Overview
- Headquarters
- Portland, OR
- Average Client Assets
- $2.9 million
- SEC CRD Number
- 299508
Clients
- HNW Share of Firm Assets
- 84.30%
- Total Client Accounts
- 337
- Discretionary Accounts
- 286
- Non-Discretionary Accounts
- 51
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
Primary Brochure: 03 27 2026 PRW FORM ADV PART 2A AND 2B FINAL (2026-03-27)
View Document Text
Item 1: Cover Page
Pearl Wealth LLC
Form ADV Part 2A
Investment Adviser Brochure
915 NW 19th Ave.
Suite F
Portland, OR 97209
(503) 223-2539
www.pearlwealthllc.com
March 2026
This Brochure provides information about the qualifications and business practices of Pearl
Wealth LLC (“we,” “us,” “our”). If you have any questions about the contents of this Brochure,
please contact Kori L. Allen, Managing Member and Chief Compliance Officer, at (503) 223-2539
or kori@pearlwealthllc.com.
Additional information about our Firm is also available at www.adviserinfo.sec.gov. 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.
We are a registered investment adviser. Please note that use of the term “registered investment
advisor” and a description of the Firm and/or our employees as “registered” does not imply a
certain level of skill or training. For more information on the qualifications of the Firm and our
employees who advise you, we encourage you to review this Brochure and the Brochure
Supplement(s).
Item 2: Summary of Material Changes
In this Item of Pearl Wealth LLC’s (“Pearl” or the “Firm,” “we,” “us,” “ours,”) Form ADV 2, we are
required to discuss any material changes that have been made to Form ADV since the last
Annual Amendment.
Material Changes since the Last Update
Since the filing of our Annual Amendment on March 12, 2025, we have no material changes to
report.
Annual Update
You will receive a summary of any material changes to our Form ADV brochure within 120 days
of our fiscal year end. We may also provide updated disclosure information about material
changes on a more frequent basis. Any summaries of changes will include the date of the last
annual update of the ADV.
The Supplement to our Form ADV Brochure (Form ADV Part 2B) provides you with information
regarding our employees that provide investment advice.
Full Brochure Available
Our Form ADV may be requested at any time, without charge by contacting Kori L. Allen,
Managing Member and Chief Compliance Officer, at (503) 223-2539 or
kori@pearlwealthllc.com. Additional information about the Firm is also available via the SEC’s
website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any
employees affiliated with the Firm who are registered as investment adviser representatives.
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Item 3 Table of Contents
Item 1: Cover Page .......................................................................................................................... 1
Item 2: Summary of Material Changes ........................................................................................... 2
Item 4: Advisory Business ............................................................................................................... 4
Item 5: Fees and Compensation ..................................................................................................... 7
Item 6: Performance-Based Fees and Side-By-Side Management ............................................... 11
Item 7: Types of Clients ................................................................................................................. 12
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 13
Item 9: Disciplinary Information ................................................................................................... 15
Item 10: Other Financial Industry Activities and Affiliations ........................................................ 16
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 17
Item 12: Brokerage Practices ........................................................................................................ 19
Item 13: Review of Accounts ........................................................................................................ 22
Item 14: Client Referrals and Other Compensation ...................................................................... 23
Item 15: Custody ........................................................................................................................... 24
Item 16: Investment Discretion ..................................................................................................... 25
Item 17: Voting Client Securities ................................................................................................... 26
Item 18 Financial Information ....................................................................................................... 27
Form ADV Part 2B – Investment Adviser Brochure Supplement .................................................. 28
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Item 4: Advisory Business
Firm Information
This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications,
business practices, and the advisory services provided by Pearl Wealth LLC’s (“Pearl,” or “the
Firm”, “we”, “us”, “ours”).
We are a federally Registered Investment Adviser with the U.S. Securities and Exchange
Commission (“SEC”). We were founded in 2019 and are owned and operated by Kori L. Allen,
Managing Member and Chief Compliance Officer and Gretchen L. Cole, Director of Client
Service.
We are an integrated registered investment adviser offering investment management services
and financial planning services for individuals and households who care about how their money
is invested. We believe that what clients invest in matters and ultimately has impact on the
world at large, as well as on our friends and communities. Our goal is to generate competitive
market returns with a lesser degree of risk, or volatility over the long term. This is achieved by
thinking globally and long-term, as well as being disciplined in the act of buying and selling
investment securities. The investment program is executed in concert with clients’ unique
situation and goals.
We are strictly a fee-only financial planning and investment management firm. We do not sell
annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned
products. We are not affiliated with entities that sell financial products or securities. No
commissions in any form are accepted. No finder’s fees are accepted.
Types of Advisory Services
Financial Planning
We offer financial planning services, which may include a review of all aspects of a client’s
current financial situation, including the following components: cash management, risk
management, insurance, education funding, goal setting, retirement planning, estate and
charitable giving planning, tax planning, and capital needs planning. Clients understand that
when we are engaged to address only certain components, the client’s overall financial and
investment issues may not be taken into consideration.
We meet with the client to review risk tolerance, financial goals and objectives, and time
horizons. Additional meetings may include a review of additional financial information; sources
of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax
returns, investments, and personal and family obligations.
The financial plan may include both long and short-term considerations, depending upon the
individual scenario. Upon completion a plan is presented to the client and the client is provided
with recommendations that are deemed to be compatible with the client’s stated goals and
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objectives. An implementation schedule is reviewed with the client to determine which steps
will be pursued, and with whom the steps may be accomplished. The client is under no
obligation to utilize the Firm to implement the advice or plan. Clients may choose all or certain
components of advice and recommendations and can implement the recommendations
through the service providers of their choice.
Wealth Management
We provide continuous advice to clients regarding investment of client funds based on the
individual needs of the client. Through personal discussions in which goals and objectives based
on a client’s particular circumstances are established, we develop a client’s personal investment
policy and create and manage a portfolio based on that policy. We will manage advisory
accounts on a discretionary basis only. Account supervision is guided by the stated objectives of
the client (i.e., maximum capital appreciation, growth, income, growth and income, etc.).
We will construct and manage an investment portfolio based on our firm's principles for
investment and investment philosophy and tailored to meet our clients' needs and investment
objectives. We will also incorporate environmental, social and governance factors into
investment decisions, to better manage risk and generate sustainable, long-term returns. We
believe that companies with these characteristics are better equipped to adapt to change and
evolve and have lower probability of unforeseen liabilities.
We will create a portfolio consisting of individual equities, and bonds, as well as exchange
traded funds (ETF’s) or no-load or load-waived mutual funds on a limited basis. We will allocate
the client’s assets among various investments taking into consideration the overall
management style selected by the client. Mutual funds will be selected on the basis of any or all
of the following criteria: the fund’s performance history; the industry sector in which the fund
invests; the track record of the fund’s manager; the fund’s investment objectives; the fund’s
management style and philosophy; and the fund’s management fee structure. Portfolio
weighting between funds and market sectors will be determined by each client’s individual
needs and circumstances.
We may also provide advice about any type of legacy position or investment otherwise held in
client portfolios.
Tailored Relationships
We tailor investment advisory services to the individual needs of the client. Our clients are
allowed to impose restrictions on the investments in their account. All limitations and
restrictions placed on accounts must be presented to us in writing.
Wrap Fee Programs
A “wrap-fee” program is one that provides the client with advisory and brokerage execution
services for an all-inclusive fee. The client is not charged separate fees for the respective
components of the total service. We do not sponsor, manage or participate in a Wrap Fee
Program.
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Fiduciary Statement
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,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing
retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Assets Under Management
As of December 31, 2025, we managed $156,345,488 in client assets; $149,156,021 managed
on a discretionary basis, and $7,189,567 on a non-discretionary basis.
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Item 5: Fees and Compensation
We base our fees on hourly charges and/or a percentage of assets under management, which
are described below.
Compensation – Financial Planning
Financial Planning fees will be charged on an hourly basis of $350 per hour.
All financial planning fees are due in arrears upon presentation of the financial plan.
Compensation – Wealth Management Services
Wealth Management fees are charged an annual fee as follows:
Investment Management
Included Services:
Portfolio Management
Financial Advice and Counseling
Quarterly Email Update and Report
Quarterly Meeting
Financial Planning
X
X
X
X
X
Investment Management Fee Tiers
First, $0 - $2 million
Then, $2 million - $5 million
Then, $5 million - $10 million
Then, $10 million and higher
Flat Rate Fee
Annual Percentage
1.00%, plus
0.75%, plus
0.50%, plus
Negotiable, plus
Negotiable with annual
CPI increase
There is a minimum wealth management fee of $3,500.
Calculation and Payment
The specific manner in which we charge fees is established in a client’s written agreement with
us. Clients may elect to be invoiced directly for fees or to authorize us to directly debit fees
from client accounts.
Accounts initiated during a calendar quarter will be charged a prorated fee. Upon termination
of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid
fees will be due and payable.
In no case will more than $1,200 be collected from the client more than 6 months in advance.
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Other Fees
There are no additional types of fees or expenses that our clients pay in connection with the
delivery of advisory services.
Agreement Terms
Either party may terminate an agreement at any time by notifying the other in writing. If the
client made an advance payment, we would refund any unearned portion of the advance
payment.
If the client made a payment in arrears, we would collect any earned yet unpaid fees.
Cash Balances
Some of your assets may be held as cash and remain uninvested. Holding a portion of your
assets in cash and cash alternatives, i.e., money market fund shares, may be based on your
desire to have an allocation to cash as an asset class, to support a phased market entrance
strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to
pay fees or to provide for asset protection during periods of volatile market conditions. Your
cash and cash equivalents will be subject to our investment advisory fees unless otherwise
agreed upon. You may experience negative performance on the cash portion of your portfolio if
the investment advisory fees charged are higher than the returns you receive from your cash.
Retirement Plan Rollover Recommendations
As part of our investment advisory services to our clients, we may recommend that clients roll
assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account
(collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP
IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the
client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from
Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts.
If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge
the client an asset-based fee as set forth in the advisory agreement the client executed with our
firm. This creates a conflict of interest because it creates a financial incentive for our firm to
recommend the rollover to the client (i.e., receipt of additional fee-based compensation).
Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover,
if clients do complete the rollover, clients are under no obligation to have the assets in an IRA
advised on by our firm. Due to the foregoing conflict of interest, when we make rollover
recommendations, we operate under a special rule that requires us to act in our clients’ best
interests and not put our interests ahead of our clients.’
Under this special rule’s provisions, we must:
• meet a professional standard of care when making investment recommendations (give
prudent advice);
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• never put our financial interests ahead of our clients’ when making recommendations
(give loyal advice);
• avoid misleading statements about conflicts of interest, fees, and investments;
•
follow policies and procedures designed to ensure that we give advice that is in our
clients’ best interests;
• charge no more than a reasonable fee for our services; and
• give clients basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company
plan. Also, current employees can sometimes move assets out of their company plan before
they retire or change jobs. In determining whether to complete the rollover to an IRA, and to
the extent the following options are available, clients should consider the costs and benefits of
a rollover. Note that an employee will typically have four options in this situation:
1. leaving the funds in the employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance
of understanding the differences between these types of accounts, we will provide clients with
a written explanation of the advantages and disadvantages of both account types and
document the basis for our belief that the rollover transaction we recommend is in your best
interests.
General Information on Compensation and Other Fees
In certain circumstances, fees, account minimums and payment terms are negotiable
depending on client’s unique situation – such as the size of the aggregate related party
portfolio size, family holdings, low-cost basis securities, or certain passively advised investments
and pre-existing relationships with clients. Certain clients may pay more or less than others
depending on the amount of assets, type of portfolio, or the time involved, the degree of
responsibility assumed, complexity of the engagement, special skills needed to solve problems,
the application of experience and knowledge of the client’s situation.
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses which shall be incurred by the client. Clients may incur certain charges imposed by
custodians, brokers, third party investment and other third parties such as fees charged by
managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire
transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions. Mutual funds and exchange traded funds also charge internal
management fees, which are disclosed in a fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to our fees, and we shall
not receive any portion of these commissions, fees, and costs.
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All fees paid to us for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds to their shareholders. These fees and expenses are
described in each fund’s prospectus. These fees will generally include a management fee, other
expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may
pay an initial or deferred sales charge.
A client could invest in a mutual fund directly, without our services. In that case, the client
would not receive our services, which are designed, among other things, to assist the client in
determining which mutual funds are most appropriate to each client’s financial condition and
objectives. Accordingly, the client should review both the fees charged by the funds and the
fees charged by us to fully understand the total amount of fees to be paid by the client and to
thereby evaluate the advisory services being provided.
Clients should note that similar advisory services may (or may not) be available from other
registered investment advisers for similar or lower fees.
Mutual Fund Share Class Selection
Similar investment management services may (or may not) be available from other investment
advisers for a lower fee. Investment management fees, which include investment management
and transaction costs, may be more or less costly than paying for the services separately,
depending upon the investment advisory fees charged, the number of transactions for the
account, the mutual fund share class you purchase and the underlying 12(b)-1 fee, and the level
of brokerage and other fees that would be payable if you obtained the services available
individually.
We may engage independent third-party advisors to provide additional investment
management services to us. Any fees incurred by such subadvisor will be paid directly by us and
not by the client.
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Item 6: Performance-Based Fees and Side-By-Side Management
“Performance-based fees” are fees based on the capital gains or capital appreciation in an
account. We do not charge performance-based fees. “Side-by-side management” refers to the
practice of managing both accounts that are charged a performance-based fee and accounts
that are charged other types of fees, such as asset-based fees and hourly fees. Because we do
not charge performance-based fees, we do not engage in side-by-side management.
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Item 7: Types of Clients
We provide services to individuals, high net worth individuals and charitable organizations.
We do not have a minimum account size.
We charge a minimum annual fee of $3,500 to open and maintain an advisory account. At our
discretion we may waive or negotiate a minimum fee.
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Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
We contract with former partner, Anthony (Tony) Tursich of Calamos Investments. Tony serves
as Pearl Wealth’s Chief Investment Officer and his team provides guidance, research and
investment selection and direction. There are no additional fees passed onto clients for this
service.
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or
managing client assets:
Fundamental Analysis, which attempts to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company itself) to determine if the company is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time
to sell).
Fundamental analysis does not attempt to anticipate market movements. 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.
Investment Strategies
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined
objectives, risk tolerance, time horizon, financial information, liquidity needs and other various
suitability factors. Your restrictions and guidelines may affect the composition of your portfolio.
It is important that you notify us immediately with respect to any material changes to your
financial circumstances, including for example, a change in your current or expected income
level, tax circumstances, or employment status.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends and other distributions), and the loss of
future earnings. Although we manage assets in a manner consistent with your investment
objectives and risk tolerance, there can be no guarantee that our efforts will be successful.
You should be prepared to bear the following risks of loss:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
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• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
•
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
political, economic and social conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar next year will not buy as
much as a dollar today, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also referred
to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily
relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding oil
and then refining it, a lengthy process, before they can generate a profit. They carry a
higher risk of profitability than an electric company, which generates its income from a
steady stream of customers who buy electricity no matter what the economic
environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties (i.e.,
Non-traded REITs and other alternative investments) are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations
may result in bankruptcy and/or a declining market value.
• Cybersecurity Risk: A breach in cyber security refers to both intentional and
unintentional events that may cause an account to lose proprietary information, suffer
data corruption, or lose operational capacity. This in turn could cause an account to
incur regulatory penalties, reputational damage, and additional compliance costs
associated with corrective measures, and/or financial loss.
• 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.
• Custodial Risk: This risk is the probability that a party to a transaction will be unable or
unwilling to fulfill its contractual obligations either due to technological errors, control
failures, malfeasance, or potential regulatory liabilities.
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Item 9: Disciplinary Information
We are required to disclose all pertinent facts regarding any legal, regulatory or disciplinary
events that would be material to your evaluation of the Firm or the integrity of our
management.
There have never been any legal, regulatory or disciplinary actions against the Firm or our
management persons.
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Item 10: Other Financial Industry Activities and Affiliations
We are required to disclose to our clients any relationship or arrangement with certain related
persons that is material to our advisory business.
Financial Industry Activities
We are not registered as a broker-dealer, and none of our management persons are registered
representatives of a broker-dealer.
Neither we, nor any of our management persons, is registered as (or associated with) a futures
commissions merchant, commodity pool operator, or a commodity trading advisor.
Neither we nor any of our management persons have a material relationship or arrangement
with any related person or financial industry entities.
Other Investment Advisors
We may recommend other investment advisors for our clients. We are not compensated for
these recommendations.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics
Our employees must comply with a Code of Ethics and Statement for Insider Trading (the
“Code”). The Code describes our high standard of business conduct, and fiduciary duty to our
clients. The Code’s key provisions include:
• Statement of General Principles
• Policy on and reporting of Personal Securities Transactions
• A prohibition on Insider Trading
• Restrictions on the acceptance of significant gifts
• Procedures to detect and deter misconduct and violations
• Requirement to maintain confidentiality of client information
Our employees must acknowledge the terms of the Code at least annually, and any employee
not in compliance with the Code may be subject to termination. We will provide a copy of our
Code upon request.
Participation or Interest in Client Transactions – Personal Securities Transactions
Both the Firm and our employees may buy or sell securities identical to those recommended to
clients for their personal accounts. The Code, described above, is designed to assure that the
personal securities transactions, activities and interests of the employees of the Firm will not
interfere with (i) making decisions in the best interest of clients and (ii) implementing such
decisions while, at the same time, allowing employees to invest for their own accounts. Under
the Code certain classes of securities, primarily mutual funds, have been designated as exempt
transactions, based upon a determination that these would materially not interfere with the
best interest of our clients. In addition, the Code requires pre-clearance of many transactions.
Nonetheless, because the Code in some circumstances would permit employees to invest in the
same securities as clients, there is a possibility that employees might benefit from market
activity by a client in a security held by an employee. The Firm may maintain a list of restricted
securities that employees may not purchase or sell based upon having (or possibly having)
access to inside information. Employee trading is continually monitored under the Code and
designed to reasonably prevent conflicts of interest between the Firm and our clients.
Participation or Interest in Client Transactions and Principal/Agency Cross Trades
We do not recommend any securities to our clients in which we have a material financial
interest. We do not affect any principal or agency cross securities transactions for client
accounts. We also do not cross trades between client accounts.
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Participation or Interest in Client Transactions – Aggregation
We and our employees may trade in the same securities with client accounts on an aggregated
basis when consistent with our obligation of best execution. In such circumstances, the
affiliated and client accounts will share commission costs equally and receive securities at a
total average price. We will retain records of the trade order (specifying each participating
account) and its allocation, which will be completed prior to the entry of the aggregated order.
Completed orders will be allocated as specified in the initial trade order. Partially filled orders
will be allocated on a pro rata basis. Any exceptions will be explained on the order.
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Item 12: Brokerage Practices
Research and Other Soft Dollar Benefits
We have no written or verbal arrangements whereby we receive soft dollars.
Brokerage for Client Referrals
We do not receive client referrals from broker/dealers.
Client Directed Brokerage
While not routine, the client may direct us to use a particular broker-dealer to execute some or
all transactions for the client. This brokerage direction must be requested by the client in
writing. In that case, the client will negotiate terms and arrangements for the account with that
broker-dealer, and we will not seek better execution services or prices from other broker-
dealers or be able to “batch” client transactions for execution through other broker-dealers
with orders for other accounts managed by us. By directing brokerage, the client may pay
higher commissions or other transaction costs or greater spreads, or receive less favorable net
prices, on transactions for the account than would otherwise be the case. Not all advisers
require or allow their clients to direct brokerage. Subject to our duty of best execution, we may
decline a client’s request to direct brokerage if, in our sole discretion, such directed brokerage
arrangements would result in additional operational difficulties.
Directed Brokerage (Schwab)
We generally recommend Schwab Institutional (“Schwab”), a member FINRA/SIPC, an
independent and unaffiliated broker-dealer. Schwab provides us with access to its institutional
trading and custody services, which are typically not available to Schwab retail investors. These
services generally are available to independent investment advisors on an unsolicited basis and
are not otherwise contingent upon our commitment to Schwab for any specific amount of
business (assets in custody or trading). Schwab’s services include the execution of securities
transactions, custody, research, and access to mutual funds and other investments that are
otherwise generally available only to institutional investors or would require a significantly
higher minimum initial investment.
For our client accounts maintained there, Schwab is compensated through commissions or
other transaction-related fees for securities trades that are executed through Schwab or that
settle into Schwab accounts. The brokerage commissions and/or transaction fees charged by
Schwab, or any other designated broker-dealer, are exclusive of and in addition to our fees.
Directed Brokerage – Other Economic Benefits (Schwab)
We may receive from Schwab, at no cost to us, professional services, computer software and
related systems support, enabling us to better monitor client accounts maintained at Schwab.
We may receive this support without cost because of the portfolio management services
rendered to clients that maintain assets at Schwab. The support provided may benefit us, but
not our clients directly. In fulfilling our duties to our clients, we endeavor at all times to put the
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interests of our clients first. Clients should be aware, however, that our receipt of economic
benefits from a broker-dealer may create a conflict of interest since these benefits may
influence our choice of broker-dealer over another broker-dealer that does not furnish similar
services, software and systems support.
The commissions paid by our clients shall comply with our duty to obtain “best execution.”
However, a client may pay a commission that is higher than another qualified broker-dealer
might charge to effect the same transaction where we determine, in good faith, that the
commission is reasonable in relation to the value of the brokerage and research services
received. 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 among others, the value of research provided,
execution capability, commission rates, and responsiveness. Consistent with the foregoing,
while we will seek competitive rates, we may not necessarily obtain the lowest possible
commission rates for client transactions.
Schwab also makes available to us other products and services that benefit us but may not
directly benefit our clients’ accounts. Many of these products and services may be used to
service all or some substantial number of our accounts, including accounts not maintained at
Schwab.
Schwab’s products and 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 our fees from our clients’ accounts; and (v) assist with
back-office functions, recordkeeping and client reporting.
Trade Aggregation
We may aggregate trades for multiple accounts. Trade aggregation is the act of trading a large
block of a security in a single order. Shares of a purchased security are then allocated to the
appropriate accounts in the appropriate proportion. The main purposes of order aggregation
are (i) for ease of trading and (ii) to obtain a lower transaction cost associated with trading a
larger quantity.
Orders for the same security entered on behalf of more than one client may be aggregated (i.e.,
blocked or bunched) subject to the aggregation being in the best interests of all participating
clients. If the order is filled at different prices during the day, the prices are averaged for the day
so that all participating accounts receive the same price. If an order has not been filled
completely so that there are not enough shares to allocate among all the clients equally, shares
will be allocated in good faith, based on the following considerations: amount of cash in the
account, existing asset allocation and industry exposure, risk profile, and type of security. If a
partial execution is attained at the end of the trading day, we will generally allocate shares on a
pro rata basis but may fill small orders entirely before applying the pro rata allocation. All clients
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participating in each aggregated order shall receive the average price and subject to minimum
ticket charges, pay a pro-rata portion of commissions.
Our allocation procedure seeks to be fair and equitable to all clients with no particular group or
client(s) being favored or disfavored over any other clients.
Accounts for us or our employees may be included in a block trade with client accounts.
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Item 13: Review of Accounts
Reviews
We monitor client portfolios as part of an ongoing process, and regular account reviews are
generally conducted on a quarterly basis. Reviews could also occur at the time of new deposits,
material changes in the client’s financial information, changes in economic cycles, at our
discretion or as often as the client directs. Reviews entail analyzing securities, sensitivity to
overall markets, economic changes, investment results, asset allocation, etc., to ensure the
investment strategy and expectations are structured to continue to meet the client’s objectives.
These reviews are conducted by one of our Investment Advisor Representatives.
Clients are encouraged to discuss their needs, goals, and objectives with us and to inform us of
any changes.
Reporting
At least quarterly, the custodian provides clients with an account statement for each client
account, which may include individual holdings, cost basis information, deposits and
withdrawals, accrued income, dividends, and performance. We may also provide clients with
periodic reports regarding their holdings, allocations, and performance.
Financial Planning – Reviews and Reporting
The initial financial plan is included as a component of the financial planning service. Clients
may receive updated financial plans for a separate fee.
22
Item 14: Client Referrals and Other Compensation
Other Compensation – Brokerage Arrangements
See disclosure in Item 12 regarding compensation, including economic benefits received in
connection with giving advice to clients.
Compensation – Client Referrals
We have been fortunate to receive many client referrals over the years. The referrals came
from current clients, estate planning attorneys, accountants, employees, personal friends of
employees and other similar sources. We do not compensate referring parties for these
referrals.
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Item 15: Custody
Custody – Fee Debiting
Clients may authorize us (in the client agreement) to debit fees directly from their account at
the broker dealer, bank or other qualified custodian (“custodian”). The custodian is advised in
writing of the limitation of our access to the account. The custodian sends a statement to the
client, at least quarterly, indicating all amounts disbursed from the account including the
amount of advisory fees paid directly to the Firm.
Custody – Account Statements
Clients receive at least quarterly statements from the custodian that holds and maintains
client’s investment assets. Clients are urged to carefully review such statements and compare
such official custodial records to the reports that we provide. Our reports may vary from
custodial statements based on accounting procedures, reporting dates, or valuation
methodologies of certain securities.
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Item 16: Investment Discretion
We may accept limited power of attorney to act on a discretionary basis on behalf of clients. A
limited power of attorney allows us to execute trades on behalf of clients. When such limited
powers exist between the Firm and the client, we have the authority to determine, without
obtaining specific client consent, both the amount and type of securities to be bought to satisfy
client account objectives.
In limited circumstances, where we have not been given discretionary authority, we consult
with the client prior to each trade.
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Item 17: Voting Client Securities
We vote proxies for securities over which we maintain discretionary authority. Our utmost
concern is that all decisions be made solely in the client's best interest. We will act in a prudent
and diligent manner intended to enhance the economic value of the assets of the client’s
portfolio. Although many proxy proposals can be voted on in accordance with our established
guidelines, we recognize that some proposals require special consideration, which may dictate
that we make an exception to the guidelines. Clients may direct our vote; however, direction
must be received in writing. Clients may contact us for information about proxy voting.
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Item 18 Financial Information
We have no financial commitments that impair our ability to meet contractual and fiduciary
commitments to clients and we have not been the subject of a bankruptcy proceeding.
We do not require prepayment of fees of both more than $1,200 per client, and more than six
months in advance; and therefore, we are not required to provide a balance sheet to clients.
We have not ever filed a bankruptcy petition.
27
Form ADV Part 2B – Investment Adviser Brochure Supplement
Pearl Wealth LLC
Form ADV Part 2B
Investment Adviser Brochure Supplement
915 NW 19th Ave.
Suite F
Portland, OR 97209
(503) 223-2539
www.pearlwealthllc.com
Kori L. Allen
March 2026
This Brochure Supplement provides information about Kori L. Allen that supplements the Pearl
Wealth LLC brochure. You should have received a copy of that Brochure. Please contact Kori L.
Allen, Managing Member and Chief Compliance Officer, at (503) 223-2539 or
kori@pearlwealthllc.com if you have any questions about the contents of this Supplement.
Additional information about Kori L. Allen (CRD # 1845744) is available on the SEC's website at
www.adviserinfo.sec.gov.
28
Item 2: Educational Background and Business Experience
We require that employees that provide investment advice have a bachelor's degree and
further coursework demonstrating knowledge of financial planning. Examples of acceptable
coursework include: an MBA, a CFP®, a CFA, a ChFC, JD, CTFA, EA or CPA. Additionally, advisers
must have work experience that demonstrates their aptitude for financial planning and
investment management.
Born 1961
Kori L. Allen
CRD #: 1845744
2019 to Present
Business Background:
Pearl Wealth LLC
Managing Member, Chief Compliance Officer
and Investment Adviser Representative
2009 to 2018
Pine Haven Investment Counsel
Partner, Chief Compliance Officer
and Investment Adviser Representative
Formal Education After High School:
Portland State University
Bachelor of Arts in Political Science
Willamette University
General
Portland State University
Certificate Central European Studies
University of Portland
Executive Certificate Financial Planning
Professional Designations:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Professional Certifications
Kori L. Allen maintains a professional designation, which requires the following minimum
requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
29
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
•
•
•
•
•
•
•
CPA
ChFC
Chartered Life Underwriter (CLU)
CFA
Ph.D. in business or economics
Doctor of Business Administration
Attorney's License
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Item 3: Disciplinary Information
Kori L. Allen has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Kori L. Allen serves as a trustee and board chair for The Library Foundation. Additionally, she is a
board member for The Nick Wilson Charitable Group. See response to Form ADV Part 2A Item
10 – Other Financial Industry Activities and Affiliations (You may also check Item 13 – Other
Activities of the Forms U4).
Item 5: Additional Compensation
Kori L. Allen does not receive any economic benefits outside of regular salaries and bonuses.
Item 6: Supervision
In the supervision of our associated persons, advice provided is limited based on the restrictions
set by Pearl Wealth LLC, and by internal decisions as to the types of investments that may be
included in client portfolios. We conduct periodic reviews of client holdings and documented
suitability information to provide reasonable assurance that the advice provided remains
aligned with each client's stated investment objectives and with our internal guidelines.
30
Kori L. Allen serves as Managing Member and Chief Compliance Officer of the Firm, while
Gretchen L. Cole, Director of Client Service provides oversight to Kori L. Allen. Both can be
reached at (503) 223-2539.
31
Form ADV Part 2B – Investment Adviser Brochure Supplement
Pearl Wealth LLC
Form ADV Part 2B
Investment Adviser Brochure Supplement
915 NW 19th Ave.
Suite F
Portland, OR 97209
(503) 223-2539
www.pearlwealthllc.com
Gretchen L. Cole
March 2026
This Brochure Supplement provides information about Gretchen L. Cole that supplements the
Pearl Wealth LLC brochure. You should have received a copy of that Brochure. Please contact
Kori L. Allen, Managing Member and Chief Compliance Officer, at (503) 223-2539 or
kori@pearlwealthllc.com if you have any questions about the contents of this Supplement.
Additional information about Gretchen L. Cole (CRD # 4194331) is available on the SEC's website
at www.adviserinfo.sec.gov
32
Item 2: Educational Background and Business Experience
We require that employees that provide investment advice have a bachelor's degree and
further coursework demonstrating knowledge of financial planning and tax planning. Examples
of acceptable coursework include: an MBA, a CFP®, a CFA, a ChFC, JD, CTFA, EA or CPA.
Additionally, advisers must have work experience that demonstrates their aptitude for financial
planning and investment management.
Born 1977
Gretchen L. Cole
CRD #: 4194331
2019 to Present
Business Background:
Pearl Wealth LLC
Director of Client Service
and Investment Adviser Representative
2014 to 2019
Pine Haven Investment Counsel
Investment Adviser Representative
Formal Education After High School:
University of Puget Sound
Bachelor of Arts in Business
Item 3: Disciplinary Information
Gretchen L. Cole has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Gretchen L. Cole is on the Finance Committee for Community Warehouse. See response to
Form ADV Part 2A Item 10 – Other Financial Industry Activities and Affiliations (You may also
check Item 13 – Other Activities of the Forms U4).
Item 5: Additional Compensation
Gretchen L. Cole does not receive any economic benefit outside of regular salaries and bonuses.
33
Item 6: Supervision
In the supervision of our associated persons, advice provided is limited based on the restrictions
set by Pearl Wealth LLC, and by internal decisions as to the types of investments that may be
included in client portfolios. We conduct periodic reviews of client holdings and documented
suitability information to provide reasonable assurance that the advice provided remains
aligned with each client's stated investment objectives and with our internal guidelines.
Kori L. Allen serves as Managing Member and Chief Compliance Officer of the Firm, while
Gretchen L. Cole, Director of Client Service provides oversight to Kori L. Allen. Both can be
reached at (503) 223-2539.
34