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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
March 2026
620 Newport Center Drive, Suite 1100
Newport Beach, CA 92660
www.pariax.com
Firm Contact:
Aria Khalili
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Pariax, LLC
dba Pariax Private Wealth Management. If clients have any questions about the contents of this
brochure, please contact us at (949) 688-0881 or info@pariax.com. The information in this brochure
has not been approved or verified by the United States Securities and Exchange Commission or by
any State Securities Authority. Additional information about our firm is also available on the SEC’s
website at www.adviserinfo.sec.gov by searching CRD #301474.
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
Pariax Private Wealth Management 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.
Since the last annual amendment filed on 02/26/2025, our firm has the following material change(s)
to disclose:
• Our firm has reduced the maximum fee for our Retirement Plan Consulting service from
2.00% to 1.50%. Clients will remain subject to the fee arrangements in their signed advisory
agreement. Please see Item 5 for additional information.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 6
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 7
Item 7: Types of Clients & Account Requirements .................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 7
Item 9: Disciplinary Information .................................................................................................................................... 13
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 13
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............ 13
Item 12: Brokerage Practices ........................................................................................................................................... 14
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 17
Item 14: Client Referrals & Other Compensation ..................................................................................................... 17
Item 15: Custody .................................................................................................................................................................... 17
Item 16: Investment Discretion ....................................................................................................................................... 18
Item 17: Voting Client Securities ..................................................................................................................................... 18
Item 18: Financial Information ........................................................................................................................................ 18
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Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm 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 Aria Khalili.
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 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—Item 11 of this Brochure—which includes procedures for personal
securities transactions 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.
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
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. Financial Planning and Consulting 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, 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.
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. As requested by our
clients our firm provides a written summary of the clients financial situation and our observations.
Financial consultations are not typically accompanied by a written summary as the process is less
formal than the planning service. Further, it is important to note that this service is not offered on a
standalone basis and is only available on a complimentary basis when requested by our Wrap Asset
Management Clients.
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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 managing
and monitoring their company's retirement plan assets. As the needs of the plan sponsor dictate,
areas of advising may include:
•
• 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.
In providing Retirement Plan Consulting services, 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.
Portfolio Monitoring:
Our firm provides general asset allocation guidance within parameters of a plan held with outside
custodians for our Portfolio Monitoring service. This service is solely consultative in nature and does
not include ongoing supervision, trading, or discretion with respect to securities transactions. Clients
are responsible for placing and executing their own trades, either on their own or with another
investment adviser. We provide non-continuous and periodic outside account monitoring. This service
is only available on a complimentary basis when requested by our Wrap Asset Management clients.
Tailoring of Advisory Services
Our firm only offers individualized investment advice to our Wrap Asset Management clients. General
investment advice will be offered to our Financial Planning & Consulting, Retirement Plan Consulting,
and Portfolio Monitoring clients.
Our firm does not usually allow Wrap Asset Management clients to impose restrictions on investing
in certain securities or types of securities due to the level of difficulty this would entail in managing
their account. Exceptions will be made on a case-by-case basis.
Participation in Wrap Fee Programs
Our firm offers and sponsors a wrap fee program, as further described in Part 2A, Appendix 1 (the
“Wrap Fee Program Brochure”). Our firm does not offer advisory services on a non-wrap basis. All
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accounts are managed on an individualized basis according to the client’s investment objectives,
financial goals, risk tolerance, etc.
Regulatory Assets Under Management
As of 12/31/2025, our firm managed $115,360,000 on a discretionary basis.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Financial Planning & Consulting:
Our firm does not charge fees for financial plans as this service is offered on a complimentary basis
when requested by our Wrap Asset Management Clients.
Portfolio Monitoring:
Our firm does not charge fees for portfolio monitoring as this service is offered on a complimentary
basis when requested by our Wrap Asset Management Clients.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed as a fee based on the percentage of Plan assets
under management. 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 annual fee charged for this service
is 1.50%. Our firm, in its sole discretion, may determine fees according to the expected scope of the
engagement and prospective client-advisor relationship. Fees to be assessed will be outlined in the
advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis monthly
in advance based on the last day of the previous month. Fees will be directly deducted from client
account(s). Our firm will only offer direct invoicing in instances where deductions may not be made
from the Plan’s Account(s). Further, our firm will assess advisory fees on all assets held in client
accounts including cash and cash equivalents. As part of the fee deduction 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 accounts and all account disbursements,
including the amount of the advisory fees paid to our firm.
b) Clients will provide authorization permitting our firm to directly debit its fees by these
terms.
c) Our firm will send an invoice directly to the custodian. If our firm sends a statement to the
client, it will include a disclosure urging the client to compare the information provided in
our statement with the statements provided by the qualified custodian.
Termination & Refunds
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the other party. Full refunds will only be made in cases where cancellation occurs
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within 5 business days of signing an agreement. Upon notice of termination, our firm will process a
pro-rata refund of the unearned portion of the advisory fees charged in advance.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
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 requirements for opening and maintaining accounts or otherwise engaging us:
• Our firm requires a minimum account balance of $1,000,000 for our Wrap Asset Management
service. Generally, this minimum account balance requirement is not negotiable and would
be required throughout the course of the client’s relationship with our firm. Exceptions may
be made at the sole discretion of our firm.
Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at
Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
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.
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
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can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
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.
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
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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
We use the following strategies 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
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.
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• 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.
Equity Securities: Equity securities represent an ownership position in a company. Equity securities
typically consist of common stocks. The prices of equity securities fluctuate based on, among other
things, events specific to their issuers and market, economic and other conditions. For example,
prices of these securities can be affected by financial contracts held by the issuer or third parties
(such as derivatives) relating to the security or other assets or indices. There may be little trading in
the secondary market for particular equity securities, which may adversely affect our firm 's ability
to value accurately or dispose of such equity securities. Adverse publicity and investor perceptions,
whether or not based on fundamental analysis, may decrease the value and/or liquidity of equity
securities. Investing in smaller companies may pose additional risks as it is often more difficult to
value or dispose of small company stocks, more difficult to obtain information about smaller
companies, and the prices of their stocks may be more volatile than stocks of larger, more established
companies. Clients should have a long-term perspective and, for example, be able to tolerate
potentially sharp declines in value.
Exchange Traded Funds (“ETFs”): An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective may be 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 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. Anyone can buy any ETF no matter where in the world it trades.
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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. However, individual investors may pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently,
this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk
associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm makes a decision to sell.
Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). Our firm does this in an
attempt to take advantage of conditions that our firm believes will soon result in a price swing in the
securities our firm purchase.
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Risk of Loss
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.
Cash & Cash Equivalent Risk: Cash and cash equivalents generally refer to either United States
dollars or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank
CD’s and commercial paper. Generally, these assets are considered nonproductive and will be
exposed to inflation risk and considerable opportunity cost risk. Investments in cash and cash
equivalents will generally return less than the advisory fee charged by our firm.
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.
Equity/Company Risk: When investing in stock positions, there is always a certain level of company
or industry specific risk that is inherent in each investment. This is also referred to as unsystematic
risk and can be reduced through appropriate diversification. There is the risk that the company will
perform poorly or have its value reduced based on factors specific to the company or its industry.
For example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
ETF Risk: When investing in an ETF, you will bear additional expenses based on your pro rata share
of the ETF’s operating expenses, including the potential to pay additional management fees. The risk
of owning an ETF generally reflects the risks of owning the underlying securities, the ETF, holds.
Clients may also incur brokerage costs when purchasing or selling ETFs.
Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may
cause your account value to likewise decrease, and vice versa. How specific fixed income securities
may react to changes in interest rates will depend on the specific characteristics of each security.
Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity
risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely
manner, or that negative perceptions of the issuer’s ability to make such payments will cause the
price of a bond to decline.
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.
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
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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.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in FCASH, 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 services, as applicable.
Item 9: 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.
Item 10: Other Financial Industry Activities & Affiliations
Aria Khalili, Managing Director and Chief Compliance Officer of our firm, is a licensed insurance
agent/broker. He may offer insurance products and receive customary fees as a result of insurance
sales. A conflict of interest exists as these insurance sales create an incentive to recommend products
based on the compensation adviser and/or our supervised persons may earn. To mitigate this
potential conflict, Mr. Khalili, as a fiduciary, will act in the client’s best interest.
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 demands 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.
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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 any potential 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.
Likewise, related persons of our firm may 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, neither our firm nor its related persons will
purposely favor their transactions over Client transactions.
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
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.
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Pariax Private Wealth Management
Our firm has an arrangement with National Financial Services LLC and Fidelity Brokerage Services LLC
(collectively, and together with all affiliates, "Fidelity") through which Fidelity provides our firm with
"institutional platform services." Our firm is independently operated and owned and is not affiliated with
Fidelity. The institutional platform services include, among others, brokerage, custody, and other related
services. Fidelity's institutional platform services that assist us in managing and administering clients'
accounts include software and other technology that (i) provide access to client account data (such as
trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated
trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv)
facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
Fidelity may make certain research and brokerage services available at no additional cost to our firm.
include: research reports on
Research products and services provided by Fidelity may
recommendations or other information about particular companies or industries; economic surveys,
data and analyses; financial publications; portfolio evaluation services; financial database software and
services; computerized news and pricing services; quotation equipment for use in running software
used in investment decision-making; and other products or services that provide lawful and appropriate
assistance by Fidelity to our firm in the performance of our investment decision-making responsibilities.
The aforementioned research and brokerage services qualify for the safe harbor exemption defined in
Section 28(e) of the Securities Exchange Act of 1934.
Fidelity does not make client brokerage commissions generated by client transactions available for
our firm’s use. The aforementioned research and brokerage services are used by our firm to manage
accounts for which our firm has investment discretion. Without this arrangement, our firm might be
compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, our firm will at all times to put the interests of our clients
first. Clients should be aware, however, that the receipt of economic benefits by our firm or our
related persons creates a potential conflict of interest and may indirectly influence our firm’s choice
of Fidelity as a custodial recommendation. Our firm examined this potential conflict of interest when
our firm chose to recommend Fidelity and have determined that the recommendation is in the best
interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best
execution.
Our non-wrap fee clients may pay a transaction fee or commission to Fidelity that is higher than
another qualified broker dealer might charge to effect the same transaction where our firm
determines in good faith that the commission is reasonable in relation to the value of the brokerage
and research services provided to the client as a whole.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Services that Generally Benefit Only Our Firm
Fidelity also offers other services intended to help manage and further develop our business
enterprise. These services include:
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technology, compliance, legal, and business consulting;
• educational conferences and events
•
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance providers.
Fidelity may provide some of these services itself. In other cases, Fidelity will arrange for third-party
vendors to provide the services to our firm. Fidelity may also discount or waive fees for some of these
services or pay all or a part of a third party’s fees. Fidelity may also provide our firm with other
benefits, such as occasional business entertainment for our personnel.
Irrespective of direct or indirect benefits to our firm or Client through Fidelity, our firm strives to
enhance the client experience, help clients reach their goals and put client interests before that of our
firm or associated persons.
Client Brokerage Commissions
Fidelity does not make client brokerage commissions generated by client transactions available for
our firm’s use.
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
Our firm does not engage in the practice of directing client brokerage to compensate or otherwise
reward brokers for client referrals.
Directed Brokerage
Our firm routinely requests that clients direct us to execute through a specified broker-dealer. Our
firm recommends the use of Fidelity. Each client will be required to establish their account(s) with
Fidelity 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
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.
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Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. Generally, portfolio transactions
are 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 or Financial Plans
Our Managing Director and CCO, Aria Khalili, reviews all client accounts on at least an annual basis.
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 does not provide written reports to clients, unless asked to do so. Verbal reports
to clients take place on at least an annual basis.
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.
Item 14: Client Referrals & Other Compensation
Fidelity
Except for the arrangements outlined in Item 12 of Form ADV Part 2A, our firm has no additional
arrangements to disclose.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Direct Fee Debiting:
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 below under
“Standing Instructions.” 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
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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
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 safeguarding procedures in conjunction with our custodian,
Fidelity:
• Fidelity’s forms, used to establish a standing letter of authorization, include the name and
account number on the receiving account and must be signed by the client.
• Fidelity’s SLOA forms currently require client’s signature.
• Fidelity performs verification on all SLOA forms and sends a transfer of notice to the client
promptly following the transaction.
• Clients always have the ability to terminate (or amend) an SLOA in writing.
• Our firm has no authority, or ability, to amend the third party designated on a standing
instruction.
• Our firm maintains records showing the third party is not a related party of our firm or
located at our firm.
• Fidelity notifies the client in writing when a new standing instruction is set up. Clients also
receive an annual mailing reconfirming the existence of the standing instruction.
Item 16: Investment Discretion
Our firm manages accounts on a discretionary basis. After you sign an agreement with our firm, we’re
allowed to buy and sell investments in your account without asking you in advance. Any limitations
will be described in the signed advisory agreement. We will have discretion until the advisory
agreement is terminated by you or our firm.
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.
Item 18: Financial Information
Inclusion of a Balance Sheet:
Our firm does not require the prepayment of more than $1,200 in fees when services cannot be
rendered within 6 months.
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Disclosure of Financial Condition:
Our firm has nothing to disclose in this regard.
Bankruptcy Petition:
Our firm has never been the subject of a bankruptcy proceeding.
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