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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
February 17, 2026
26050 Mureau Road, Suite 103
Calabasas, CA 91302
www.privatewealthsolutions.com
Firm Contact: Douglas J.
Lagerstrom
Chief Compliance Officer
information about our
This brochure provides information about the qualifications and business practices of Private Wealth
Solutions, LLC. If clients have any questions about the contents of this brochure, please contact us at
(818)-264-0600 or doug@privatewealthsolutions.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
firm is also available on the SEC’s website at
www.adviserinfo.sec.gov by searching CRD #289437.
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
Private Wealth Solutions, LLC is required to make clients aware of information that has changed since the
last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can
then determine whether to review the brochure in its entirety or to contact us with questions about the
changes.
Since our last annual amendment filed on 02/14/2025, there have been no material changes to disclose.
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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......................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss................................................................8
Item 9: Disciplinary Information.................................................................................................................. 15
Item 10: Other Financial Industry Activities & Affiliations............................................................................15
Item 11: Code of Ethics, Participation or Interest in.....................................................................................16
Client Transactions & Personal Trading ....................................................................................................... 16
Item 12: Brokerage Practices.......................................................................................................................17
Item 13: Review of Accounts or Financial Plans........................................................................................... 19
Item 14: Client Referrals & Other Compensation.........................................................................................20
Item 15: Custody......................................................................................................................................... 20
Item 16: Investment Discretion................................................................................................................... 21
Item 17: Voting Client Securities..................................................................................................................21
Item 18: Financial Information .................................................................................................................... 22
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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 California
in 2013 and has been in business as an investment adviser since 2017. Our firm is owned by Douglas
Lagerstrom and Allen Minassian.
Our firm provides asset management and investment consulting services for many different types of
clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As
a fiduciary it is our duty to always act in the client’s best interest. This is accomplished in part by knowing
the client. Our
firm has established a service-oriented advisory practice with open lines of
communication. Working with clients to understand their investment objectives while educating them
about our process, facilitates the kind of working relationship we value.
Types of Advisory Services Offered
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), mutual funds and other public and private securities or investments. The
client’s individual investment strategy is tailored to their specific needs and may include some or all of the
previously mentioned securities. Portfolios will be designed to meet a particular investment goal,
determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based
upon the client’s individual needs, stated goals and objectives.
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 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. Our firm provides clients with a summary
of their financial situation, and observations for financial planning engagements. Financial consultations
are not typically accompanied by a written summary of observations and recommendations, as the
process is less formal than the planning service. Assuming that all the information and documents
requested from the client are provided promptly, plans or consultations are typically completed within 6
months of the client signing a contract with our firm.
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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 establishing, monitoring
and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor
dictate, areas of advising could include: investment options, plan structure and participant education.
Retirement Plan Consulting services typically include:
Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad strategies
to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment
options and make recommendations for appropriate changes.
Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and notify
the client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services with
respect to the following types of assets: employer securities, real estate (excluding real estate funds and
publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid
investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan
consulting services shall be in compliance with the applicable state laws regulating retirement consulting
services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”)
governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client
accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our
firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as
designated by the Retirement Plan Consulting Agreement with respect to the provision of services
described therein.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management clients. Our firm offers
general investment advice to our Financial Planning & Consulting and Retirement Plan Consulting clients.
Each Asset Management client has the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio. Restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer a wrap fee program.
Regulatory Assets Under Management
Our firm manages $500,000,000 on a non-discretionary basis as of December 31, 2025.
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Item 5: Fees & Compensation
Compensation for Our Advisory Services Asset
Management:
The maximum annual fee charged for this service will not exceed 1.50%. 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 value of the account(s) on the last day of the previous month.
Fees are negotiable and will be deducted from client account(s). Adjustments will be made for deposits
and withdrawals during the month in excess of $100,000. In rare cases, our firm will agree to directly
invoice. As part of this process, Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm
c)
will send an invoice directly to the custodian; and
If our firm sends a copy of our invoice to the client, legend urging the comparison of information
provided in our statement with those from the qualified custodian will be included.
Financial Planning & Consulting:
Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. The maximum hourly fee to be charged will not exceed $500. Flat fees will
not exceed $5,000. Our firm requires a retainer of 50% of the ultimate financial planning or consulting
fee at the time of signing. The remainder of the fee will be directly billed to the client and due within 30
days of a financial plan being delivered or consultation rendered. Our firm will not require a retainer
exceeding $1,200 when services cannot be rendered within 6 months.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on the percentage of Plan assets under management.
The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. Fees based on a percentage of managed Plan assets will not exceed 1.00%.
The fee-paying arrangements for Retirement Plan Consulting service will be determined on a case-by-
case basis and will be detailed in the signed consulting agreement.
Other Types of Fees & Expenses
Clients will incur transaction charges for trades executed by their chosen custodian. These transaction
fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles
Schwab (“Schwab”), does not charge transaction fees for U.S. listed equities and exchange traded funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges
imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
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disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual
fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan
fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees for
trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts
and securities transactions. Our firm does not receive a portion of these fees.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Asset Management services
in writing at any time. Upon termination, we will refund the unearned portion of any advisory fees paid
in advance, calculated on a pro-rata basis through the effective termination date..
Financial Planning & Consulting clients may terminate their agreement at any time before the delivery of
a financial plan by providing written notice. For purposes of calculating refunds, all work performed by us
up to the point of termination shall be calculated at the hourly fee currently in effect. Clients will receive a
pro-rata refund of unearned fees based on the time and effort expended by our firm.
Either party 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 within 5
business days of signing an agreement. After 5 business days from initial signing, either party must
provide the other party 30 days written notice to terminate billing. Billing will terminate 30 days after
receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work
completed by our firm on behalf of the client. Clients will incur charges for bona fide advisory services
rendered up to the point of termination (determined as 30 days from receipt of said written notice) and
such fees will be due and payable.
Commissionable Securities Sales
Representatives of our firm are registered representatives of Kovack Securities, Inc. (“KSI”), member
FINRA/SIPC. As such they are able to accept compensation for the sale of securities or other investment
products, including distribution or service (“trail”) fees from the sale of mutual funds. Clients should be
aware that the practice of accepting commissions for the sale of securities presents a conflict of interest
and gives our firm and/or our representatives an incentive to recommend investment products based on
the compensation received. Our firm generally addresses commissionable sales conflicts that arise when
explaining to clients these sales create an incentive to recommend based on the compensation to be
earned and/or when recommending commissionable mutual funds, explaining that “no-load” funds are
also available. Our firm does not prohibit clients from purchasing recommended investment products
through other unaffiliated brokers or agents.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
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Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
Individuals and High Net Worth Individuals;
Trusts, Estates or Charitable Organizations;
Pension and Profit Sharing Plans;
Corporations, Limited Liability Companies and/or Other Business Types
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging us.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing client
assets:
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 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.
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
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of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions. Technical
analysts also widely use market
indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other inputs.
These indicators are used to help assess whether an asset is trending, and if it is, the probability of its
direction and of continuation. Technicians also look for relationships between price/volume indices and
market indicators. Technical analysis employs models and trading rules based on price and volume
transformations, such as the relative strength index, moving averages, regressions, inter-market and
intra-market price correlations, business cycles, stock market cycles or, classically, through recognition of
chart patterns. Technical analysis is widely used among traders and financial professionals and is very
often used by active day traders, market makers and pit traders. The risk associated with this type of
analysis is that analysts use subjective judgment to decide which pattern(s) a particular instrument
reflects at a given time and what the interpretation of that pattern should be.
Investment Strategies We Use
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:
Alternative Investments: Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”),
Business Development Companies (“BDCs”), and other alternative investments involve a high degree of
risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They can be
highly leveraged, speculative and volatile, and an investor could lose all or a substantial amount of an
investment. Alternative investments may lack transparency as to share price, valuation and portfolio
holdings. Complex tax structures often result in delayed tax reporting. Compared to mutual funds, hedge
funds and commodity pools are subject to less regulation and often charge higher fees. Alternative
investment managers typically exercise broad investment discretion and may apply similar strategies
across multiple investment vehicles, resulting in less diversification.
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
large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign
or more of the preceding];
[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
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life settlements, catastrophe bonds, personal
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
life insurance products, etc.);
products (annuity,
derivatives such as long-short or market neutral strategies, options, collateralized debt, and futures;
foreign currency; venture capital; private equity; and/or distressed securities.
Debt Securities (Bonds): Issuers use debt securities to borrow money. Generally, issuers pay investors
periodic interest and repay the amount borrowed either periodically during the life of the security
and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero coupon
bonds, which do not pay current interest, but rather are priced at a discount from their face values and
their values accrete over time to face value at maturity. The market prices of debt securities fluctuate
depending on such factors as interest rates, credit quality, and maturity. In general, market prices of
debt securities decline when interest rates rise and increase when interest rates fall. Bonds with longer
rates of maturity tend to have greater interest rate risks.
Certain additional risk factors relating to debt securities include: (a) When interest rates are declining,
investors have to reinvest their interest income and any return of principal, whether scheduled or
unscheduled, at lower prevailing rates.; (b) Inflation causes tomorrow’s dollar to be worth less than
today’s; in other words, it reduces the purchasing power of a bond investor’s future interest payments
and principal, collectively known as “cash flows.” Inflation also leads to higher interest rates, which in
turn leads to lower bond prices.; (c) Debt securities may be sensitive to economic changes, political and
corporate developments, and interest rate changes. Investors can also expect periods of economic
change and uncertainty, which can result in increased volatility of market prices and yields of certain
debt securities. 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. (d) Debt
securities may contain redemption or call provisions entitling their issuers to redeem them at a specified
price on a date prior to maturity. If an issuer exercises these provisions in a lower interest rate market,
the account would have to replace the security with a lower yielding security, resulting in decreased
income to investors. Usually, a bond is called at or close to par value. This subjects investors that paid a
premium for their bond risk of lost principal. In reality, prices of callable bonds are unlikely to move
much above the call price if lower interest rates make the bond likely to be called.; (e) If the issuer of a
debt security defaults on its obligations to pay interest or principal or is the subject of bankruptcy
proceedings, the account may incur losses or expenses in seeking recovery of amounts owed to it.; (f)
There may be little trading in the secondary market for particular debt securities, which may affect
adversely the account's ability to value accurately or dispose of such debt securities. Adverse publicity
and investor perceptions, whether or not based on fundamental analysis, may decrease the value
and/or liquidity of debt securities.
Our firm attempts to reduce the risks described above through diversification of the client’s portfolio and
by credit analysis of each issuer, as well as by monitoring broad economic trends and corporate and
legislative developments, but there can be no assurance that our firm will be successful in doing so.
Credit ratings for debt securities provided by rating agencies reflect an evaluation of the safety of
principal and interest payments, not market value risk. The rating of an issuer is a rating agency's view of
past and future potential developments related to the issuer and may not necessarily reflect actual
outcomes. There can be a lag between the time of developments relating to an issuer and the time a
rating is assigned and updated.
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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
make a decision to sell.
Margin Transactions: Our firm may purchase securities for your portfolio with money borrowed from
your brokerage account. This allows you to purchase more stock than you would be able to with your
available cash and allows us to purchase securities without selling other holdings. Margin accounts and
transactions are risky and not necessarily appropriate for every client. It should be noted that our firm
bills advisory fees on securities purchased on margin which creates a financial incentive for us to utilize
margin in client accounts.
Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis: Analysis of the experience and track
record of the manager of the mutual fund or ETF in an attempt to determine if that manager has
demonstrated an ability to invest over a period of time and in different economic conditions. The
underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is
significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The
funds or ETFs are monitored in an attempt to determine if they are continuing to follow their stated
investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may not be able to
replicate that success in the future. In addition, as our firm does not control the underlying investments
in a fund or ETF, managers of different funds held by the Client may purchase the same security,
increasing the risk to the Client if that security were to fall in value. There is also a risk that
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a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could
make the holding(s) less suitable for the Client’s portfolio.
Modern Portfolio Theory (“MPT”): A mathematical framework for assembling a portfolio of assets such
that the expected return is maximized for a given level of risk, defined as variance. Its key insight is that an
asset's risk and return should not be assessed by itself, but by how it contributes to a portfolio's overall
risk and return. MPT assumes that investors are risk averse, meaning that given two portfolios that offer
the same expected return, investors will prefer the less risky one. Thus, an investor will take on
increased risk only if compensated by higher expected returns. Conversely, an investor who wants
higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but
different investors will evaluate the trade-off differently based on individual risk aversion characteristics.
The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a
more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists
that has better expected returns.
The risk, return, and correlation measures used by MPT are based on expected values, which means that
they are mathematical statements about the future (the expected value of returns is explicit in the
above equations, and implicit in the definitions of variance and covariance). In practice, investors must
substitute predictions based on historical measurements of asset return and volatility for these values in
the equations. Very often such expected values fail to take account of new circumstances that did not
exist when the historical data were generated. Mathematical risk measurements are also useful only to
the degree that they reflect investors' true concerns—there is no point minimizing a variable that
nobody cares about in practice. MPT uses the mathematical concept of variance to quantify risk, and this
might be justified under the assumption of elliptically distributed returns such as normally distributed
returns, but for general return distributions other risk measures (like coherent risk measures) might
better reflect investors' true preferences.
Real Estate Investment Trusts (“REITs”): REITs primarily invest in real estate or real estate- related
loans. Equity REITs own real estate properties, while mortgage REITs hold construction, development
and/or long-term mortgage loans. Changes in the value of the underlying property of the trusts, the
creditworthiness of the issuer, property taxes, interest rates, tax laws, and regulatory requirements,
such as those relating to the environment all can affect the values of REITs. Both types of REITs are
dependent upon management skill, the cash flows generated by their holdings, the real estate market in
general, and the possibility of failing to qualify for any applicable pass-through tax treatment or failing to
maintain any applicable exemptive status afforded under relevant laws.
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, are appropriately diversified in investments, and ask any
questions.
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.
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
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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.
Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a
borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit risk.
Currency Risk: Fluctuations in the value of the currency in which your investment is denominated may
affect the value of your investment and thus, your investment may be worth more or less in the future.
All currency is subject to swings in valuation and thus, regardless of the currency denomination of any
particular investment you own, currency risk is a realistic risk measure. That said, currency risk is
generally a much larger factor for investment instruments denominated in currencies other than the
most widely used currencies (U.S. dollar, British pound, German mark, Euro, Japanese yen, French franc,
etc.).
Economic Risk: The prevailing economic environment is important to the health of all businesses. Some
companies, however, are more sensitive to changes in the domestic or global economy than others.
These types of companies are often referred to as cyclical businesses. Countries in which a large portion
of businesses are in cyclical industries are thus also very economically sensitive and carry a higher
amount of economic risk. If an investment is issued by a party located in a country that experiences wide
swings from an economic standpoint or in situations where certain elements of an investment
instrument are hinged on dealings in such countries, the investment instrument will generally be subject
to a higher level of economic risk.
ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional expenses
based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential
duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of
owning the underlying securities the ETF or mutual fund holds. Clients will also incur brokerage costs
when purchasing ETFs
Financial Risk: Financial risk is represented by internal disruptions within an investment or the issuer of
an investment that can lead to unfavorable performance of the investment. Examples of financial risk
can be found in cases like Enron or many of the dot com companies that were caught up in a period of
extraordinary market valuations that were not based on solid financial footings of the companies.
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.
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Private Wealth Solutions, LLC
Growth Securities Risk: Securities of companies perceived to be “growth” companies may be more
volatile than other stocks and may involve special risks. The price of a “growth” security may be
impacted if the company does not realize its anticipated potential or if there is a shift in the market to
favor other types of securities.
Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds from
your investment will not be worth what they are today. Throughout time, the prices of resources and end-
user products generally increase and thus, the same general goods and products today will likely be
more expensive in the future. The longer an investment is held, the greater the chance that the
proceeds from that investment will be worth less in the future than what they are today. Said another
way, a dollar tomorrow will likely get you less than what it can today.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to the
investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a
particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the
value of the interest-paying investment(s) they hold. In general, changes in prevailing interest rates in
the market will have an inverse relationship to the value of existing, interest paying investments. In other
words, as interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of
interest will go down. The reverse is generally true as well.
Legal/Regulatory Risk: Certain investments or the issuers of investments may be affected by changes in
state or federal laws or in the prevailing regulatory framework under which the investment instrument
or its issuer is regulated. Changes in the regulatory environment or tax laws can affect the performance
of certain investments or issuers of those investments and thus, can have a negative impact on the
overall performance of such investments.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited market
in which they trade. Thus, you may experience the risk that your investment or assets within your
investment may not be able to be liquidated quickly, thus, extending the period of time by which you may
receive the proceeds from your investment. Liquidity risk can also result in unfavorable pricing when
exiting (i.e. not being able to quickly get out of an investment before the price drops significantly) a
particular investment and therefore, can have a negative impact on investment returns.
Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple
companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect.
Further, regardless of how well individual companies perform, the value of your portfolio could also
decrease if there are deteriorating economic or market conditions. It is important to understand that the
value of your investment may fall, sometimes sharply, in response to changes in the market, and you
could lose money. Investment risks include price risk as may be observed by a drop in a security’s price
due to company specific events (e.g. earnings disappointment or downgrade in the rating of a bond) or
general market risk (e.g. such as a “bear” market when stock values fall in general). For fixed-income
securities, a period of rising interest rates could erode the value of a bond since bond values generally fall
as bond yields go up. Past performance is not a guarantee of future returns.
Market Timing Risk: Market timing can include high risk of loss since it looks at an aggregate market
versus a specific security. Timing risk explains the potential for missing out on beneficial movements in
price due to an error in timing. This could cause harm to the value of an investor's portfolio because of
purchasing too high or selling too low.
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Private Wealth Solutions, LLC
Mid-Sized Companies Risk: Investments in securities issued by mid-sized companies may involve greater
risks than are customarily associated with larger, more established companies. Securities issued by mid-
sized companies tend to be more volatile than securities issued by larger or more established companies
and may underperform as compared to the securities of larger companies.
Money Market Risk: An investment in a money market fund is not a bank deposit and is not insured or
guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although a
money market fund seeks to preserve the value of your investment at $1.00 per share, it is possible to
lose money by investing in a money market fund.
Operational Risk: Operational risk can be experienced when an issuer of an investment product is
unable to carry out the business it has planned to execute. Operational risk can be experienced as a
result of human failure, operational inefficiencies, system failures, or the failure of other processes
critical to the business operations of the issuer or counter party to the investment.
Past Performance: Charting and technical analysis are often used interchangeably. Technical analysis
generally attempts to forecast an investment’s future potential by analyzing its past performance and
other related statistics. In particular, technical analysis often times involves an evaluation of historical
pricing and volume of a particular security for the purpose of forecasting where future price and volume
figures may go. As with any investment analysis method, technical analysis runs the risk of not knowing
the future and thus, investors should realize that even the most diligent and thorough technical analysis
cannot predict or guarantee the future performance of any particular investment instrument or issuer
thereof.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our firm
tries to achieve the highest return on client cash balances through relatively low-risk conservative
investments.
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
Representatives of our firm are registered representatives of KSI, member FINRA/SIPC, and licensed
insurance agents. As a result of these transactions, they receive normal and customary commissions. A
conflict of interest exists as these commissionable sales create an incentive to recommend products based
on the compensation earned. To mitigate this potential conflict, our firm will act in the client’s best
interest.
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Private Wealth Solutions, LLC
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.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by our
representatives for their personal accounts1. In order to monitor compliance with our personal trading
policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting system for
all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which
our firm or a related person has a material financial interest without prior disclosure to the client.
Related persons of our firm may buy or sell securities and other investments that are also recommended
to clients. In order to minimize this conflict of interest, our related persons will place client interests
ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon
request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they buy
or sell the same securities for client accounts. In order to minimize this conflict of interest, our related
persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a
copy of which is available upon request. Further, our related persons will refrain from buying or selling the
same securities prior to buying or selling for our clients in the same day unless included in a block trade.
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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Private Wealth Solutions, LLC
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Our firm does not maintain custody of client assets. Client assets must be maintained by a qualified
custodian. Our firm seeks to recommend a custodian who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available providers
and their services. The factors considered, among others, are these:
Timeliness of execution
Timeliness and accuracy of trade confirmations
Research services provided
Ability to provide investment ideas
Execution facilitation services provided
Record keeping services provided
Custody services provided
Frequency and correction of trading errors
Ability to access a variety of market venues
Expertise as it relates to specific securities
Financial condition
Business reputation
Quality of services
With this in consideration, our firm participates in the Schwab Institutional program. Charles Schwab.
(“Schwab”) member FINRA/SIPC. Schwab is an independent SEC-registered broker- dealer. Schwab offers
services to independent investment advisers which includes custody of securities, trade execution,
clearance and settlement of transactions. Schwab enables us to obtain many no- load mutual funds
without transaction charges and other no-load funds at nominal transaction charges. Schwab does not
charge client accounts separately for custodial services. Schwab generally does not charge ticket charges
for online U.S.-listed equities and ETFs, but clients may still incur other custodian and product-level fees
(e.g., wires, certain fixed income markups/markdowns, options, mutual fund transaction fees where
applicable, account/service fees, etc.)..
Schwab may make certain research and brokerage services available at no additional cost to our firm.
Research products and services provided by Schwab may include: research reports on recommendations
or other information about particular companies or industries; economic surveys, data and analyses;
financial database software and services;
financial publications; portfolio evaluation 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 Schwab 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.
Schwab 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 accounts for which our firm provides investment advisory services.
Without this arrangement, our firm might be compelled to purchase the same or similar services at our
own expense.
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Private Wealth Solutions, LLC
As part of our fiduciary duty to our clients, our firm will endeavor 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
Schwab as a custodial recommendation. Our firm examined this potential conflict of interest when our
firm chose to recommend Schwab 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.
including the value of
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,
research provided, execution capability, and
responsiveness.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will generally
be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
Schwab does not make client brokerage commissions generated by client transactions available for our
firm’s use. Our firm does not direct client transactions to a particular broker-dealer in return for soft
dollar benefits. Our firm does not receive brokerage for client referrals.
Directed Brokerage
In certain instances, clients may seek to limit or restrict our discretionary authority in making the
determination of the brokers with whom orders for the purchase or sale of securities are placed for
execution, and the commission rates at which such securities transactions are effected. Clients may seek
to limit our authority in this area by directing that transactions (or some specified percentage of
transactions) be executed through specified brokers in return for portfolio evaluation or other services
deemed by the client to be of value. Any such client direction must be in writing (often through our
advisory agreement), and may contain a representation from the client that the arrangement is
permissible under its governing laws and documents, if this is relevant.
Our firm provides appropriate disclosure in writing to clients who direct trades to particular brokers, that
with respect to their directed trades, they will be treated as if they have retained the investment
discretion that our firm otherwise would have in selecting brokers to effect transactions and in
negotiating commissions and that such direction may adversely affect our ability to obtain best price and
execution. In addition, our firm will inform clients in writing that the trade orders may not be aggregated
with other clients’ orders and that direction of brokerage may hinder best execution.
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
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Private Wealth Solutions, LLC
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be
for the exclusive benefit of the plan.
Client-Directed Brokerage
Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost clients
more money. For example,
in a directed brokerage account, clients may pay higher brokerage
commissions because our firm may not be able to aggregate orders to reduce transaction costs, or
clients may receive less favorable prices.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes that
to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur,
the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved.
In any given situation, our firm attempts to allocate trade executions in the most equitable manner
possible, taking into consideration client objectives, current asset allocation and availability of funds using
price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors review accounts on at least an annual basis for our
Asset Management clients. 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. 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.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to their
plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal
updated reports regarding their financial plans unless they separately engage our firm for a post-
financial plan meeting or update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to discuss
updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not
receive written or verbal updated reports regarding their plans unless they choose to engage our firm for
ongoing services.
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Private Wealth Solutions, LLC
Item 14: Client Referrals & Other Compensation
Charles Schwab
Our firm may recommend Schwab to clients for custody and brokerage services. There is no direct link
between our firm’s participation in the program and the investment advice given to clients, although we
receive economic benefits through our participation in the program that are typically not available to
Schwab retail investors. These benefits include the following products and services (provided without
cost or at a discount): receipt of duplicate client statements and confirmations; research related
products and tools; consulting services; access to a trading desk serving our firm’s participants; access to
block trading (which provides the ability to aggregate securities transactions for execution and then
allocate the appropriate shares to client accounts); the ability to have advisory fees deducted directly
from client accounts; access to an electronic communications network for client order entry and account
information; access to mutual funds with no transaction fees and to certain institutional money
managers; and discounts on compliance, marketing, research, technology, and practice management
products or services provided to us by third party vendors. Schwab may also have paid for business
consulting and professional services received by our firm’s related persons. Some of the products and
services made available by Schwab through the program may benefit our firm but may not benefit our
client accounts. These products or services may assist us in managing and administering client accounts,
including accounts not maintained at Schwab. Other services made available by Schwab are intended to
help us manage and further develop our business enterprise. The benefits received by our firm or our
personnel through participation in the program do not depend on the amount of brokerage transactions
directed to Schwab. As part of our fiduciary duties to our clients, we endeavor 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 in and of itself creates a potential conflict of interest and may indirectly
influence our firm’s choice of Schwab for custody and brokerage services.
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
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 “Third Party Money
Movement.” All of 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
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Private Wealth Solutions, LLC
the custody, safety or security of
statements will include a legend that recommends the client compare the account statements received
from the qualified custodian with those received from our firm. Clients are encouraged to raise any
questions with us about
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 authorization (“SLOA”) is deemed to have custody. As
such, our firm has adopted the following safeguards in conjunction with our custodian:
The client provides an instruction to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s
account number at a custodian to which the transfer should be directed.
The client authorizes the investment adviser, in writing, either on the qualified custodian’s form
or separately, to direct transfers to the third party either on a specified schedule or from time to
time.
The client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the client’s authorization, and provides a transfer of
funds notice to the client promptly after each transfer.
The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the client’s
instruction.
The investment adviser maintains records showing that the third party is not a related party of
the investment adviser or located at the same address as the investment adviser.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Our firm does not accept discretionary authority to manage securities accounts on behalf of clients. As
such, our firm is required to obtain the client’s permission prior to effecting securities transactions.
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.
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Item 18: Financial Information
Inclusion of a Balance Sheet
Our firm does not require nor is prepayment solicited for more than $1,200 in fees per client, 6 months
or more in advance. Therefore, our firm has not included a balance sheet for our most recent fiscal year.
Disclosure of Financial Condition
Our firm has received financial assistance through the U.S. Small Business Administration’s (“SBA”)
Economic Injury Loan (“EIL”) program and the Paycheck Protection Program (“PPP”). The EIL program is
intended to support small businesses in response to the COVID-19 pandemic by providing low-interest
loans and granting a $10,000 grant for business essential purposes. The PPP is intended to assist us with
maintaining our firm’s business in response by providing low-interest loans for business essentials such
as payroll expenses. Although our firm has directly received funding from an outside entity, clients are
not obligated to partner with any SBA lenders nor is our firm directly affiliated with the SBA outside of
this unique situation. In addition, the funding is meant to provide relief to our firm’s current operations
and are not intended for soliciting business. Alternatively, the PPP loans are eligible for forgiveness, but
it is not guaranteed as it will be based on factors such as staff retention and being used for payroll or
firm overhead.
Bankruptcy Petition
Our firm has nothing to disclose in this regard.
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Private Wealth Solutions, LLC