIVITIES
Neither NRG nor its management persons are registered or has an application pending to register as
a broker-dealer or a registered representative of a broker-dealer.
Neither NRG nor its management persons are registered or has an application pending to register as
a futures commission merchant, commodity pool operator, or commodity trading advisor.
AFFILIATIONS
Stefanie Morgan is the sole owner of various real estate rental properties for which she provides
property management services. Stefanie Morgan’s real estate rental properties and J.P. Davis, Inc. are
SELECTION OF OTHER INVESTMENT ADVISERS
not affiliated.
ITEM 11
Code of Ethics, Participation in Client Transactions
We do not recommend or select other investment advisers for our clients.
and Personal Trading
CODE OF ETHICS
NRG has developed a code of ethics that will apply to all of our supervised persons. We and our IARs
must act in a fiduciary capacity when providing investment advisory services to you. As a fiduciary,
it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and
to act solely in the best interest of each of our clients at all times. NRG has a fiduciary duty to all
clients. This fiduciary duty is considered the core underlying principle of our code of ethics, which
also covers our insider trading and personal securities transactions policies and procedures. We
require all of our supervised persons to conduct business with the highest level of ethical standards
and to comply with all federal and state securities laws at all times. Upon employment or affiliation
and at least annually thereafter, all supervised persons will acknowledge that they have read,
understand, and agree to comply with our Code of Ethics.
Our Code of Ethics is available to clients and prospective clients upon request.
RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST
Neither we nor any related person recommend to clients or buys or sells for clients’ accounts
securities in which we or a related person has a material financial interest.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
There may be instances where an IAR will recommend to investment advisory clients or prospective
clients the purchase or sale of securities in which an IAR, its affiliates, or other clients may also have
a position or interest. Certain affiliated accounts may trade in the same securities with client accounts
on an aggregated basis. Generally, in such circumstances, the affiliated and client accounts will share
execution costs equally. Completed trade orders will be allocated according to the instructions from
the initial trade order. Partially filled trade orders will be allocated on a pro-rata basis. Any exceptions
will be explained in the trade order.
11
NRG Wealth Management
PERSONAL TRADING
ITEM 12
Employees are permitted to have personal securities accounts as long as personal investing practices
are in line with fiduciary standards and regulatory requirements and do not conflict with their duty
to NRG and our clients. NRG monitors and controls personal trading. We forbid any officer or
employee, either personally or on behalf of others, to trade on material, nonpublic information or to
Brokerage Practices
communicate such information to others in violation of the law.
NRG currently has arrangements with Altruist LLC (“Altruist") and Shareholders Service Group
(“SSG”), members of FINRA/SIPC. Altruist and SSG are the unaffiliated, qualified custodians, whereby
NRG would require clients to custody their accounts. Altruist and SSG do not supervise NRG, its agents
or activities.
As a fiduciary, we are obligated to seek out the best execution of client transactions for the accounts
that we manage. In general, the execution of securities transactions is at a total cost to process each
transaction and are the most favorable under the circumstances. However, we do not limit the best
execution to the lowest available price. Additional factors are taken into consideration when
determining the arrangement and services in the selection of a broker-dealer or qualified custodian.
Our review consists of reviewing the commission and fee structures of various broker-dealers,
research platforms, and execution services. Accordingly, while we do consider competitive rates, we
do not necessarily obtain the lowest possible commission rates for account transactions. Therefore,
the overall services provided by unaffiliated broker-dealers and qualified custodians are evaluated
to determine the best execution. You may pay trade execution charges and higher commissions
through the trading platforms approved by us than through platforms that have not been approved
by us.
LLC Fee Schedule
available
at altruist.com/legal – are automatically
Adviser participates in the Model Marketplace [and/or uses tax management tools] of Altruist LLC,
an SEC-registered investment adviser and affiliate of Altruist Financial, LLC. Through the Model
Marketplace, Adviser has access to model portfolios, including Altruist LLC-generated portfolios and
Third-Party Portfolios to assist it in managing or advising Adviser’s client accounts. Adviser also has
the ability to create custom model portfolios and has access to tax management tools for use with
Altruist LLC-generated portfolios, Third-Party Portfolios, and custom model portfolios, to
assist Adviser in managing or advising its client accounts. Altruist LLC’s Model Marketplace fees and
tax management tool fees – each of which range between 0.00% and 1.00% and are listed in
the Altruist
deducted
from Adviser’s house account or passed through to and debited from clients’ accounts, according to
the instruction of Adviser. Altruist LLC and its affiliates do not act as investment advisers
or fiduciary to Adviser clients. Adviser is responsible for suitability of all investment decisions
and transactions for client accounts subscribed to model portfolios through the Model Marketplace.
RESEARCH AND OTHER SOFT DOLLAR BENEFITS
While NRG has no formal soft dollar program in which soft dollars are used to pay for third-party
services, NRG may receive research, products, or other services from custodians and broker-dealers
in connection with client securities transactions (“soft dollar benefits”). NRG may enter into soft-
dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e)
of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular
client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and
NRG does not seek to allocate benefits to client accounts proportionate to any soft dollar credits
12
NRG Wealth Management
generated by the accounts. NRG benefits by not having to produce or pay for the research, products,
or services, and NRG will have an incentive to recommend a broker-dealer based on receiving
research or services. Clients should be aware that NRG’s acceptance of soft dollar benefits may result
in higher commissions charged to the client.
BROKERAGE FOR CLIENT REFERRALS
We do not receive client referrals from broker-dealers.
DIRECTED BROKERAGE
NRG will require clients to use a specific broker-dealer to execute transactions. We do not permit
clients to direct us to execute transactions through another broker-dealer other than Altruist and
SSG. Not all advisers require clients to use a particular broker-dealer.
TRADE AGGREGATION
ITEM 13
If NRG buys or sells the same securities on behalf of more than one client, then it may (but would be
under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients
in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In
such case, NRG would place an aggregate order with the broker on behalf of all such clients in order
to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to
ensure that accounts are not systematically disadvantaged by this policy. NRG would determine the
appropriate number of shares and select the appropriate brokers consistent with its duty to seek best
Review of Accounts
execution, except for those accounts with specific brokerage direction (if any).
PERIODIC REVIEWS
All client accounts for NRG's advisory services provided on an ongoing basis are reviewed at least
twice a year by John P Davis with regard to clients’ respective investment policies and risk tolerance
levels. All accounts at NRG are assigned to this reviewer.
REVIEW TRIGGERS
Additional reviews may be triggered by events in the client’s financial or personal status. We also
conduct periodic reviews to evaluate the current market, economic, and political events and how
these may affect client accounts.
REGULAR REPORTS
Each client of NRG’s advisory services will receive advisory account reports from the custodian at a
minimum quarterly, depending on account activity. These reports show asset value by cash balances,
security, unit cost, total cost, current per share values, etc. Clients are encouraged to phone or email
us as often as they deem necessary to receive information regarding the investment tactics and
strategies being followed.
Financial guidance clients are provided a one-time written financial plan concerning their financial
situation. After the presentation of the plan, there are no further reports.
13
NRG Wealth Management
Client Referrals and Other Compensation
ITEM 14
NRG receives an economic benefit from certain custodians in the form of support products and
services made available to us and when clients maintain accounts at those custodians. These products
and services, how they benefit us, and the related conflicts of interest are described above (see Item
12 – Brokerage Practices). The availability to us of these products and services is not based on us
giving particular investment advice, such as buying particular securities for our clients.
ITEM 15
We do not pay a referral fee to third-party solicitors.
Custody
ITEM 16
We are not affiliated with the custodian. Altruist and SSG do not supervise NRG, its agents or activities.
We are deemed to have custody of client funds and securities due to our ability to deduct
management fees from clients’ accounts. We will not take physical custody of clients’ funds and will
not assign or transfer trading authorization to another advisor. Clients will receive account
statements from the qualified custodian(s) holding their funds and securities at least quarterly. The
custodian’s account statements will indicate the amount of our advisory fees deducted from the
clients’ account(s) each billing period. These statements should be carefully reviewed by the client
for accuracy. Accordingly, NRG will follow the safeguards specified by the SEC rather than undergo an
Investment Discretion
annual audit.
DISCRETIONARY AUTHORITY FOR TRADING
If you are participating in our asset-based portfolio management services, upon receiving your
written authorization via our executed investment advisory agreement, we will maintain trading
authorization over your designated account and may also implement trades on a discretionary basis.
When discretionary authority is granted, we will have the limited authority to determine the type of
securities to be purchased, sold, or exchanged and a number of securities that can be bought, sold, or
exchanged for your portfolio without obtaining your consent for each transaction.
ITEM 17
On a case-by-case basis, you may place reasonable restrictions on the types of investments that may
be purchased or sold in your account so long as the restrictions are explicitly set forth or included as
Voting Client Securities
an attachment to the investment advisory agreement.
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies,
and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the
Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications
relating to the Client’s investment assets. If the Client would like our opinion on a particular proxy vote,
they may contact us at the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event
we were to receive any written or electronic proxy materials, we would forward them directly to you by
mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would
forward you any electronic solicitation to vote proxies.
14
NRG Wealth Management
Financial Information
ITEM 18
We are not required to include a balance sheet for our most recent fiscal year. We are not subject to
a financial condition that is reasonably likely to impair our ability to meet contractual commitments
to our clients.
We are currently not in, nor have been historically in a financially precarious situation or the subject
of a bankruptcy petition.
15
NRG Wealth Management