View Document Text
Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
September 16, 2025
Onyx Bridge Wealth Group, LLC
120 White Plains Road, Suite 115
Tarrytown, NY, 10591
Firm Contact:
Cindy Schlanger
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Onyx Bridge
Wealth Group, LLC. If clients have any questions about the contents of this brochure, please contact
us at (914)909-6699. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any State Securities Authority. Additional
information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD #306097.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Onyx Bridge Wealth Group, LLC is required to make clients aware of information that has changed
since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them.
Clients can then determine whether to review the brochure in its entirety or to contact us with
questions about the changes.
As of September 2025, our firm has added disclosure in Item 4 (Advisory Business) and Item 10
(Other Financial Industry Activities & Affiliations) regarding two affiliated entities under common
control: Onyx Bridge Tax Group LLC and Onyx Bridge Retirement Group LLC. These entities
operate as separate businesses providing tax preparation/consulting services and retirement plan
administration services, respectively. While our firm shares certain physical premises with these
affiliates, all operations and client relationships are maintained independently. Clients of Onyx Bridge
Wealth Group, LLC are under no obligation to engage either entity for services, and any such
engagement would be pursuant to a separate agreement.
In addition, we have updated Item 10 of our Form ADV Part 2A Brochure to disclose that certain of
our investment adviser representatives are also registered representatives of Emerson Equity LLC,
a broker-dealer. We continue to have representatives affiliated with Purshe Kaplan Sterling
Investments (“PKS”).
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 2
Onyx Bridge Wealth Group, LLC
Item 3: Table of Contents
Contents
Item 1: Cover Page ........................................................................................................................................ 1
Item 2: Material Changes ............................................................................................................................... 1
Item 3: Table of Contents .............................................................................................................................. 3
Item 4: Advisory Business ............................................................................................................................. 4
Item 5: Fees & Compensation ....................................................................................................................... 7
Item 6: Performance-Based Fees & Side-By-Side Management................................................................. 10
Item 7: Types of Clients & Account Requirements ..................................................................................... 11
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .......................................................... 11
Item 9: Disciplinary Information ................................................................................................................. 24
Item 10: Other Financial Industry Activities & Affiliations........................................................................ 24
Item 11: Code of Ethics, Participation or Interest in ................................................................................... 25
Item 12: Brokerage Practices ....................................................................................................................... 26
Item 13: Review of Accounts ...................................................................................................................... 29
Item 14: Client Referrals & Other Compensation ....................................................................................... 29
Item 15: Custody.......................................................................................................................................... 30
Item 16: Investment Discretion ................................................................................................................... 31
Item 17: Voting Client Securities ................................................................................................................ 31
Item 18: Financial Information .................................................................................................................... 32
Item 1: Cover Page ...................................................................................................................................... 33
Item 2: Material Changes ............................................................................................................................. 33
Item 3: Table of Contents ............................................................................................................................ 35
Item 4: Services, Fees & Compensation ...................................................................................................... 36
Item 5: Account Requirements & Types of Clients ..................................................................................... 41
Item 6: Portfolio Manager Selection & Evaluation ..................................................................................... 41
Item 7: Client Information Provided to Portfolio Manager(s) ..................................................................... 42
Item 8: Client Contact with Portfolio Manager(s) ....................................................................................... 43
Item 9: Additional Information .................................................................................................................... 43
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 3
Onyx Bridge Wealth Group, LLC
Item 4: Advisory Business
Onyx Bridge Wealth Group, LLC is a limited liability company formed under the laws of the State of
Delaware in 2019 and has been in business as an investment adviser since that time. Our firm is
wholly owned by Jared Cohen. Our firm is dedicated to providing individuals and other types of
clients with a wide array of investment advisory services.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Asset Management Services (Wrap fee program)
Our firm offers discretionary and non-discretionary asset management services to our clients.
Discretionary asset management service means we will make investment decisions and place buy or
sell orders in your account without contacting you. These decisions would be made based upon your
stated investment objectives. Non-discretionary asset management service means that we must
obtain your approval prior to making any transactions in your account. You choose as to whether to
grant our firm discretionary authority or non-discretionary authority in your investment
management agreement with our firm.
In offering asset management services to its clients, our firm offers portfolio models for use with
clients. Our firm creates and manages its own portfolio models for use with clients, except for
portfolio models sourced through Schwab’s Managed Account Services™. In creating its own portfolio
models, we rely on research we obtain from third-party research consultants. Currently, we receive
our research from consultant Helios Quantitative Research LLC of Granite Bay, CA (“Helios”).
Capital Integration Systems LLC and iCapital Network, Inc.
Clients may also request that we consider certain investments offered on the Capital Integration
Systems LLC (“CAIS”) and iCapital Network, Inc. (“iCapital”) Alternative Investments Portals as
potential investments for the client’s Account. Please see Item 8 below for more information about
CAIS and iCapital, and risks associated with alternative investments.
Please see the firm’s Form ADV Part 2A, Appendix 1: Wrap Fee Program Brochure for more
information with respect to our wrap fee program.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 4
Onyx Bridge Wealth Group, LLC
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, End of Life
Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost
Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance
Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning. Some of these
services could be offered through third-party vendors engaged by our firm.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
•
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
•
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 5
Onyx Bridge Wealth Group, LLC
In some cases, we may use a third-party platform to facilitate management of held away assets such
as defined contribution plan participant accounts, with discretion. The platform allows us to avoid
being considered to have custody of Client funds since we do not have direct access to Client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the Client allowing them
to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser
will review the current account allocations. When deemed necessary, Adviser will rebalance the
account considering client investment goals and risk tolerance, and any change in allocations will
consider current economic and market trends. The goal is to improve account performance over time,
minimize loss during difficult markets, and manage internal fees that harm account performance.
Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed
necessary
Donor Advised Funds:
We may assist clients in establishing and managing Donor-Advised Funds (DAFs) as part of their
charitable giving strategy. Our services may include advising clients on the selection of a DAF
provider, recommending suitable investments for the fund, and coordinating charitable donations
made from the DAF.
Corporate Trustees:
As part of our fiduciary services, we assist clients in establishing trusts and may recommend using
Charles Schwab & Co., Inc. as a corporate trustee for clients who do not have an individual to act in
this capacity. Schwab serves as the corporate trustee and is responsible for the management and
administration of the trust assets in accordance with the terms of the trust agreement.
Tailoring of Advisory Services
Each Asset Management client has the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio. Restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the account.
Regulatory Assets Under Management
As of December 31, 2024, our firm manages approximately $994,089,023 in client assets on a
discretionary basis and $6,812,294 in client assets on a non-discretionary basis.
Affiliated Business
Our firm is under common control with two affiliated entities: Onyx Bridge Tax Group LLC and
Onyx Bridge Retirement Group LLC. These entities are operated as separate businesses and
provide tax and retirement plan administration services, respectively. While we share certain
physical office space, each business maintains separate operations, personnel, and financial records.
Clients of our advisory firm are under no obligation to engage either affiliated entity for services, and
any such engagement would be pursuant to a separate agreement.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 6
Onyx Bridge Wealth Group, LLC
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Asset Management Fees:
Please see our Wrap Fee Program Brochure for information regarding our fees and compensation
for Wrap Asset Management services.
Financial Planning & Consulting:
Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. The maximum hourly fee to be charged for our financial planning and
consulting services will not exceed $500; and flat fees to be charged for such services will not exceed
$10,000. The fee-paying arrangements will be determined on a case-by-case basis and will be
detailed in the signed consulting agreement. Our firm will not require a retainer exceeding $1,200
when services cannot be rendered within 6 months.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on the percentage of plan assets under
management or, in select cases, based on a flat fee as described below, in either case as agreed with
the client. The total estimated fee, as well as the ultimate fee charged, is based on the scope and
complexity of our engagement with the client. Fees based on a percentage of managed Plan assets
will not exceed 1.00%. Our fee for Retirement Plan Consulting services is negotiable, depending on
individual client circumstances. For example, instead of the above 1.00%-based fee for Retirement
Plan Consulting services, we and the client may agree to have an annual flat fee for such services;
provided, that, in order to have a flat fee arrangement with us, client must have one or more accounts
with us with assets under management equal to $2,500,000 or greater (“AUM threshold”). If the AUM
threshold is met at the time of contracting, Client may be charged a flat fee of up to $100,000.
As the fee for our Retirement Plan Consulting services is annual, it is charged to client each year,
regardless of whether a percentage-based fee or a flat fee is chosen. The fee arrangement for our
Retirement Plan Consulting services will be determined on a case-by-case basis and will be detailed
in the signed agreement for such services between us and the client.
We may modify the fee for our Retirement Plan Consulting services at any time upon 30 days prior
written notice to client.
Donor Advised Funds:
In connection with our advisory services for Donor-Advised Funds, we may charge an asset-based
fee for managing the investments held within the DAF. Additionally, clients may be subject to fees
imposed by the DAF sponsor, which are not collected by us.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 7
Onyx Bridge Wealth Group, LLC
Corporate Trustees:
If Schwab serves as a corporate trustee, clients may be subject to fees charged by Schwab for its
trustee services. These fees are separate from the fees charged by our firm for advisory services.
Other Types of Fees & Expenses
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges,
mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified
retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market
makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on
brokerage accounts and securities transactions. Our firm does not receive a portion of these fees.
Wrap clients will not incur transaction costs for trades by their chosen custodian. More information
about this can be found in our separate Wrap Fee Program Brochure.
IRA Rollover Considerations: As a normal extension of financial advice, we provide education or
recommendations related to the rollover of an employer-sponsored retirement plan. A plan
participant leaving employment has several options.
Each choice offers advantages and
disadvantages, depending on desired investment options and services, fees and expenses,
withdrawal options, required minimum distributions, tax treatment, and the investor's unique
financial needs and retirement plans. The complexity of these choices may lead an investor to seek
assistance from us.
An Associated Person who recommends an investor roll over plan assets into an Individual
Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets
are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan
assets into an IRA. In most cases, fees and expenses will increase to the investor as a result because
the above-described fees will apply to assets rolled over to an IRA and outlined ongoing services will
be extended to these assets.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are also
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. We have to act
in your best interests and not put our interest ahead of yours. At the same time, the way we make
money creates some conflicts with your interests.
Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact
investment management fees within the range disclosed in our Form ADV Part 2A Brochure. As a
result, the Associated Person servicing your account may charge more or less for the same service
than another Associated Person of our firm. Further, our annual investment management fee may be
higher than that charged by other investment advisors offering similar services/programs.
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly,
unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds,
etc.) are included as part of assets under management for purposes of calculating the firm’s advisory
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 8
Onyx Bridge Wealth Group, LLC
fee. At any specific point in time, depending upon perceived or anticipated market conditions/events
(there being no guarantee that such anticipated market conditions/events will occur), the firm may
maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While
assets are maintained in cash or cash equivalents, such amounts could miss market advances and,
depending upon current yields, at any point in time, the firm’s advisory fee could exceed the interest
paid by the client’s cash or cash equivalent positions.
Billing on Margin: Unless otherwise agreed in writing, the gross amount of assets in the client’s
account, including margin balances, are included as part of assets under management for purposes
of calculating the firm’s advisory fee. Clients should note that this practice will increase total assets
under management used to calculate advisory fees which will in turn increase the amount of fees
collected by our firm. This practice creates a conflict of interest in that our firm has an incentive to
use margin in order to increase the amount of billable assets. At all times, the firm and its Associated
Persons strive to uphold their fiduciary duty of fair dealing with clients. Clients are free to restrict
the use of margin by our firm. However, clients should note that any restriction on the use of margin
may negatively impact an account’s performance in a rising market.
limited to
Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, the firm will review client portfolios
on an ongoing basis to determine if any changes are necessary based upon various factors, including
but not
investment performance, fund manager tenure, style drift, account
additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment
objectives. Based upon these and other factors, there may be extended periods of time when the firm
determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding,
unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply
during these periods, and there can be no assurance that investment decisions made by the firm will
be profitable or equal any specific performance level(s).
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for our Asset Management
services by providing the written notice as provided in such agreement. Upon notice of termination
pro-rata advisory fees for services rendered to the point of termination will be charged. If advisory
fees cannot be deducted, our firm will send an invoice for due advisory fees to the client.
Either party may terminate the financial planning & consulting agreement signed with our firm for
our Financial Planning & Consulting services by providing the written notice as provided in such
agreement. For purposes of calculating refunds, all work performed by us up to the point of
termination shall be calculated at the hourly fee currently in effect. Clients will receive a pro-rata
refund of unearned fees based on the time and effort expended by our firm.
Either party may terminate the retirement plan consulting agreement signed with our firm for our
Retirement Plan Consulting services by providing the written notice as provided in such agreement.
Full refunds will only be made in cases where cancellation occurs within 5 business days of signing
an agreement. After 5 business days from initial signing, either party must provide the other party
30 days written notice to terminate billing. Billing will terminate 30 days after receipt of termination
notice. Clients will be charged on a pro-rata basis, which takes into account work completed by our
firm on behalf of the client. Clients will incur charges for bona fide advisory services rendered up to
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 9
Onyx Bridge Wealth Group, LLC
the point of termination (determined as 30 days from receipt of said written notice) and such fees
will be due and payable.
Commissionable Securities Sales
Some representatives of our firm are registered representatives of Purshe Kaplan Sterling
Investments (“PKS”), a broker-dealer, member FINRA/SIPC. As such they are able to accept
compensation for the sale of securities or other investment products, including distribution or
service (“trail”) fees. Please see the Form ADV Part 2B Brochure Supplement for your designated
representative to see if he or she is a registered representative of PKS. Clients should be aware that
the practice of accepting commissions for the sale of securities presents a conflict of interest and
gives our firm and/or our representatives an incentive to recommend investment products based on
the compensation received. Our firm generally addresses commissionable sales conflicts that arise
when explaining to clients these sales create an incentive to recommend based on the compensation
to be earned and/or when recommending commissionable mutual funds, explaining that “no-load”
funds are also available. Our firm does not prohibit clients from purchasing recommended
investment products through other unaffiliated brokers or agents.
Certain Associated Persons of our firm are licensed as independent insurance agents. These persons
will earn commission-based compensation for selling insurance products, including insurance
products they sell to our clients. Insurance commissions earned by these persons are separate from
and in addition to our advisory fees. The sale of insurance instruments and other commissionable
products offered by Associated Persons are intended to complement our advisory services. However,
this practice presents a conflict of interest because persons providing investment advice on behalf of
our firm who are insurance agents have an incentive to recommend insurance products to you for
the purpose of generating commissions rather than solely based on your needs. We address this
conflict of interest by recommending insurance products only where we, in good faith, believe that it
is appropriate for the client’s particular needs and circumstances and only after a full presentation
of the recommended insurance product to our client. In addition, we explain the insurance
underwriting process to our clients to illustrate how the insurer also reviews the client’s application
and disclosures prior to the issuance of a resulting insuring agreement. Clients to whom the firm
offers advisory services are informed that they are under no obligation to purchase insurance
services. Clients who do choose to purchase insurance services are under no obligation to use our
licensed Associated Persons and may use the insurance brokerage firm and agent of their choice.
Where fixed annuities are sold, clients should also note that the annuity sales result in substantial
up-front commissions and ongoing trails based on the annuity’s total value. In addition, many
annuities contain surrender charges and/or restrictions on access to your funds. Payments and
withdrawals can have tax consequences. Optional lifetime income benefit riders are used to calculate
lifetime payments only and are not available for cash surrender or in a death benefit unless specified
in the annuity contract. In some annuity products, fees can apply when using an income rider. Annuity
guarantees are based on the financial strength and claims-paying ability of the issuing insurance
company. We urge our clients to read all insurance contract disclosures carefully before making a
purchase decision. Rates and returns mentioned on any program presented are subject to change
without notice. Insurance products are subject to fees and additional expenses.
Item 6: Performance-Based Fees & Side-By-Side Management
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 10
Onyx Bridge Wealth Group, LLC
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit-Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We do not implement our own methods of analysis, but, rather, will rely on research we obtain from
third party research consultants. At this time, we receive research from Helios. Clients should refer
to our third-party research consultant’s brochures for more information about these firms’ methods
of analysis. Helios may use one or more of the following methods of analysis when providing research
to us:
Charting: In this type of technical analysis, our firm reviews charts of market and security activity in
an attempt to identify when the market is moving up or down and to predict when how long the trend
may last and when that trend might reverse.
Cyclical Analysis: Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis
Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable
information, such as management expertise, industry cycles, strength of research and development,
and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on
numbers that can be found on reports such as balance sheets. The two techniques, however, will often
be used together in order to examine a company's operations and evaluate its potential as an
investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to
the social and experiential realm rather than the mathematical one. This approach depends on the
kind of intelligence that machines (currently) lack, since things like positive associations with a
brand, management trustworthiness, customer satisfaction, competitive advantage and cultural
shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative
analysis is that subjective judgment may prove incorrect.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 11
Onyx Bridge Wealth Group, LLC
Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The
process usually consists of searching vast databases for patterns, such as correlations among liquid
assets or price-movement patterns (trend following or mean reversion). The resulting strategies may
involve high-frequency trading. The results of the analysis are taken into consideration in the
decision to buy or sell securities and in the management of portfolio characteristics. A risk in using
quantitative analysis is that the methods or models used may be based on assumptions that prove to
be incorrect.
Sector Analysis: Sector analysis involves identification and analysis of various industries or
economic sectors that are likely to exhibit superior performance. Academic studies indicate that the
health of a stock's sector is as important as the performance of the individual stock itself. In other
words, even the best stock located in a weak sector will often perform poorly because that sector is
out of favor. Each industry has differences in terms of its customer base, market share among firms,
industry growth, competition, regulation and business cycles. Learning how the industry operates
provides a deeper understanding of a company's financial health. One method of analyzing a
company's growth potential is examining whether the amount of customers in the overall market is
expected to grow. In some markets, there is zero or negative growth, a factor demanding careful
consideration. Additionally, market analysts recommend that investors should monitor sectors that
are nearing the bottom of performance rankings for possible signs of an impending turnaround.
Technical Analysis: A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Investment Strategies We Use
The following investment strategies are used in managing client accounts, provided that such
strategies are appropriate to the needs of the client and consistent with the client's investment
objectives, risk tolerance, and time horizons, among other considerations:
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 12
Onyx Bridge Wealth Group, LLC
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic,
foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-
term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these
three provides a starting point. Usually included are hybrid instruments such as convertible bonds
and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be
considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.;
Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps;
insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and
futures; foreign currency; venture capital; private equity; and/or distressed securities.
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames and diversification. The most common forms of asset allocation are: strategic, dynamic,
tactical, and core-satellite.
• Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset
mix that seeks to provide the optimal balance between expected risk and return for a long-
term investment horizon. Generally speaking, strategic asset allocation strategies are
agnostic to economic environments, i.e., they do not change their allocation postures relative
to changing market or economic conditions.
• Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in
that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance
between expected risk and return for a long-term investment horizon. Like strategic
allocation strategies, dynamic strategies largely retain exposure to their original asset
classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust
their postures over time relative to changes in the economic environment.
• Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or individual
stocks that show the most potential for perceived gains. While an original asset mix is
formulated much like strategic and dynamic portfolio, tactical strategies are often traded
more actively and are free to move entirely in and out of their core asset classes
• Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core'
strategic element making up the most significant portion of the portfolio, while applying a
dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this
way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical
allocation strategies mentioned above.
Exchange Traded Funds (“ETFs”): An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
between the returns of a fund and the returns of the index, can arise due to differences in
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 13
Onyx Bridge Wealth Group, LLC
composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous
pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs
trade like stocks, you can place orders just like with individual stocks - such as limit orders, good-
until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are
bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought
and sold at the market prices on the exchanges, which resemble the underlying NAV but are
independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV
of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in
board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can
buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which
generally can only be bought in the country in which they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees.
Margin Transactions: Our firm may purchase stocks, mutual funds, and/or other securities for your
portfolio with money borrowed from your brokerage account. This allows you to purchase more
stock than you would be able to with your available cash, and allows us to purchase stock without
selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate
for every client. The potential risks associated with these transactions are (1) You can lose more
funds than are deposited into the margin account; (2) the forced sale of securities or other assets in
your account; (3) the sale of securities or other assets without contacting you; and (4) you may not
be entitled to choose which securities or other assets in your account(s) are liquidated or sold to
meet a margin call.
Options: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder, or option buyer). The contract offers the buyer the right,
but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the
strike price) during a certain period of time or on a specific date (exercise date). Options are
extremely versatile securities. Traders use options to speculate, which is a relatively risky practice,
while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option
buyers and writers have conflicting views regarding the outlook on the performance of a:
• Call Option: Call options give the option to buy at certain price, so the buyer would want the
stock to go up. Conversely, the option writer needs to provide the underlying shares in the
event that the stock's market price exceeds the strike due to the contractual obligation. An
option writer who sells a call option believes that the underlying stock's price will drop
relative to the option's strike price during the life of the option, as that is how he will reap
maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes
that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock
for a lower price and then sell it for a profit. However, if the underlying stock does not close
above the strike price on the expiration date, the option buyer would lose the premium paid
for the call option.
• Put Option: Put options give the option to sell at a certain price, so the buyer would want the
stock to go down. The opposite is true for put option writers. For example, a put option buyer
is bearish on the underlying stock and believes its market price will fall below the specified
strike price on or before a specified date. On the other hand, an option writer who sells a put
option believes the underlying stock's price will increase about a specified price on or before
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 14
Onyx Bridge Wealth Group, LLC
the expiration date. If the underlying stock's price closes above the specified strike price on
the expiration date, the put option writer's maximum profit is achieved. Conversely, a put
option holder would only benefit from a fall in the underlying stock's price below the strike
price. If the underlying stock's price falls below the strike price, the put option writer is
obligated to purchase shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock
price to the option’s strike price, small movements in a stock can translate into big movements in the
underlying options.
Structured Products: Structured products are designed to facilitate highly customized risk-return
objectives. While structured products come in many different forms, they typically consist of a debt
security that is structured to make interest and principal payments based upon various assets, rates
or formulas. Many structured products include an embedded derivative component. Structured
products may be structured in the form of a security, in which case these products may receive
benefits provided under federal securities law, or they may be cast as derivatives, in which case they
are offered in the over-the-counter market and are subject to no regulation.
Investing in structured products includes significant risks, including valuation, lack of liquidity, price,
credit and market risks. The relative lack of liquidity due to the highly customized nature of the
investment. Moreover, the full extent of returns from the complex performance features is often not
realized until maturity. As such, structured products tend to be more of a buy-and-hold investment
decision rather than a means of getting in and out of a position with speed and efficiency.
Another risk with structured products is the credit quality of the issuer. Although the cash flows are
derived from other sources, the products themselves are legally considered to be the issuing financial
institution's liabilities. The vast majority of structured products are from high-investment-grade
issuers only. Also, there is a lack of pricing transparency. There is no uniform standard for pricing,
making it harder to compare the net-of-pricing attractiveness of alternative structured product
offerings than it is, for instance, to compare the net expense ratios of different mutual funds or
commissions among broker-dealers.
Third-Party Money Manager Analysis: The analysis of the experience, investment philosophies,
and past performance of independent third-party investment managers in an attempt to determine
if that manager has demonstrated an ability to invest over a period of time and in different economic
conditions. Analysis is completed by monitoring the manager’s underlying holdings, strategies,
concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of
the due-diligence process, the manager’s compliance and business enterprise risks are surveyed and
reviewed. A risk of investing with a third-party manager who has been successful in the past is that
they may not be able to replicate that success in the future. In addition, as our firm does not control
the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager
may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable
investment for our clients. Moreover, as our firm does not control the manager’s daily business and
compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent
business, regulatory or reputational deficiencies.
Donor Advised Funds:
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 15
Onyx Bridge Wealth Group, LLC
As part of our advisory services, we may recommend specific investment strategies for assets held
within Donor-Advised Funds. The investment options available within a DAF are generally limited to
the choices offered by the sponsoring organization, and we will consider these options when
providing advice.
Capital Integration Systems LLC Investments (“CAIS”)
CAIS sources and selects various private funds for its platform through a due diligence process
conducted by Mercer Investment Consulting (“Mercer”). Products that are appropriate and desirable
for the platform are subject to internal committee reviews by CAIS and a fully independent review
by Mercer. Product onboarding occurs only following the successful completion of these processes.
iCapital Network, Inc. (“iCapital”)
We have contracted with iCapital and their affiliates to provide our Associated Persons with access
to the iCapital Network alternative investment platform, software, and services. iCapital and/or its
affiliates conduct due diligence (investment and operational) on private equity and hedge fund
offerings available on their platform.
Privately Offered Securities valuations can lag a month or more and are provided by the issuer’s
third-party administrator, iCapital or CAIS to the custodian. The fee calculation uses this data to
calculate the fee.
In addition to reviewing the risk disclosure contained herein, clients participating in alternative
investments available to them through the iCapital and CAIS portals should closely read the relevant
prospectus or private placement memorandum prior to investing. Such documents are intended to
include all material risks of such investments, and are hereby incorporated herein by reference.
Risk of Loss
General Investment Risk: Investing in securities involves risk of loss that clients should be prepared
to bear. While the stock market may increase and the account(s) could enjoy a gain, it is also possible
that the stock market may decrease and the account(s) could suffer a loss. It is important that clients
understand the risks associated with investing in the stock market, and that their assets are
appropriately diversified in investments. Clients are encouraged to ask our firm any questions
regarding their risk tolerance.
Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
Concentrated Position Risk: Certain Associated Persons may recommend that clients concentrate
account assets in an industry or economic sector. In addition to the potential concentration of
accounts in one or more sectors, certain accounts may, or may be advised to, hold concentrated
positions in specific securities. Therefore, at times, an account may, or may be advised to, hold a
relatively small number of securities positions, each representing a relatively large portion of assets
in the account. As a result, the account will be subject to greater volatility than a more sector
diversified portfolio. Investments in issuers within an industry or economic sector that experiences
adverse economic, business, political conditions or other concerns will impact the value of such a
portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of
a single investment within the portfolio will affect the overall value of the portfolio and will cause
greater losses than it would in a portfolio that holds more diversified investments.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 16
Onyx Bridge Wealth Group, LLC
Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a
borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e., borrowed funds) are subject to credit
risk.
Cryptocurrency Risk: Cryptocurrency (e.g., bitcoin and ether), often referred to as “virtual
currency,” “digital currency,” or “digital assets,” is designed to act as a medium of exchange.
Cryptocurrency is an emerging asset class. There are thousands of cryptocurrencies, the most well-
known of which is bitcoin. Certain of the firm’s clients may have exposure to bitcoin or another
cryptocurrency, directly or indirectly through an investment such as an ETF or other investment
vehicles. Cryptocurrency operates without central authority or banks and is not backed by any
government. Cryptocurrencies may experience very high volatility and related investment vehicles
may be affected by such volatility. As a result of holding cryptocurrency, certain of the firm’s clients
may also trade at a significant premium or discount to NAV. Cryptocurrency is also not legal tender.
Federal, state or foreign governments may restrict the use and exchange of cryptocurrency, and
regulation in the U.S. is still developing. The market price of many cryptocurrencies, including bitcoin,
has been subject to extreme fluctuations. If cryptocurrency markets continue to be subject to sharp
fluctuations, investors may experience losses if the value of the client’s investments decline. Similar
to fiat currencies (i.e., a currency that is backed by a central bank or a national, supra-national or
quasi-national organization), cryptocurrencies are susceptible to theft, loss and destruction.
Cryptocurrency exchanges and other trading venues on which cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives and other currencies. The SEC has
issued a public report stating U.S. federal securities laws require treating some digital assets as
securities.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers or malware. Due to relatively recent launches, most cryptocurrencies have a limited
trading history, making it difficult for investors to evaluate investments. Generally, cryptocurrency
transactions are irreversible such that an improper transfer can only be undone by the receiver of
the cryptocurrency agreeing to return the cryptocurrency to the original sender. Digital assets are
highly dependent on their developers and there is no guarantee that development will continue or
that developers will not abandon a project with little or no notice. Third parties may assert
intellectual property claims relating to the holding and transfer of digital assets, including
cryptocurrencies, and their source code. Any threatened action that reduces confidence in a
network’s long-term ability to hold and transfer cryptocurrency may affect investments in
cryptocurrencies.
Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency
are uncertain and an investment in cryptocurrency may produce income that is not treated as
qualifying income for purposes of the income test applicable to regulated investment companies.
Certain cryptocurrency investments may be treated as a grantor trust for U.S. federal income tax
purposes, and an investment by the firm’s clients in such a vehicle will generally be treated as a direct
investment in cryptocurrency for tax purposes and “flow-through” to the underlying investors.
Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a
breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes,
and practices designed to protect networks, systems, computers, programs, and data from cyber-
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 17
Onyx Bridge Wealth Group, LLC
attacks and hacking by other computer users, and to avoid the resulting damage and disruption of
hardware and software systems, loss or corruption of data, and/or misappropriation of confidential
information. In general, cyber-attacks are deliberate; however, unintentional events may have
similar effects. Cyber-attacks may cause losses to clients by interfering with the processing of
transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading.
Clients may also incur substantial costs as the result of a cybersecurity breach, including those
associated with forensic analysis of the origin and scope of the breach, increased and upgraded
cybersecurity, identity theft, unauthorized use of proprietary information, litigation, and the
dissemination of confidential and proprietary information. Any such breach could expose our firm to
civil liability as well as regulatory inquiry and/or action. In addition, clients could be exposed to
additional losses as a result of unauthorized use of their personal information. While our firm has
established a business continuity plan and systems designed to prevent cyber-attacks, there are
inherent limitations in such plans and systems, including the possibility that certain risks have not
been identified. Similar types of cyber security risks are also present for issuers of securities,
investment companies and other investment advisers in which we invest, which could result in
material adverse consequences for such entities and may cause a client's investment in such entities
to lose value.
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to
certain environmental, social and governance (ESG) investment criteria it may avoid purchasing
certain securities for ESG reasons when it is otherwise economically advantageous to purchase those
securities or may sell certain securities for ESG reasons when it is otherwise economically
advantageous to hold those securities. In general, the application of the portfolio’s ESG investment
criteria may affect the portfolio’s exposure to certain issuers, industries, sectors and geographic
areas, which may affect the financial performance of the portfolio, positively or negatively, depending
on whether these issuers, industries, sectors or geographic areas are in or out of favor. An adviser
can vary materially from other advisers with respect to its methodology for constructing ESG
portfolios or screens, including with respect to the factors and data that it collects and evaluates as
part of its process. As a result, an adviser’s ESG portfolio or screen may materially differ from or
contradict the conclusions reached by other ESG advisers concerning the same issuers. Further, ESG
criteria are dependent on data and are subject to the risk that such data reported by issuers or
received from third-party sources may be subjective, or it may be objective in principle but not
verified or reliable.
ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities, the ETF, or mutual fund holds.
Financial Risk: Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 18
Onyx Bridge Wealth Group, LLC
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of resources
and end-user products generally increase and thus, the same general goods and products today will
likely be more expensive in the future. The longer an investment is held, the greater the chance that
the proceeds from that investment will be worth less in the future than what they are today. Said
another way, a dollar tomorrow will likely get you less than what it can today.
Inverse Funds: Inverse mutual funds and ETFs, which are sometimes referred to as "short" funds,
seek to provide the opposite of the single-day performance of the index or benchmark they track.
Inverse funds are often marketed as a way to profit from, or hedge exposure to, downward moving
markets. Some inverse funds also use leverage, such that they seek to achieve a return that is a
multiple of the opposite performance of the underlying index or benchmark (i.e., -200%, -300%). In
addition to leverage, these funds may also use derivative instruments to accomplish their objectives.
As such, inverse funds are highly volatile and provide the potential for significant losses.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. Thus, you may experience the risk that your investment or assets within
your investment may not be able to be liquidated quickly, thus, extending the period of time by which
you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable
pricing when exiting (i.e., not being able to quickly get out of an investment before the price drops
significantly) a particular investment and therefore, can have a negative impact on investment
returns.
Manager Risk: There is always the possibility that poor security selection will cause your
investments to underperform relative to benchmarks or other funds with a similar investment
objective.
Market Risk: The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes in
the market, and you could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g., earnings disappointment or
downgrade in the rating of a bond) or general market risk (e.g., such as a “bear” market when stock
values fall in general). For fixed-income securities, a period of rising interest rates could erode the
value of a bond since bond values generally fall as bond yields go up. Past performance is not a
guarantee of future returns.
Market Timing Risk: Market timing can include high risk of loss since it looks at an aggregate market
versus a specific security. Timing risk explains the potential for missing out on beneficial movements
in price due to an error in timing. This could cause harm to the value of an investor's portfolio because
of purchasing too high or selling too low.
Options Risk: Options on securities may be subject to greater fluctuations in value than an
investment in the underlying securities. Additionally, options have an expiration date, which makes
them “decay” in value over the amount of time they are held and can expire worthless. Purchasing
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 19
Onyx Bridge Wealth Group, LLC
and writing put and call options are highly specialized activities and entail greater than ordinary
investment risks.
Past Performance: Charting and technical analysis are often used interchangeably. Technical
analysis generally attempts to forecast an investment’s future potential by analyzing its past
performance and other related statistics. In particular, technical analysis often times involves an
evaluation of historical pricing and volume of a particular security for the purpose of forecasting
where future price and volume figures may go. As with any investment analysis method, technical
analysis runs the risk of not knowing the future and thus, investors should realize that even the most
diligent and thorough technical analysis cannot predict or guarantee the future performance of any
particular investment instrument or issuer thereof.
Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and
mortality over a wide geographic area, crossing international boundaries, and causing significant
economic, social, and political disruption. It is difficult to predict the long-term impact of such events
because they are dependent on a variety of factors including the global response of regulators and
governments to address and mitigate the worldwide effects of such events. Workforce reductions,
travel restrictions, governmental responses and policies and macroeconomic factors will negatively
impact investment returns.
Preferred Securities Risk: Preferred Securities have similar characteristics to bonds in that
preferred securities are designed to make fixed payments based on a percentage of their par value
and are senior to common stock. Like bonds, the market value of preferred securities is sensitive to
changes in interest rates as well as changes in issuer credit quality. Preferred securities, however,
are junior to bonds with regard to the distribution of corporate earnings and liquidation in the event
of bankruptcy. Preferred securities that are in the form of preferred stock also differ from bonds in
that dividends on preferred stock must be declared by the issuer’s board of directors, whereas
interest payments on bonds generally do not require action by the issuer’s board of directors, and
bondholders generally have protections that preferred stockholders do not have, such as indentures
that are designed to guarantee payments – subject to the credit quality of the issuer – with terms and
conditions for the benefit of bondholders. In contrast preferred stocks generally pay dividends, not
interest payments, which can be deferred or stopped in the event of credit stress without triggering
bankruptcy or default. Another difference is that preferred dividends are paid from the issue’s after-
tax profits, while bond interest is paid before taxes.
Recommendation of Other Advisers: In the event we recommend a third-party investment adviser
to manage all or a portion of your assets, we will advise you on how to allocate your assets among
various classes of securities or third-party investment managers, programs, or managed model
portfolios. As such, we will primarily rely on investment model portfolios and strategies developed
by the third-party investment advisers and their portfolio managers. If there is a significant deviation
in characteristics or performance from the stated strategy and/or benchmark, we may recommend
changing models or replacing a third-party investment adviser. The primary risks associated with
investing with a third party is that while a particular third party may have demonstrated a certain
level of success in the past; it may not be able to replicate that success in future markets. In addition,
as we do not control the underlying investments in third party model portfolios, there is also a risk
that a third party may deviate from the stated investment mandate or strategy of the portfolio,
making it a less suitable investment for our clients. To mitigate this risk, we seek third parties with
proven track records that have demonstrated a consistent level of performance and success over
time. A third party’s past performance is not a guarantee of future results and certain market and
economic risks exist that may adversely affect an account’s performance that could result in capital
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 20
Onyx Bridge Wealth Group, LLC
losses in your account. Please refer to the third-party investment adviser’s advisory agreements,
Form ADV Brochure, and associated disclosure documents for details on their specific investment
strategies, methods of analysis, and associated risks.
Risks Associated with Investing in Inverse and Leveraged Funds: Leveraged mutual funds and
ETFs generally seek to deliver multiples of the daily performance of the index or benchmark that they
track. Inverse mutual funds and ETFs generally seek to deliver the opposite of the daily performance
of the index or benchmark that they track. Inverse funds often are marketed as a way for investors
to profit from, or at least hedge their exposure to, downward-moving markets. Some Inverse funds
are both inverse and leveraged, meaning that they seek a return that is a multiple of the inverse
performance of the underlying index. To accomplish their objectives, leveraged and inverse funds
use a range of investment strategies, including swaps, futures contracts, and other derivative
instruments. Leveraged, inverse, and leveraged inverse funds are more volatile and riskier than
traditional funds due to their exposure to leverage and derivatives, particularly total return swaps
and futures. At times, we will recommend leveraged and/or inversed funds, which may amplify gains
and losses.
Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few
cases, monthly) basis, and reset their leverage daily. A "single day" is measured from the time the
leveraged fund calculates its net asset value ("NAV") to the time of the leveraged fund's next NAV
calculation. The return of the leveraged fund for periods longer than a single day will be the result of
each day's returns compounded over the period. Due to the effect of this mathematical compounding,
their performance over longer periods of time can differ significantly from the performance (or
inverse performance) of their underlying index or benchmark during the same period of time. For
periods longer than a single day, the leveraged fund will lose money when the level of the Index is
flat, and the leveraged fund may lose money even if the level of the Index rises. Longer holding
periods, higher index volatility, and greater leverage all exacerbate the impact of compounding on an
investor's returns. During periods of higher Index volatility, the volatility of the Index may affect the
leveraged fund's return as much as or more than the return of the Index itself. Therefore, holding
leveraged, inverse, and leveraged inverse funds for longer periods of time increases their risk due to
the effects of compounding and the inherent difficulty in market timing. Leveraged funds are riskier
than similarly benchmarked funds that do not use leverage. Non-traditional funds are highly volatile
and not suitable for all investors. They provide the potential for significant losses.
Risks Associated with Investing in Buffer ETFs: Buffer ETFs are also known as defined-outcome
ETFs since the ETF is designed to offer downside protection for a specified period of time. These ETFs
are modeled after options-based structured notes, but are generally cheaper, and offer more
liquidity. Buffer ETFs are designed to safeguard against market downturns by employing complex
options strategies. Buffer ETFs typically charge higher management fees that are considerably more
than the index funds whose performance they attempt to track. Additionally, because buffer funds
own options, they do not receive dividends from their equity holdings. Both factors result in the
underperformance of the Buffer ETF compared to the index they attempt to track. Clients should
carefully read the prospectus for a buffer ETF to fully understand the cost structures, risks, and
features of these complex products.
Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under
all market conditions and each investor should evaluate his/her ability to maintain any investment
he/she is considering in light of his/her own investment time horizon. Investments are subject to
risk, including possible loss of principal.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 21
Onyx Bridge Wealth Group, LLC
Structured Notes: Below are some specific risks related to the structured notes recommended by
our firm:
• Complexity: Structured notes are complex financial instruments. Clients should understand
the reference asset(s) or index(es) and determine how the note’s payoff structure
incorporates such reference asset(s) or index(es) in calculating the note’s performance. This
payoff calculation may include leverage multiplied by the performance of the reference asset
or index, protection from losses should the reference asset or index produce negative returns,
and/or fees. Structured notes may have complicated payoff structures that can make it
difficult for clients to accurately assess their value, risk and potential for growth through the
term of the structured note. Determining the performance of each note can be complex and
this calculation can vary significantly from note to note depending on the structure. Notes can
be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or
inverse-leveraged, which may result in larger returns or losses. Clients should carefully read
the prospectus for a structured note to fully understand how the payoff on a note will be
calculated and discuss these issues with our firm.
•
• Market risk. Some structured notes provide for the repayment of principal at maturity, which
is often referred to as “principal protection.” This principal protection is subject to the credit
risk of the issuing financial institution. Many structured notes do not offer this feature. For
structured notes that do not offer principal protection, the performance of the linked asset or
index may cause clients to lose some, or all, of their principal. Depending on the nature of the
linked asset or index, the market risk of the structured note may include changes in equity or
commodity prices, changes in interest rates or foreign exchange rates, and/or market
volatility.
Issuance price and note value: The price of a structured note at issuance will likely be higher
than the fair value of the structured note on the date of issuance. Issuers now generally
disclose an estimated value of the structured note on the cover page of the offering
prospectus, allowing investors to gauge the difference between the issuer’s estimated value
of the note and the issuance price. The estimated value of the notes is likely lower than the
issuance price of the note to investors because issuers include the costs for selling,
structuring, and/or hedging the exposure on the note in the initial price of their notes. After
issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to
value given their complexity.
• Liquidity: The ability to trade or sell structured notes in a secondary market is often very
limited, as structured notes (other than exchange-traded notes known as ETNs) are not listed
for trading on securities exchanges. As a result, the only potential buyer for a structured note
may be the issuing financial institution’s broker-dealer affiliate or the broker-dealer
distributor of the structured note. In addition, issuers often specifically disclaim their
intention to repurchase or make markets in the notes they issue. Clients should, therefore, be
prepared to hold a structured note to its maturity date or risk selling the note at a discount
to its value at the time of sale.
• Credit risk: Structured notes are unsecured debt obligations of the issuer, meaning that the
issuer is obligated to make payments on the notes as promised. These promises, including
any principal protection, are only as good as the financial health of the structured note issuer.
If the structured note issuer defaults on these obligations, investors may lose some, or all, of
the principal amount they invested in the structured notes as well as any other payments that
may be due on the structured notes.
Alternatives Risk: Non-traded REITs, business development companies, limited partnerships, and
direct alternatives are subject to various risks such as devaluation based on adverse market
conditions and may not be suitable for all investors. A prospectus that discloses all risks, fees, and
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 22
Onyx Bridge Wealth Group, LLC
expenses may be obtained from your investment adviser representative. Read the prospectus
carefully before investing. This disclosure is not a solicitation or offering which can only be made in
conjunction with a copy of the prospectus. Investors considering an investment strategy utilizing
alternative investments should understand that alternative investments are generally considered
speculative in nature; and, such investments involve a high degree of risk, particularly if
concentrating investments in one or few alternative investments.
Risks Associated with Investing in Private Funds: Private investment funds are not registered
with the Securities and Exchange Commission and may not be registered with any other regulatory
authority. Accordingly, they are not subject to certain regulatory restrictions and oversight to which
other issuers are subject. There may be little public information available about their investments
and performance. Moreover, as sales of shares of private investment companies are generally
restricted to certain qualified purchasers, it could be difficult for a client to sell its shares of a private
investment company at an advantageous price and time, and investments in a private investment
company routinely include a “lock up” period, during which investors are not permitted to withdraw
their funds from such private investment company. Since shares of private investment companies
are not publicly traded, from time to time it may be difficult to establish a fair value for the client’s
investment in these companies. In addition, private investment companies may employ leverage,
including the use of borrowed funds. While such strategy may increase the opportunity to achieve
higher returns on the amounts invested, it also increases the risk of loss.
Illiquid securities: Illiquid securities involve the risk that investments may not be readily sold at the
desired time or price. Securities that are illiquid, that are not publicly traded, and/or for which no
market is currently available may be difficult to purchase or sell, which may impact the price or
timing of a transaction. An inability to sell securities can adversely affect an account's value or
prevent an account from taking advantage of other investment opportunities. Lack of liquidity may
cause the value of investments to decline and illiquid investments may also be difficult to value. A
client may not be able to liquidate investment in the event of an emergency or any other reason.
Certain investment strategies used by our firm may invest in illiquid asset vehicles, such as private
equity and real estate. Investment in an illiquid asset vehicle poses similar risks as direct investments
in illiquid securities. In addition, investment in an illiquid asset vehicle will be subject to the terms
and conditions of the illiquid asset vehicle’s investment policy and governing documents that often
include provisions that may involve investor lock-in periods, mandatory capital calls, redemption
restrictions, infrequent valuation of assets, etc. In addition, investments in illiquid securities or
vehicle may normally involve investment in non-marketable securities where there is limited
transparency. If obligated to sell an illiquid security prior to an expected maturity date, particularly
with an infrastructure investment, they may not be able to realize fair value. Investments in illiquid
securities or vehicles may include restrictions on withdrawal rights and shares may not be freely
transferable.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our Wrap Asset
Management service, as applicable.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 23
Onyx Bridge Wealth Group, LLC
Item 9: Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of us or the integrity of our
management. There are no legal or disciplinary events that are material to the evaluation of our
advisory business or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Affiliations
Our firm has an affiliation with Charles Schwab & Co., Inc., and in certain scenarios we may
recommend Schwab to serve as a corporate trustee for client trusts. Schwab provides both custodial
and trust services and this relationship creates a potential conflict of interest, which we disclose fully
to clients.
Certain of our Investment Adviser Representatives (“IARs”) are also registered representatives of
Purshe Kaplan Sterling Investments (“PKS”), a broker-dealer and member of FINRA/SIPC. In
addition, some of our IARs are also registered representatives of Emerson Equity LLC (“Emerson”),
a broker-dealer and member of FINRA/SIPC. In their capacities as registered representatives of PKS
or Emerson, these individuals may recommend or effect securities transactions for which they
receive normal and customary commissions or other compensation.
This arrangement creates a conflict of interest because it gives our IARs an incentive to recommend
investment products based on the compensation received, rather than solely on the client’s needs.
To mitigate these conflicts, we disclose the relationship to clients and emphasize that our IARs have
a fiduciary duty to act in the client’s best interest. Clients are under no obligation to purchase
securities or investment products through PKS or Emerson and may choose any broker-dealer of
their preference.
Our firm is under common control with Onyx Bridge Tax Group LLC and Onyx Bridge Retirement
Group LLC.
• Onyx Bridge Tax Group LLC provides tax preparation, accounting, and related consulting services.
• Onyx Bridge Retirement Group LLC provides third-party administration (“TPA”) and retirement
plan services.
These entities are separate from our investment advisory business. No client information, revenue,
or operations are commingled unless we have signed client permission. A potential conflict of interest
exists to the extent that our investment adviser representatives may recommend the services of these
affiliates. To mitigate this conflict, we disclose the relationship and inform clients that they are free
to select any accounting firm or third-party service provider of their choice.
Activities
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 24
Onyx Bridge Wealth Group, LLC
As part of our client acquisition strategy, we may engage in cold calling as a tool for prospecting
potential clients. This activity is solely intended to identify and reach individuals who may benefit
from our investment advisory services. Our Investment Adviser Representatives (IARs) use cold
calling as an outreach method, and there are no associated sales incentives or commissions linked to
these calls.
We may source potential client leads through third-party lead generation services. However, there
are no conflicts of interest or financial incentives related to these services, and we are committed to
ensuring that all prospecting efforts comply with applicable regulations and maintain the highest
standards of professionalism.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
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. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives 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 with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demand the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
our representatives for their personal accounts1. In order to monitor compliance with our personal
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 25
Onyx Bridge Wealth Group, LLC
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day unless included in
a block trade. If related persons’ accounts are included in a block trade, our related persons will always
trade personal accounts last.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
While our firm does not maintain physical custody of client assets, we are deemed to have custody of
certain client assets if given the authority to withdraw assets from client accounts (see Item 15
Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to
recommend a custodian who will hold client assets and execute transactions on terms that are overall
most advantageous when compared to other available providers and their services. The factors
considered, among others, are these:
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record-keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
With this in consideration, we recommend the services of Charles Schwab & Co., Inc. (Schwab) through
their Institutional Platform. Schwab is an independent and unaffiliated registered broker-dealer and
member of FINRA and SIPC. The primary factor in suggesting a broker-dealer or custodian is that the
services of the recommended firm are provided in a cost-effective manner. While the quality of
execution at the best price is an important determinant, best execution does not necessarily mean
the lowest price and it is not the sole consideration. The trading process of any broker-dealer
suggested by our firm must be efficient, seamless, and straight-forward. Overall custodial support
services, trade correction services, and statement preparation are some of the other factors
determined when suggesting a broker-dealer.
Research and Other Soft Dollar Benefits received from Schwab
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 26
Onyx Bridge Wealth Group, LLC
Our firm has an institutional custodial relationship with Schwab Advisor Services (formerly called
Schwab Institutional). Schwab Advisor Services serves independent investment advisory firms like
ours. We are independently owned and operated and not affiliated with Schwab. Schwab will hold
your assets in a brokerage account and will buy and sell securities in your account(s) upon our
instructions. While we recommend that you use Schwab as custodian/broker, you will decide
whether to do so and you will open your account with Schwab by entering into an account agreement
directly with them. We do not open the account for you.
Your Custody and Brokerage Costs
Schwab generally does not charge you separately for custody services, but it is compensated by
charging commissions or other fees on trades that it executes or that settle into your Schwab account.
In addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or “trade away”
fee for each trade that we have executed by a different broker-dealer but where the securities bought
or the funds from the securities sold are deposited (settled) into your Schwab account.
Research and Other Soft Dollar Benefits
Although not considered “soft dollar” compensation, our firm may receive some economic benefits
from Schwab Advisor Services in the form of access to its institutional brokerage, trading, custody,
reporting, and related services, many of which are not typically available to Schwab retail customers.
Schwab also makes available various support services. Some of those services help us manage or
administer our clients’ accounts while others help us manage and grow our business. Schwab’s
support services are generally available on an unsolicited basis (we do not have to request them) and
at no charge to us. Below is a detailed description of Schwab’s support services:
Services that Benefit You: Schwab’s institutional brokerage services include access to a broad range
of investment products, execution of securities transactions, and custody of client assets. The
investment products available through Schwab include some to which we might not otherwise have
access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit you and your account.
Services that May Not Directly Benefit You: Schwab also makes available to us other products and
services that benefit us but may not directly benefit you or your account. These products and services
assist us in managing and administering our clients’ accounts. They include investment research,
both Schwab’s own and that of third parties. We may use this research to service all or some
substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition
to investment research, Schwab also makes available software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and account
statements);
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
facilitate payment of our fees from our clients’ accounts; and
•
• provide pricing and other market data;
•
• assist with back-office functions, recordkeeping, and client reporting.
Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage
and further develop our business enterprise. These services include:
• educational conferences and events;
•
technology, compliance, legal, and business consulting;
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 27
Onyx Bridge Wealth Group, LLC
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants, and insurance providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab may also discount or waive its fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits
such as occasional business entertainment of our personnel.
Transition Assistance Benefits
Schwab has provided our firm and its related persons assistance with the transition of their
associated business to their platform. The proceeds made available as Transition Assistance are
intended for a variety of purposes, including but not limited to: offsetting account transfer fees
(“ACAT”) that our clients might have otherwise incurred, legal services related to the formation of
the advisory firm, technology set-up fees, marketing and mailing costs, stationery, and licensure
transfer fees.
Our firm attempts to mitigate these conflicts of interest by evaluating and recommending that Clients
use Schwab’s services based on the benefits that such services provide, rather than the Transition
Assistance made available to our firm. We consider our custodial broker-dealers’ suite of services
when recommending that Clients maintain accounts with them. Clients should, however, be aware of
this conflict of interest and take it into consideration when deciding whether to custody their assets
in an advisory account at Schwab.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers and custodians with which we have an
institutional advisory arrangement. In addition, we do not receive other benefits from a broker-
dealer in exchange for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in determining
the brokers-dealers and/or custodians with whom orders for the purchase or sale of securities are
placed for execution and the commission rates at which such securities transactions are effected. Our
firm routinely requests that clients direct us to execute through a specified broker-dealer. Our firm
recommends the use of Schwab. Each client will be required to establish their account(s) with Schwab
if not already done. Please note that not all advisers have this requirement.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 28
Onyx Bridge Wealth Group, LLC
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Client-Directed Brokerage
Our firm does not allow client-directed brokerage outside our recommendations.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes
that to do so will be in the best interest of the effected accounts. When such concurrent authorizations
occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, our firm attempts to allocate trade executions in the most equitable
manner possible, taking into consideration client objectives, current asset allocation and availability of
funds using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts
Our management personnel or financial advisors review accounts on at least an annual basis for our
Wrap Asset Management. The nature of these reviews is to learn whether client accounts are in line
with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable.
Our firm may review client accounts more frequently than described above. Among the factors which
may trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc. Our firm does not provide written reports to clients, unless asked to do so. Verbal
reports to clients take place on at least an annual basis when our Wrap Asset Management clients are
contacted.
Item 14: Client Referrals & Other Compensation
Schwab
Our firm has brokerage and clearing arrangements with Schwab and receives additional benefits
from them in the form of electronic delivery of client information, electronic trading platforms,
institutional trading support, proprietary and/or third-party research, continuing education,
practice management advice, and other services provided by custodians for the benefit of
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 29
Onyx Bridge Wealth Group, LLC
investment advisory clients. Please refer to item 12 above for more information about the receipt of
additional benefits from broker-dealers/account custodians.
Product Sponsor Funded Events
Various product wholesalers provide financial assistance to allow us to sponsor client appreciation
events, educational seminars, or attend such seminars hosted by the product sponsor. This money is
not directly tied to our use of their products, nor it is contingent upon any future business to be
directed to their products, nonetheless it creates a conflict of interest that may incentivize us to utilize
their products. Our firm will adhere to our fiduciary duty to act in our client’s best interest when
selecting what products to use in client accounts.
Referral Fees
Our firm pays referral fees (non-commission based) to independent solicitors (non-registered
representatives) for the referral of their clients to our firm in accordance with Rule 206 (4)-3 of the
Investment Advisers Act of 1940. Such referral fee represents a share of our investment advisory fee
charged to our clients. This arrangement will not result in higher costs to the referred client. In this
regard, our firm maintains Solicitors Agreements in compliance with Rule 206 (4)-3 of the
Investment Advisers Act of 1940 and applicable state and federal laws. All clients referred by
Solicitors to our firm will be given full written disclosure describing the terms and fee arrangements
between our firm and Solicitor(s). In cases where state law requires licensure of solicitors, our firm
ensures that no solicitation fees are paid unless the solicitor is registered as an investment adviser
representative of our firm. If our firm is paying solicitation fees to another registered investment
adviser, the licensure of individuals is the other firm’s responsibility.
Item 15: Custody
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described in the Third Party
Money Movement discussion, below. All our clients receive account statements directly from their
qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully
review these statements. Additionally, if our firm decides to send its own account statements to
clients, such statements will include a legend that recommends the client compare the account
statements received from the qualified custodian with those received from our firm. Clients are
encouraged to raise any questions with us about the custody, safety or security of their assets and
our custodial recommendations.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 30
Onyx Bridge Wealth Group, LLC
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As
such, our firm has adopted the following safeguards in conjunction with our custodian:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Should clients grant our firm non-discretionary authority,
our firm would be required to obtain the client’s permission prior to effecting securities transactions.
Limitations may be imposed by the client in the form of specific constraints on any of these areas of
discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 31
Onyx Bridge Wealth Group, LLC
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• Our firm has never been the subject of a bankruptcy proceeding.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 32
Onyx Bridge Wealth Group, LLC
Item 1: Cover Page
Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure
April 15, 2025
Wrap Program
Sponsored by:
Onyx Bridge Wealth Group, LLC
120 White Plains Rd #115
Tarrytown, NY 10591
Firm Contact:
Cindy Schlanger
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Onyx Bridge
Wealth Group, LLC. If clients have any questions about the contents of this brochure, please contact
us at (914) 909-6699. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any State Securities Authority. Additional
information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD #306097.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 33
Onyx Bridge Wealth Group, LLC
Onyx Bridge Wealth Group, LLC is required to make clients aware of information that has changed
since the last annual update to the Wrap Brochure (“Wrap Brochure”) and that may be important to
them. Clients can then determine whether to review the brochure in its entirety or to contact us with
questions about the changes.
On March 31, 2025, we submitted our annual updating amendment filing for fiscal year 2024. We
have updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under
management of approximately $994,089,023, and non-discretionary assets under management of
approximately $6,812,294.
Additionally, we have updated several sections of our Brochure to provide information about added
services as detailed in Item 4 and the associated conflicts of interest including fees in Item 5. Please
refer to the Form ADV Part 2A for a complete list of our material changes.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 34
Onyx Bridge Wealth Group, LLC
Item 3: Table of Contents
A table of contents is found on page 3 of this Form ADV Part 2 Brochure.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 35
Onyx Bridge Wealth Group, LLC
Item 4: Services, Fees & Compensation
Onyx Bridge Wealth Group, LLC is a limited liability company formed under the laws of the State of
Delaware in 2019 and has been in business as an investment adviser since that time.
Our firm manages assets for many different types of clients to help meet their financial goals while
remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in
the client’s best interest. This is accomplished in part by knowing the client. Our firm has established
a service-oriented advisory practice with open lines of communication. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Our Wrap Advisory Services
Wrap Fee Program:
Our firm sponsors and offers a wrap fee program (“Wrap Fee Program”) whereby the firm manages
client accounts for an annual fee that includes certain discretionary or non-discretionary portfolio
management services, custodial services and trade execution services. Discretionary asset
management service means we will make investment decisions and place buy or sell orders in your
account without contacting you. These decisions would be made based upon your stated investment
objectives. Non-discretionary asset management service means that we must obtain your approval prior
to making any transactions in your account. You choose as to whether to grant our firm discretionary
authority or non-discretionary authority in your investment management agreement with our firm.
Under our Wrap Fee Program, we implement asset allocation and advisory services and create
portfolio models in conjunction with research we receive from third-party research consultants.
Certain portfolio models may be sourced through Schwab’s Managed Account Services™, and other
sub-advisers. At this time, we also receive research from consultant Helios Quantitative Research LLC
of Granite Bay, CA (“Helios”). In such cases, we are responsible for the creation of the portfolio models
and the client’s asset allocation strategy, security selection, account supervision, and implementation
of transactions.
Capital Integration Systems LLC and iCapital Network, Inc.
Clients may also request that we consider certain investments offered on the Capital Integration
Systems LLC (“CAIS”) and iCapital Network, Inc. (“iCapital”) Alternative Investments Portals as
potential investments for the client’s Account. Please see Item 8 of our Form ADV Part 2A above for
more information about CAIS, iCapital and risks associated with alternative investments.
A portfolio is created, and accounts are managed, to diversify a client’s investments and may include
various types of securities such as equity securities, exchange traded funds (“ETFs”), mutual funds,
U.S. government securities, corporate debt securities, commercial paper, municipal securities,
certificates of deposit, and covered options in its portfolio management programs. Other types of
investments may also be recommended where such investments are appropriate based on the
client’s stated goals and objectives. The client’s individual investment strategy under our Wrap Fee
Program is tailored to their specific needs and may include some or all of the previously mentioned
securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to
the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 36
Onyx Bridge Wealth Group, LLC
continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual
needs, stated goals and objectives
In some cases, our firm will utilize the sub-advisory services of a third-party investment advisory
firm or individual advisor to aid in the implementation of an investment portfolio designed by our
firm. Before selecting a firm or individual, our firm will ensure that the chosen party is properly
licensed or registered where required. We will provide initial due diligence on third party money
managers and ongoing reviews of the portion of client accounts that they manage. In order to assist
in the selection of a third-party money manager, our firm will gather client information pertaining to
financial situation, investment objectives, and reasonable restrictions to be imposed upon the
management of the account. Our firm will periodically review third party money manager reports
provided to the client at least annually.
Our firm will contact clients from time to time in order to review their financial situation and
objectives; communicate information to third party money managers as warranted; and, assist the
client in understanding and evaluating the services provided by the third-party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
Investments and allocations are determined and based upon the client’s investment objectives, risk
tolerance, time horizon, financial horizon, financial information, and other various suitability factors.
Further restrictions and guidelines imposed by clients may affect the composition and performance
of a client’s portfolio. For these reasons, performance of the portfolio may not be identical with the
average client of our firm. On an ongoing basis, our firm reviews the client’s financial circumstances
and investment objectives and makes the necessary adjustments to the client’s portfolio to achieve
the desired results.
In addition to providing us with information regarding their personal financial circumstances,
investment objectives and tolerance for risk, clients are required to provide the firm with prompt
notice of any changes in their personal financial circumstances, investment objectives, goals, and
tolerance for risk. We will contact clients at least annually to determine whether there have been any
changes in a client's personal financial circumstances, investment objectives, and tolerance for risk.
However, we construct your investment portfolio, we will monitor your portfolio’s performance on
a continuous basis, and rebalance the portfolio whenever necessary, as changes occur in market
conditions, your financial circumstances, or both.
In addition to the advisory services, the wrap fee program includes certain brokerage services of
Schwab. We are independently owned and operated and not affiliated with Schwab. Schwab will act
solely as broker-dealer and not as an investment advisor to you. They will have no discretion over
your account and will act solely on instructions they receive from us or you. Schwab has no
responsibility for our services and undertakes no duty to you to monitor our firm’s management of
your account or other services we provide to you. Schwab will hold your assets in a brokerage
account and buy and sell securities and execute other transactions when we or you instruct them to.
We do not open the account for you.
Wrap Fee Program Fee
For our Wrap Fee Program services, we charge an annual asset management fee of up to 2.00% of
the market value of the assets being managed. As mentioned above in this Item 4, the client receives
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 37
Onyx Bridge Wealth Group, LLC
asset management services that include discretionary portfolio management services, advisory
services, custodial services, and trade execution services for this annual fee.
Asset management fees are negotiable depending on factors such as the amount of assets under
management, range of investments, and complexity of the client’s financial circumstances, among
others. For example, instead of the above percentage-based fee for wrap asset management services,
we and client may agree to have a flat fee arrangement for such services; provided, that, in order to
have a flat fee arrangement with us, client must have one or more accounts with us with assets under
management equal to $2,500,000 or greater (“AUM threshold”). If the AUM threshold is met at the
time of contracting, Client may be charged a flat fee of up to $100,000.
We may modify the asset management fee for our services under our Wrap Fee Program at any time
upon 30 days prior written notice to client.
Asset management fees are billed monthly or quarterly, in advance or in arrears, based on the
average daily balance of the account for the billing period. The exact fee to be paid by the client, and
the timing of its payment, will be clearly stated in the asset management agreement signed by the
client and the firm. The custodian holding the client’s account will deduct the asset management fees
directly and automatically from the account provided the client has given written authorization and
will forward our portion of the fee to our firm. A client may choose to pay an annual flat fee for wrap
asset management services directly to us or to have such a flat fee deducted from the account at the
custodian. If insufficient cash is available to pay such asset management fees, securities in an amount
equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. The qualified
custodian will send an account statement at least quarterly. This statement will detail all account
activity. The custodian will usually deduct from a designated account to facilitate billing.
Privately Offered Securities valuations can lag a month or more and are provided by the issuer’s
third-party administrator, iCapital or CAIS to the custodian. The fee calculation uses this data to
calculate the fee.
At the inception of asset management services, the first pay period’s fees will be calculated on a pro-
rata basis. The investment advisor representative (an “IAR”) recommending our wrap asset
management services to a client will share in the asset management fee charged by us.
Fees are generally negotiable and will be deducted from client account(s). Adjustments will be made
for deposits and withdrawals during the billing period. Our firm does not offer direct invoicing. As
part of this process, Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the
market values for each security included in the Assets and all account disbursements,
including the amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms.
Our firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Advisory fees for assets managed through CAIS will be directly deducted separately by CAIS.
Fee Based Variable Annuity Products
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 38
Onyx Bridge Wealth Group, LLC
We have entered into an agreement with various vendors to provide fee-based variable annuity
products to our clients. Our firm and Associated Persons do not receive a commission on these
products. For these products, we will be paid an asset-based management fee according to our
advisory fee schedule (detailed above) and/or the client’s written agreement with the product
sponsor. Advisory fees are withdrawn directly from the client’s account(s) with the client’s written
authorization. With regard to variable annuity products, individual accounts will be maintained at
the insurance company that issued the variable annuity product. For fee-based variable annuity
accounts, our quarterly asset management fee is based on the value of the account as of the close of
business on the last day of each calendar quarter and is billed in arrears.
Additional Fees
In some cases, sub advisers and third-party money managers will charge a separate fee for
sub advisory services that is in addition to our wrap fee advisory fee. The combined annual fee
charged to clients whose wrap fee portfolios incorporate third party money managers and/or sub
advisors will not exceed the maximum fee published in our Wrap Fee Program Brochure. Our firm
will debit its fees as laid out in the executed advisory agreement between the client and our firm.
Third-party money managers establish and maintain their own billing procedures over which we
have no control. In general, they will directly bill you and you will receive a copy of the appropriate
disclosure documents that explain these procedures.
In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen
custodian for certain investments, charges imposed directly by a mutual fund, index fund, or
exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees,
initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable
annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark-
downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer
fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not
receive a portion of these fees.
Important Information About Fees
The benefits under a wrap fee program depend, in part, upon the size of the account, the costs
associated with managing the account, and the frequency or type of securities transactions executed
in the account.
For example, a wrap fee program may not be suitable for all accounts, including but not limited to
accounts holding primarily, and for any substantial period of time, cash or cash equivalent
investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security
that can be traded without commissions or other transaction fees.
In order to evaluate whether a wrap fee arrangement is appropriate for you, you should compare the
agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee
Program with the amounts that would be charged by other advisers, broker-dealers, and custodians,
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 39
Onyx Bridge Wealth Group, LLC
for advisory fees, brokerage, and execution costs, and custodial services comparable to those
provided under the Wrap Fee Program.
When managing a client's account on a wrap fee basis, we receive as compensation for our
investment advisory services, the balance of the total wrap fee you pay after custodial, trading and
other management costs (including execution and transaction fees) have been deducted.
Accordingly, we have a conflict of interest because we have a financial incentive to maximize our
compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to
a wrap fee. For example, our wrap fee arrangement creates incentives for us to trade less frequently
or select investments that that reduce our costs, and in some cases increase expenses that are borne
by the client.
Our recommended custodian Schwab generally does not charge transaction fees for online trades of
U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-transaction-fee (“NTF”) mutual funds.
This means that, in most cases, when we buy these types of securities, we can do so without paying
commissions to Schwab. Since we pay the transaction fees charged by the custodian to clients
participating in our Wrap Fee Program, this presents a conflict of interest because we are
incentivized to recommend no transaction fee equities and exchange traded funds over other types
of securities in order to reduce our costs.
In determining whether to establish a Wrap Fee Program account, you are advised that the overall
cost of the Wrap Fee Program may be higher than you might otherwise incur by purchasing
separately the types of securities available in the Wrap Fee Program. In order to compare the cost of
the Wrap Fee Program with unbundled services, you should consider the turnover rate in our
investment strategies, trading activity in the account, and standard advisory fees and brokerage
commissions that would be charged at Schwab, or other broker-dealers and investment advisers.
The advisory fee may cost you more compared to assets held in a traditional brokerage account. In a
brokerage account, a client is charged a commission for each transaction, and the representative has
no duty to provide ongoing advice with respect to the account. If you plan to follow a buy-and-hold
strategy for the account or you do not wish to purchase ongoing investment advice or management
services, you should consider opening a brokerage account rather than a Wrap Fee Program account.
The investment products available to be purchased in the wrap fee program can be purchased by you
outside of a wrap fee program account, through broker-dealers or other investment firms not
affiliated with our firm.
Fees and Costs Not Included in Wrap Fee
Our wrap fee does not include the fees and costs listed below. The fees and costs may apply to
transactions in your account. The fees and costs not included in the wrap fee that you will pay include:
• Commissions and other fees charged by broker-dealers other than Schwab for transactions
in your account if our firm uses Prime Brokerage, Step-In, or Trade Away Services.
• Fees charged by mutual fund companies, closed-end funds, electronically traded funds, and
other collective investment vehicles, including, but not limited to, sales loads and/or charges
and short-term redemption fees.
• Markups and markdowns, bid-ask spreads, and selling concessions in connection with
transactions Schwab executes as principal. Principal transactions contrast with transactions
in which Schwab acts as your agent in effecting trades. Markups and markdowns and bid-ask
spreads are not separate fees but are reflected in the net price at which a trade order is
executed.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 40
Onyx Bridge Wealth Group, LLC
• Costs imposed by third parties, such as transfer taxes, odd-lot differentials, certificate
delivery fees, reorganization fees, and any other fees required by law. Schwab may also
charge for additional services such as wire transfer fees and fees for alternative investments.
Termination and Refunds:
Either party may terminate the advisory agreement signed with our firm for Wrap Asset Management
services by providing the written notice provided under the asset management agreement you sign
with us for our Wrap Asset Management services. Upon notice of termination, our firm will process
a pro-rata refund of the unearned portion of the advisory fees (if any) charged in advance.
Item 5: Account Requirements & Types of Clients
Our firm has the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us.
Item 6: Portfolio Manager Selection & Evaluation
Selection of Portfolio Managers:
Our firm’s investment adviser representatives (“IARs”) act as portfolio manager(s) for our Wrap Fee
Program. A conflict arises in that other investment advisory firms may charge the same or lower fees
than our firm for similar services. Our IARs are subject to individual licensing requirements as
imposed by state securities boards. Our firm is required to confirm or update each IAR’s Form U4 on
an annual basis. IAR supervision is conducted by our Chief Compliance Officer or management
personnel.
In some cases, our firm will utilize the sub-advisory services of a third-party investment advisory
firm or individual advisor to aid in the implementation of an investment portfolio designed by our
firm. Before selecting a firm or individual, our firm will ensure that the chosen party is properly
licensed or registered where required. We will provide initial due diligence on third party money
managers and ongoing reviews of the portion of client accounts that they manage. In order to assist
in the selection of a third-party money manager, our firm will gather client information pertaining to
financial situation, investment objectives, and reasonable restrictions to be imposed upon the
management of the account. Our firm will periodically review third party money manager reports
provided to the client at least annually.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 41
Onyx Bridge Wealth Group, LLC
In some cases, third-party money managers will charge a separate fee for sub advisory
services that is in addition to our wrap fee advisory fee. The combined annual fee charged to
clients whose wrap fee portfolios incorporate third party money managers and/or sub advisors will
not exceed the maximum fee published in our Wrap Fee Program Brochure.
Advisory Business:
Information about our Wrap Fee Program services can be found in Item 4 of this brochure. Our firm
offers individualized investment advice to our clients under the Wrap Fee Program.
Each client under the Wrap Fee Program has the opportunity to place reasonable restrictions on the
types of investments to be held in the portfolio. Restrictions on investments in certain securities or
types of securities may not be possible due to the level of difficulty this would entail in managing the
account.
Participation in Wrap Fee Programs:
All accounts are managed on an individualized basis according to the client’s investment objectives,
financial goals, risk tolerance, etc.
Performance-Based Fees & Side-By-Side Management:
Our firm does not charge performance-based fees.
Investment Strategies
Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information
about our firm’s investment strategies.
Methods of Analysis
Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information
about the methods of analysis used by our firm.
Risk of Loss
Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information
about risks associated with investments in securities.
Voting Client Securities:
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Item 7: Client Information Provided to Portfolio Manager(s)
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 42
Onyx Bridge Wealth Group, LLC
All accounts are managed by our licensed IARs. The IAR selected to manage the client’s account(s) or
portfolio(s) will be privy to the client’s investment goals and objectives, risk tolerance, restrictions
placed on the management of the account(s) or portfolio(s) and relevant client notes taken by our
firm. Please see our firm’s Privacy Policy for more information on how our firm utilizes client
information.
Our firm will provide the following types of information about our clients to sub advisers and/or
third-party investment managers:
• Client name and contact information
• Client income
• Employment and residential information
• Social security number
• Personal information
• Cash balance
• Security balances
• Transaction detail history
•
Investment objectives, goals and risk tolerance
Most sub advisers and/or third-party investment managers also collect separate suitability
information from clients.
Item 8: Client Contact with Portfolio Manager(s)
Clients are always free to directly contact their portfolio manager(s) with any questions or concerns
about their portfolios or other matters.
Item 9: Additional Information
Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Financial Industry Activities & Affiliations
Please refer to Item 10 of our Form ADV Part 2A Brochure above for information about our other
financial industry activities and/or affiliations.
Code of Ethics, Participation or Interest in Client Transactions & Personal Trading
Please refer to Item 11 of our Form ADV Part 2A Brochure above for information about our Code of
Ethics, Participation or Interest in Client Transactions and Personal Trading.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 43
Onyx Bridge Wealth Group, LLC
Review of Accounts
Please refer to Item 13 of our Form ADV Part 2A Brochure above for information about Account
Reviews, Statements, and Reports.
Brokerage Practices and Trade Aggregation
Please refer to Item 12 of the firm’s Form ADV Part 2A Disclosure Brochure above for information
about our brokerage practices and trade aggregation.
Client Referrals & Other Compensation
Please refer to Item 14 of our Form ADV Part 2A Brochure above for information about Client
Referrals & Other Compensation.
Financial Information
Please refer to Item 18 of our Form ADV Part 2A Brochure above for Financial Information about our
firm.
ADV Part 2A – Firm Brochure &
ADV Part 2A, Appendix 1 – Wrap Fee Brochure
Page 44
Onyx Bridge Wealth Group, LLC