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Item 1: Cover Page
Item 1: Cover Page
Part 2A of Form ADV
Firm Brochure
September 10, 2025
Providence Wealth Advisors, LLC
SEC File No. 801-71352
Main Office
20220 South LaGrange Road
Frankfort, IL 60423
815-306-2020
Branch Offices
10100 Calumet Avenue
Dyer, IN 46311
219-365-7878
6431 W. 127th Street
Palos Heights, IL 60463
708-966-5743
email: cdalton@providencewealth.com
website: www.providencewealth.com
This brochure provides information about the qualifications and business practices of Providence Wealth
Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at
cdalton@providencewealth.com. The information in this brochure has not been approved or verified by
the United States Securities and Exchange Commission or any State securities authority. Registration with
the SEC or State Regulatory Authority does not imply a certain level of skill or expertise.
Additional information about Providence Wealth Advisors, LLC., is also available on the SEC’s website at
www.adviserinfo.sec.gov.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 2: Material Changes
Item 2: Material Changes
This Firm Brochure is our disclosure document prepared according to regulatory requirements
and rules. Consistent with the rules, we will ensure that you receive a summary of any material
changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal
year. Furthermore, we will provide you with other interim disclosures about material changes as
necessary.
There are no material changes since the last annual update of this Brochure issued February
2025.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 3: Table of Contents
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 and Compensation ............................................................................................................................. 9
Item 6: Performance-Based Fees and Side-by-Side Management .......................................................... 12
Item 7: Types of Clients ............................................................................................................................................ 13
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss .................................................. 14
Item 9: Disciplinary Information ........................................................................................................................... 24
Item 10: Other Financial Industry Activities and Affiliations ......................................................................... 25
Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal
Trading ............................................................................................................................................................ 26
Item 12: Brokerage Practices .................................................................................................................................... 28
Item 13: Review of Accounts .................................................................................................................................... 35
Item 14: Client Referrals and Other Compensation ......................................................................................... 36
Item 15: Custody ........................................................................................................................................................... 37
Item 16: Investment Discretion ................................................................................................................................ 38
Item 17: Voting Client Securities ............................................................................................................................. 39
Item 18: Financial Information ................................................................................................................................. 40
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Part 2A of Form ADV: Providence Wealth Brochure
Item 4: Advisory Business
Item 4: Advisory Business
A. Providence Wealth Advisors, LLC
Providence Wealth Advisors, LLC ("Providence Wealth" or “the firm”), a Securities and Exchange
Commission registered investment advisor, is an Illinois limited liability company that provides
financial planning discretionary and non-discretionary investment advisory services to high-net-
worth clients as more fully described below. Providence Wealth has been providing investment
advisory and financial planning services since April of 2010 and is principally owned by
Providence Bank & Trust Company.
B. Advisory Services Offered
Providence Wealth is an independent investment advisory and financial planning firm offering a
variety of financial services to individuals including high-net-worth individuals, trusts, retirement
plans, pension and profit sharing plans, and state or municipal government entities. Advisory
services may include investment strategy, portfolio management, financial planning, and estate
planning.
Clients have the right to provide the firm with any reasonable investment restrictions on the
management of their portfolio, which must be in writing and sent to the firm. Clients should
promptly notify the firm in writing of any changes in such restrictions or in the client's personal
financial circumstances, investment objectives, goals and tolerance for risk. Providence Wealth
will remind clients of their obligation to inform the firm of any such changes or any restrictions
that should be imposed on the management of the client’s account. Providence Wealth will also
contact clients at least annually to determine whether there have been any changes in a client's
personal financial circumstances, investment objectives and tolerance for risk.
Portfolio Management Services
Providence Wealth provides discretionary asset management services to its clients. Providence
Wealth receives a limited power of attorney to effect securities, mutual fund, and exchange-
traded fund transactions on behalf of its clients that include securities and strategies as itemized
in Item 8 of this Brochure.
Providence Wealth’s discretionary asset management services are predicated on asset allocation
models to create diversified portfolios consisting of individual securities, mutual funds, exchange
traded funds and portfolios managed by separate account managers engaged by Providence
Wealth on the client’s behalf. The asset allocation methodology employed by Providence Wealth
relies on modern portfolio theory, which involves the application of certain mathematical
principles to the historical risk, return and correlation characteristics of asset classes to combine
asset classes in such a way that maximizes return potential for a targeted level of risk. The
resulting asset allocation chosen seeks a projected return potential consistent with the client's
investment objectives, goals, tolerance for risk, and other personal and financial circumstances.
In preparing the asset allocation, Providence Wealth will analyze each client's current
investments, investment objectives, goals, age, time horizon, financial circumstances, investment
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Part 2A of Form ADV: Providence Wealth Brochure
Item 4: Advisory Business
experience, investment restrictions and limitations, and risk tolerance. Providence Wealth’s
objective is to review the client’s tax, financial, and estate planning objectives and goals in
connection with the client’s investment objectives, goals, tolerance for risk and other personal
and financial circumstances and make appropriate asset allocation recommendations and
implementation decisions. Providence Wealth may engage third-party service providers to assist
with the tax and estate planning portion of the services provided to clients. In addition,
Providence Wealth may utilize third-party software to analyze individual security holdings and
separate account managers utilized within the client’s portfolio.
Providence Wealth may prepare an investment policy statement based on the client’s
investment objectives, goals, tolerance for risk and such other factors unique to the client and
provide appropriate recommendations. On a quarterly basis, Providence Wealth, in connection
with a third-party service provider, will provide such clients with reports regarding the
performance of their portfolios. In addition, Providence Wealth will monitor those portfolios and
make additional recommendations from time to time to rebalance and/or reallocate each
client's investments.
Providence Wealth's investment advisory services to clients are based on asset allocation models
that, as noted above, take into account a client's personal financial circumstances, investment
objectives and tolerance for risk (e.g., cash-flow, tax and estate). Providence Wealth's
engagement with a client will include, as appropriate, the following:
▪ Providing assistance in reviewing the client's current investment portfolio against the
client's personal and financial circumstances as disclosed to Providence Wealth in
response to a questionnaire and/or in discussions with the client and reviewed in
meetings with the firm.
▪ Analyzing the client's financial circumstances, investment holdings and strategy, and
goals.
▪ Providing assistance in identifying a targeted asset allocation and portfolio design based
on modern portfolio theory.
▪
Implementing and/or recommending mutual funds, exchange traded funds, portfolios
managed by separate account managers and, in appropriate cases where clients are
qualified, alternative investments, each matched to the asset categories in the client's
targeted asset allocation for consideration by the client.
▪ Reporting to the client on a quarterly basis or at some other interval agreed to with the
client, information on contributions and withdrawals in the client's investment portfolio
and the performance of the client's portfolio measured against appropriate benchmarks
(including benchmarks selected by the client).
▪ Proposing changes in the client's targeted asset allocation in consideration of changes in
the client's personal circumstances, investment objectives and tolerance for risk, the
performance record of any of the client's investments, and/or the performance of any
fund or manager retained by the client.
▪
If the client’s portfolio and personal circumstances, investment objectives and tolerance
for risk make such advice appropriate, providing recommendations to hedge a client’s
portfolio through the use of derivative strategies, to generate additional income through
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Part 2A of Form ADV: Providence Wealth Brochure
Item 4: Advisory Business
the use of covered call option writing strategies involving exchange listed or OTC
options, and/or to monetize or hedge concentrated stock positions.
When appropriate to the needs of and suitability for a client, Providence Wealth will assist in
developing a strategy for monetizing/hedging a portfolio or a concentrated stock position held
by the client. Monetizing a concentrated stock position allows a client to receive funds to
diversify the portfolio and limit its downside exposure while allowing for the continued potential
to participate, to a lesser extent, in any increase in the price of the concentrated stock. Hedging
a concentrated stock position allows a client to protect against losses below a certain stock price
while allowing for the potential to participate in any increase in the price of the stock.
Providence Wealth will also assist in the proper diversification of concentrated stock positions
through the use of exchange traded funds in certain situations.
Non-Discretionary Investment Advisory Services
For non-discretionary services, Providence Wealth will recommend a diversified asset allocation
structure utilizing one or more securities for each recommended asset class pursuant to the
client’s investment goals, objectives, risk tolerance and other financial circumstances. Clients
may also elect to engage a third-party investment manager to manage client portfolio assets
pursuant to their investment goals, objectives, risk tolerance and other financial circumstances.
Pursuant to a client’s request, Providence Wealth may recommend one or more investment
managers available on the client’s custodian platform. Please be advised that certain portfolio
managers may not be available on the client’s custodial platform, a factor that should be
considered in evaluating the investment manager. Providence Wealth’s primary focus will be on
publicly traded equities (common and preferred stocks), exchange traded funds, open end
mutual funds, and fixed income securities (taxable and tax-free). Please refer to Item 8 of this
Brochure for a complete listing of the types of securities for which Providence Wealth provides
advice.
For clients with less than $100,000 in portfolio assets, Providence Wealth will recommend a
diversified portfolio of no-load or load-waived mutual funds that serves as a proxy of its core
value philosophy with an overlay of non-correlated assets. Providence Wealth will deliver
performance reports to such clients and will be available to discuss the portfolio no less
frequently than annually or as otherwise mutually agreed upon with the client.
In certain instances, Providence Wealth may recommend one or more third-party separate
account managers to manage one or more asset classes for a client. Please be advised that in
such instances Providence Wealth acts in the capacity of an investment consultant and provides
advice as to the most appropriate separate account manager in light of the client’s personal and
financial circumstances. Providence Wealth’s fees for this service are the same as if it were
managing the portfolio assets on a discretionary basis. In addition to fees charged by
Providence Wealth, the client will incur charges from the separate account manager. Although
Providence Wealth places its clients’ interests first by recommending the most appropriate
separate account managers, there is the potential for conflicts in that Providence Wealth earns
the same fee whether it is managing the portfolio or outsourcing the management. As a result,
one could view Providence Wealth’s loyalties as being divided in that Providence Wealth is paid
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Part 2A of Form ADV: Providence Wealth Brochure
Item 4: Advisory Business
to find the most appropriate separate account managers for asset classes outside of its core
management competency but will recommend itself for portfolio assets requiring the use of its
core management competency.
Financial Planning Services
Providence Wealth offer financial planning services solely to investment advisory clients, at no
additional charge. Clients may receive a written or oral report (depending on the client’s
preference) providing a detailed financial plan designed to help achieve the client’s stated
financial goals and objectives. Based on the client’s needs, financial planning services may
include (but are not limited to) the following:
▪ Preparation of a recommended asset allocation that serves to diversify the client's
portfolio among different categories of investments such as domestic and international
small, medium and large capitalization securities; corporate and government fixed
income (short-, intermediate- and long-term maturities); emerging market securities (i.e.,
foreign issuers), real estate investment trusts, and such other alternative asset categories
that are suitable in light of the client's investment goals, objectives and risk tolerance.
▪ Preparation of a retirement plan that serves to identify whether the client is saving
enough and investing in a way that meets retirement objectives in light of the client's
financial circumstances and risk tolerance.
▪ Preparation of cash flow projections to ensure that the client can meet daily living
expenses and obligations.
▪
Insurance planning to meet the needs of the client, taking into account family, business
and other financial objectives of the client.
▪ Preparation of an estate plan to ensure that wealth transition, tax and related issues are
met in accordance with the client's wishes. In all instances, an estate attorney will need to
be hired to review estate plan structure, address specific legal issues, draft necessary
documents and assist Providence Wealth in the implementation of the estate plan.
Providence Wealth gathers required information through in-depth personal interviews and
questionnaires. Information gathered includes a client's current financial status, investment
objectives, future goals and attitudes towards risk. Related documents supplied by the client are
carefully reviewed, and a report is prepared covering one or more of the above-mentioned
topics as directed by the client.
Retirement Rollovers – Conflicts and Added Fees
As a plan participant, clients may be paying little or nothing for the plan’s investment services.
As such, clients’ costs are likely to be more post-rollover. Alternative courses of action are
available to you: (i) Assuming it is permitted by the Plan, you can leave your money in your
current Plan. (ii) If you have changed employers, you can roll your assets into the new
employer’s Plan, if permissible by your new employer. (iii) You can establish an IRA R/O and
place into a commission-based account at a broker-dealer. (iv) You can establish an IRA R/O and
place into a fee-based advisory account. (v) You can withdraw your retirement money and pay
the taxes and any applicable penalties.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 4: Advisory Business
C. Client-Tailored Services and Client-Imposed Restrictions
Clients’ accounts will be managed on the basis of their financial situation and investment
objectives, and in accordance with any reasonable restrictions they have imposed on the
management of their accounts—for example, restricting the type or amount of security to be
purchased in the portfolio.
D. Wrap Fee Programs
Providence Wealth does not participate in wrap fee programs. (Wrap fee programs offer services
for one all-inclusive fee.)
E. Client Assets Under Management
As of December 31, 2024, Providence Wealth had approximately $601.1 million of discretionary
assets and $0 of non-discretionary assets under management.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 5: Fees and Compensation
Item 5: Fees and Compensation
A. Methods of Compensation and Fee Schedule
Portfolio Management Asset-Based Fee Schedule
The annual fee for portfolio asset supervisory services provided by Providence Wealth will be
charged as a percentage of assets under supervision by the firm. The fees will be computed in
the following manner:
Basis point charge X market value of assets X actual number of days/365 days
Providence Wealth’s asset-based fee schedule for accounts is detailed below, although such fee
schedule is negotiable.
Assets Under Supervision
Annual Fee Rate
First $250,000
Next $250,000
Next $500,000
Next $500,000
Next $500,000
Balance
1.25%
1.00%
0.85%
0.75%
0.65%
0.50%
Providence Wealth requires a minimum annual fee of $500. Please be advised that based upon
the minimum annual fee of $500, Providence Wealth’s investment advisory services are designed
for clients with assets of at least $40,000. Clients with less than $40,000 in assets may be able to
find more cost-effective investment advisory services with advisors other than Providence
Wealth.
Asset-based fees are always subject to the investment advisory agreement between the client
and Providence Wealth. Such fees are paid quarterly in advance. The client and the client’s
custodian or broker-dealer will be invoiced at the beginning of each calendar quarter, based
upon the market value (market value plus any credit balance or minus any debit balance) of the
client's account at the end of the previous quarter, as mutually agreed upon by the client and
Providence Wealth. The fees will be prorated if the investment advisory relationship commences
otherwise than at the beginning of a calendar quarter.
The client authorizes the qualified custodian to automatically deduct the fee and all other
charges payable hereunder from the assets in the account when due, with such payments to be
reflected on the next account statement sent to the client. If insufficient cash is available to pay
such fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay
for the unpaid balance. Providence Wealth may modify the fee at any time upon 30 days’ written
notice to the client. In the event the client has an ERISA-governed plan, fee modifications must
be approved in writing by the client.
A client investment advisory agreement may be canceled at any time by the client, or by
Providence Wealth with 60 days’ prior written notice to the client. Upon termination, any
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Part 2A of Form ADV: Providence Wealth Brochure
Item 5: Fees and Compensation
unearned, prepaid fees will be refunded. The client has the right to terminate an agreement
without penalty within five business days after entering into the agreement.
B. Client Payment of Fees
Providence Wealth will deduct advisory fees directly from the client’s account provided that (i)
the client provides written authorization to the qualified custodian, and (ii) the qualified
custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from
the account.
The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian
will not verify the calculation.
C. Additional Client Fees Charged
All fees paid for investment advisory services are separate and distinct from the fees and
expenses charged by exchange-traded funds, mutual funds, private placements, pooled
investment vehicles, broker-dealers, and custodians retained by clients. Such fees and expenses
are described in each exchange-traded fund and mutual fund’s prospectus, each private
placement or pooled investment vehicle’s confidential offering memoranda, and by any broker-
dealer or custodian retained by the client. Clients are advised to read these materials carefully
before investing. If a mutual fund also imposes sales charges, a client may pay an initial or
deferred sales charge as further described in the mutual fund’s prospectus. A client using
Providence Wealth may be precluded from using certain mutual funds or separate account
managers because they may not be offered by the client's custodian.
Please refer to the Brokerage Practices section (Item 12) for additional information regarding the
firm’s brokerage practices.
D. Prepayment of Client Fees
Providence requires the prepayment of its portfolio management fees. Providence Wealth’s fees
will either be paid directly by the client or disbursed to Providence Wealth by the qualified
custodian of the client’s investment accounts, subject to prior written consent of the client. The
custodian will deliver directly to the client an account statement, at least quarterly, showing all
investment and transaction activity for the period, including fee disbursements from the
account.
A client investment advisory agreement may be canceled at any time by the client, or by
Providence Wealth with 60 days’ prior written notice to the client. A financial planning
agreement may be terminated by either party for any reason upon receipt of written notice.
Upon termination of any account, any unearned, prepaid fees will be refunded, and any earned,
unpaid fees will be due and payable. The client has the right to terminate an agreement without
penalty within five business days after entering into the agreement.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 5: Fees and Compensation
E. External Compensation for the Sale of Securities to Clients
Providence Wealth’s financial advisors are compensated primarily through a salary and bonus
structure. Certain Providence Wealth advisory professionals may also generate commission-
based compensation for the sale of insurance products paid to the firm. Please see Item 10.C. for
detailed information and conflicts of interest.
F. Important Disclosure – Custodian Investment Programs
Please be advised that the firm utilizes certain custodians/broker-dealers. Under these
arrangements we can access certain investment programs offered through such custodian(s)
that offer certain compensation and fee structures that create conflicts of interest of which
clients need to be aware. Please note the following:
Limitation on Mutual Fund Universe for Custodian Investment Programs: There are certain
programs in which we participate where a client’s investment options may be limited in certain
of these programs to those mutual funds and/or mutual fund share classes that pay 12b-1 fees
and other revenue sharing fee payments, and the client should be aware that the firm is not
selecting from among all mutual funds available in the marketplace when recommending
mutual funds to the client.
Conflict Between Revenue Share Class (12b-1) and Non-Revenue Share Class Mutual Funds:
Revenue share class/12b-1 fees are deducted from the net asset value of the mutual fund and
generally, all things being equal, cause the fund to earn lower rates of return than those mutual
funds that do not pay revenue sharing fees. The client is under no obligation to utilize such
programs or mutual funds. Although many factors will influence the type of fund to be used, the
client should discuss with their investment adviser representative whether a share class from a
comparable mutual fund with a more favorable return to investors is available that does not
include the payment of any 12b-1 or revenue sharing fees given the client’s individual needs
and priorities and anticipated transaction costs. In addition, the receipt of such fees can create
conflicts of interest in instances where the custodian receives the entirety of the 12b-1 and/or
revenue sharing fees and takes the receipt of such fees into consideration in terms of benefits it
may elect to provide to the firm, even though such benefits may or may not benefit some or all
of the firm clients.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 6: Performance-Based Fees and Side-by-Side Management
Item 6: Performance-Based Fees and Side-by-Side Management
Providence Wealth does not charge performance-based fees and therefore has no economic
incentive to manage clients’ portfolios in any way other than what is in their best interests.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 7: Types of Clients
Item 7: Types of Clients
Providence Wealth offers its investment services to various types of clients, including high-net-
worth individuals, trusts, retirement plans, pension and profit sharing plans, and state or
municipal government entities. Although Providence Wealth provides investment services to the
various types of clients mentioned, the services are conditioned upon meeting certain minimum
criteria established by the firm for each of the investment programs it offers.
Providence Wealth requires a minimum annual fee of $500. Please be advised that based upon
the minimum annual fee of $500, Providence Wealth’s investment advisory services are designed
for clients with assets of at least $40,000. Clients with less than $40,000 in assets may be able to
find more cost-effective investment advisory services with advisors other than Providence
Wealth.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
A. Methods of Analysis and Investment Strategies
Providence Wealth uses a variety of sources of data to conduct its economic, investment and
market analysis, such as financial newspapers and magazines, economic and market research
materials prepared by others, conference calls hosted by mutual funds, corporate rating services,
annual reports, prospectuses, and company press releases. It is important to keep in mind that
there is no specific approach to investing that guarantees success or positive returns; investing
in securities involves risk of loss that clients should be prepared to bear.
Providence Wealth and its investment adviser representatives are responsible for identifying and
implementing the methods of analysis used in formulating investment recommendations to
clients. The methods of analysis may include quantitative methods for optimizing client
portfolios, computer-based risk/return analysis, technical analysis, and statistical and/or
computer models utilizing long-term economic criteria.
▪ Optimization involves the use of mathematical algorithms to determine the appropriate
mix of assets given the firm’s current capital market rate assessment and a particular
client’s risk tolerance.
▪ Quantitative methods include analysis of historical data such as price and volume
statistics, performance data, standard deviation and related risk metrics, how the security
performs relative to the overall stock market, earnings data, price to earnings ratios, and
related data.
▪ Technical analysis involves charting price and volume data as reported by the exchange
where the security is traded to look for price trends.
▪ Computer models may be used to attempt the future value of a security based on
assumptions of various data categories such as earnings, cash flow, profit margins, sales,
and a variety of other company specific metrics.
In addition, Providence Wealth reviews research material prepared by others, as well as
corporate filings, corporate rating services, and a variety of financial publications. Providence
Wealth may employ outside vendors or utilize third-party software to assist in formulating
investment recommendations to clients.
Mutual Funds, Exchange-Traded Funds, Pooled Investment Vehicles, and Individual
Equity and Fixed Income Securities
Providence Wealth may recommend institutional share class” mutual funds, exchange-traded
funds (“ETFs”), individual securities (including fixed income instruments), and pooled investment
vehicles.
A description of the criteria to be used in formulating an investment recommendation for
mutual funds, ETFs, individual securities (including fixed-income securities), and pooled
investment vehicles is set forth below.
Providence Wealth has formed relationships with third-party vendors that
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
▪ prepare performance reports
▪ perform or distribute research of individual securities
▪ perform billing and certain other administrative tasks
Providence Wealth may utilize additional independent third parties to assist it in recommending
and monitoring individual securities, funds, and pooled investment vehicles to clients as
appropriate under the circumstances.
Providence Wealth reviews certain quantitative and qualitative criteria related to funds and to
formulate investment recommendations to its clients. Quantitative criteria may include
▪ performance history of a fund evaluated against that of its peers and other benchmarks
▪ analysis of risk-adjusted returns
▪
fund’s fee structure
▪
relevant fund portfolio manager’s tenure
Qualitative criteria used in selecting/recommending funds include the investment objectives
and/or management style and philosophy of a fund; a fund’s consistency of investment style;
and employee turnover and efficiency and capacity.
Quantitative and qualitative criteria related to funds are reviewed by Providence Wealth on a
quarterly basis or such other interval as appropriate under the circumstances. In addition, funds
are reviewed to determine the extent to which their investments reflect any of the following:
efforts to time the market, engage in portfolio pumping, or evidence style drift such that their
portfolios no longer accurately reflect the particular asset category attributed to the fund by
Providence Wealth (all are negative factors in implementing an asset allocation structure).
Account minimum balances and fees may significantly differ between clients/funds. Each client’s
individual needs and circumstances will determine portfolio weighting, which can have an
impact on the funds utilized. Providence Wealth will endeavor to obtain equal treatment for its
clients with funds but cannot assure equal treatment.
Providence Wealth will regularly review the activities of funds utilized for the client. Clients that
invest in funds should first review and understand the disclosure documents of those funds,
which contain information relevant to such retention or investment, including information on
the methodology used to analyze securities, investment strategies, fees and conflicts of interest.
Similarly, clients qualified to invest in pooled investment vehicles should review the private
placement memoranda or other disclosure materials relating to such vehicles before making a
decision to invest.
Material Risks of Investment Instruments
Providence Wealth may invest in equity securities, corporate debt instruments, municipal fixed
income instruments, government securities including asset-backed securities, and options on
securities as detailed below:
▪ Equity securities
▪ Warrants and rights
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
▪ Mutual fund securities
▪ Exchange-traded funds
▪ Corporate debt securities, commercial paper and certificates of deposit
▪ Municipal securities
▪ U.S. government securities
▪ Pooled investment vehicles
▪ Structured products
▪ Government and agency mortgage-backed securities
▪ Corporate debt obligations
▪ Mortgage-backed securities
▪ Collateralized obligations
▪ Fixed equity annuities
▪ Fixed equity indexed annuities
▪ Variable annuities
Equity Securities
Investing in individual companies involves inherent risk. The major risks relate to the
company’s capitalization, quality of the company’s management, quality and cost of the
company’s services, the company’s ability to manage costs, efficiencies in the manufacturing
or service delivery process, management of litigation risk, and the company’s ability to create
shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in
addition to the general risks of equity securities, have geopolitical risk, financial transparency
risk, currency risk, regulatory risk and liquidity risk.
Warrants and Rights
Warrants are securities, typically issued with preferred stock or bonds, that give the holder the
right to purchase a given number of shares of common stock at a specified price and time. The
price of the warrant usually represents a premium over the applicable market value of the
common stock at the time of the warrant’s issuance. Warrants have no voting rights with
respect to the common stock, receive no dividends, and have no rights with respect to the
assets of the issuer.
Investments in warrants and rights involve certain risks, including the possible lack of a liquid
market for the resale of the warrants and rights, potential price fluctuations due to adverse
market conditions or other factors, and failure of the price of the common stock to rise. If the
warrant is not exercised within the specified time period, it becomes worthless.
Mutual Fund Securities
Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund
include the quality and experience of the portfolio management team and its ability to create
fund value by investing in securities that have positive growth, the amount of individual
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
company diversification, the type and amount of industry diversification, and the type and
amount of sector diversification within specific industries. In addition, mutual funds tend to be
tax inefficient and therefore investors may pay capital gains taxes on fund investments while
not having yet sold the fund.
Exchange-Traded Funds (“ETFs”)
ETFs are investment companies whose shares are bought and sold on a securities exchange.
An ETF holds a portfolio of securities designed to track a particular market segment or index.
Some examples of ETFs are SPDRs®, streetTRACKS®, DIAMONDSSM, NASDAQ 100 Index
Tracking StockSM (“QQQs SM”), iShares® and VIPERs®. The funds could purchase an ETF to gain
exposure to a portion of the U.S. or foreign market. The funds, as a shareholder of another
investment company, will bear their pro rata portion of the other investment company’s
advisory fee and other expenses, in addition to their own expenses.
Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its
size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price
movement of the ETF or enhancing any downward price movement. Also, ETFs require more
frequent portfolio reporting by regulators and are thereby more susceptible to actions by
hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may
employ leverage, which creates additional volatility and price risk depending on the amount of
leverage utilized, the collateral and the liquidity of the supporting collateral.
Further, the use of leverage (i.e., employ the use of margin) generally results in additional
interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional
volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price
of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the
ETF.
Corporate Debt, Commercial Paper and Certificates of Deposit
Fixed income securities carry additional risks than those of equity securities described above.
These risks include the company’s ability to retire its debt at maturity, the current interest rate
environment, the coupon interest rate promised to bondholders, legal constraints,
jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of 10 years or
greater, they will likely have greater price swings when interest rates move up or down. The
shorter the maturity the less volatile the price swings. Foreign bonds also have liquidity and
currency risk.
Commercial paper and certificates of deposit are generally considered safe instruments,
although they are subject to the level of general interest rates, the credit quality of the issuing
bank and the length of maturity. With respect to certificates of deposit, depending on the
length of maturity there can be prepayment penalties if the client needs to convert the
certificate of deposit to cash prior to maturity.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Municipal Securities
Municipal securities carry additional risks than those of corporate and bank-sponsored debt
securities described above. These risks include the municipality’s ability to raise additional tax
revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its
debt and to retire its debt at maturity. Municipal bonds are generally tax-free at the federal
level, but may be taxable in individual states other than the state in which both the investor
and municipal issuer is domiciled.
U.S. Government Securities
U.S. government securities include securities issued by the U.S. Treasury and by U.S.
government agencies and instrumentalities. U.S. government securities may be supported by
the full faith and credit of the United States.
Pooled Investment Vehicles
A pooled investment vehicle, such as a commodity pool or investment company, is generally
offered only to investors who meet specified suitability, net worth and annual income criteria.
Pooled investment vehicles sell securities through private placements and thus are illiquid and
subject to a variety of risks that are disclosed in each pooled investment vehicle’s confidential
private placement memorandum or disclosure document. Investors should read these
documents carefully and consult with their professional advisors prior to committing
investment dollars. Because many of the securities involved in pooled investment vehicles do
not have transparent trading markets from which accurate and current pricing information can
be derived, or in the case of private equity investments where portfolio security companies are
privately held with no publicly traded market, Providence Wealth will be unable to monitor or
verify the accuracy of such performance information.
Structured Products
Structured products are designed to facilitate highly customized risk-return objectives. While
structured products come in many different forms, they typically consist of a debt security that
is structured to make interest and principal payments based upon various assets, rates or
formulas. Many structured products include an embedded derivative component. Structured
products may be structured in the form of a security, in which case these products may receive
benefits provided under federal securities law, or they may be cast as derivatives, in which case
they are offered in the over-the-counter market and are subject to no regulation.
Investment in structured products includes significant risks, including valuation, liquidity, price,
credit and market risks. One common risk associated with structured products is a relative lack
of liquidity due to the highly customized nature of the investment. Moreover, the full extent of
returns from the complex performance features is often not realized until maturity. As such,
structured products tend to be more of a buy-and-hold investment decision rather than a
means of getting in and out of a position with speed and efficiency.
Another risk with structured products is the credit quality of the issuer. Although the cash
flows are derived from other sources, the products themselves are legally considered to be the
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
issuing financial institution's liabilities. The vast majority of structured products are from high-
investment-grade issuers only. Also, there is a lack of pricing transparency. There is no uniform
standard for pricing, making it harder to compare the net-of-pricing attractiveness of
alternative structured product offerings than it is, for instance, to compare the net expense
ratios of different mutual funds or commissions among broker-dealers.
Government and Agency Mortgage-Backed Securities
The principal issuers or guarantors of mortgage-backed securities are the Government
National Mortgage Association (“GNMA”), Fannie Mae (“FNMA”) and the Federal Home Loan
Mortgage Corporation (“FHLMC”). GNMA, a wholly owned U.S. government corporation within
the Department of Housing and Urban Development (“HUD”), creates pass-through securities
from pools of government-guaranteed (Farmers’ Home Administration, Federal Housing
Authority or Veterans Administration) mortgages. The principal and interest on GNMA pass-
through securities are backed by the full faith and credit of the U.S. government.
FNMA, which is a U.S. government-sponsored corporation owned entirely by private
stockholders that is subject to regulation by the secretary of HUD, and FHLMC, a corporate
instrumentality of the U.S. government, issue pass-through securities from pools of
conventional and federally insured and/or guaranteed residential mortgages. FNMA
guarantees full and timely payment of all interest and principal, and FHMLC guarantees timely
payment of interest and ultimate collection of principal of its pass-through securities.
Mortgage-backed securities from FNMA and FHLMC are not backed by the full faith and credit
of the U.S. government.
Corporate Debt Obligations
Corporate debt obligations include corporate bonds, debentures, notes, commercial paper
and other similar corporate debt instruments. Companies use these instruments to borrow
money from investors. The issuer pays the investor a fixed or variable rate of interest and must
repay the amount borrowed at maturity. Commercial paper (short-term unsecured promissory
notes) is issued by companies to finance their current obligations and normally has a maturity
of less than nine months. Providence Wealth may also invest in corporate debt securities
registered and sold in the United States by foreign issuers (Yankee bonds) and those sold
outside the U.S. by foreign or U.S. issuers (Eurobonds).
Mortgage-Backed Securities
Mortgage-backed securities represent interests in a pool of mortgage loans originated by
lenders such as commercial banks, savings associations, and mortgage bankers and brokers.
Mortgage-backed securities may be issued by governmental or government-related entities,
or by non-governmental entities such as special-purpose trusts created by commercial
lenders.
Pools of mortgages consist of whole mortgage loans or participations in mortgage loans. The
majority of these loans are made to purchasers of between one and four family homes. The
terms and characteristics of the mortgage instruments are generally uniform within a pool but
may vary among pools. For example, in addition to fixed-rate, fixed-term mortgages,
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Providence Wealth may purchase pools of adjustable-rate mortgages, growing equity
mortgages, graduated payment mortgages and other types. Mortgage poolers apply
qualification standards to lending institutions, which originate mortgages for the pools as well
as credit standards and underwriting criteria for individual mortgages included in the pools. In
addition, many mortgages included in pools are insured through private mortgage insurance
companies.
Mortgage-backed securities differ from other forms of fixed income securities, which normally
provide for periodic payment of interest in fixed amounts, with principal payments at maturity
or on specified call dates. Most mortgage-backed securities, however, are pass-through
securities, which means that investors receive payments consisting of a pro rata share of both
principal and interest (less servicing and other fees), as well as unscheduled prepayments as
loans in the underlying mortgage pool are paid off by the borrowers. Additional prepayments
to holders of these securities are caused by prepayments resulting from the sale or foreclosure
of the underlying property or refinancing of the underlying loans. As prepayment rates of
individual pools of mortgage loans vary widely, it is not possible to accurately predict the
average life of a particular mortgage-backed security. Although mortgage-backed securities
are issued with stated maturities of up to 40 years, unscheduled or early payments of principal
and interest on the mortgages may shorten considerably the securities’ effective maturities.
Collateralized Obligations
Collateralized mortgage obligations (“CMOs”) are collateralized by mortgage-backed
securities issued by GNMA, FHLMC or FNMA (“mortgage assets”). CMOs are multiple-class
debt obligations. Payments of principal and interest on the mortgage assets are passed
through to the holders of the CMOs as they are received, although certain classes (often
referred to as “tranches”) of CMOs have priority over other classes with respect to the receipt
of mortgage prepayments. Each tranche is issued at a specific or floating coupon rate and has
a stated maturity or final distribution date. Interest is paid or accrues in all tranches on a
monthly, quarterly or semi-annual basis. Payments of principal and interest on mortgage
assets are commonly applied to the tranches in the order of their respective maturities or final
distribution dates, so that generally no payment of principal will be made on any tranche until
all other tranches with earlier stated maturity or distribution dates have been paid in full.
Collateralized debt obligations ("CDOs") include collateralized bond obligations ("CBOs"),
collateralized loan obligations ("CLOs") and other similarly structured securities. CBOs and
CLOs are types of asset-backed securities. A CBO is a trust that is backed by a diversified pool
of high-risk, below-investment-grade fixed income securities. A CLO is a trust typically
collateralized by a pool of loans, which may include, among others, domestic and foreign
senior secured loans, senior unsecured loans and subordinate corporate loans, including loans
that may be rated below investment grade or equivalent unrated loans.
Fixed Equity Annuities
A fixed annuity is a contract between an insurance company and a customer, typically called
the annuitant. The contract obligates the company to make a series of fixed annuity payments
to the annuitant for the duration of the contract. The annuitant surrenders a lump sum of cash
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
in exchange for monthly payments that are guaranteed by the insurance company. Please note
the following risks: (i) Spending power risk. Social security retirement benefits have cost-of-
living adjustments. Most fixed annuities do not. Consequently, the spending power provided
by the monthly payment may decline significantly over the life of the annuity contract because
of inflation. (ii) Death and survivorship risk. In a conventional fixed annuity, once the annuitant
has turned over a lump sum premium to the insurance company, it will not be returned. The
annuitant could die after receiving only a few monthly payments, but the insurance company
may not be obligated to give the annuitant’s estate any of the money back. A related risk is
based on the financial consequences for a surviving spouse. In a standard single-life annuity
contract, a survivor receives nothing after the annuitant dies. That may put a severe dent in a
spouse’s retirement income. To counteract this risk, consider a joint life annuity. (iii) Company
failure risk. Private annuity contracts are not guaranteed by the FDIC, SIPC, or any other federal
agency. If the insurance company that issues an annuity contract fails, no one in the federal
government is obligated to protect the annuitant from financial loss. Most states have
guaranty associations that provide a level of protection to citizens in that state if an insurance
company also doing business in that state fails. A typical limit of state protection, if it applies
at all, is $100,000. To control this risk, contact the state insurance commissioner to confirm
that your state has a guaranty association and to learn the guarantee limits applicable to a
fixed annuity contract. Based on that information, consider dividing fixed annuity contracts
among multiple insurance companies to obtain the maximum possible protection. Also check
the financial stability and credit ratings of the annuity insurance companies being considered.
A.M. Best and Standard & Poor’s publish ratings information.
Fixed Equity Indexed Annuities
An equity-indexed annuity is a type of fixed annuity that is distinguished by the interest yield
return being partially based on an equities index, typically the S&P 500. The returns (in the
form of interest credited to the contract) can consist of a guaranteed minimum interest rate
and an interest rate linked to a market index. The guaranteed minimum interest rate usually
ranges from 1 to 3 percent on at least 87.5 percent of the premium paid. As long as the
company offering the annuity is fiscally sound enough to meet its obligations, the annuitant
will be guaranteed to receive this return no matter how the market performs. Your index-
linked returns will depend on how the index performs but, generally speaking, an investor with
an indexed annuity will not see his or her rate of return fully match the positive rate of return
of the index to which the annuity is linked — and could be significantly less. One major reason
for this is that returns are subject to contractual limitations in the form of caps and
participation rates. Participation rates are the percentage of an index's returns that are
credited to the annuity. For instance, if an annuity has a participation rate of 75 percent, then
the index-linked returns would only amount to 75 percent of the gains associated with the
index. Interest caps, meanwhile, essentially mean that during big bull markets, investors won't
see their returns go sky-high. For instance, if an index rises 12 percent, but an investor's
annuity has a cap of 7 percent, his or her returns will be limited to 7 percent.
Some indexed annuity contracts allow the issuer to change these fees, participation rates, and
caps from time to time. Investors should also be aware that trying to withdraw the principal
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
amount from a fixed indexed annuity during a certain period — usually within the first 9 or 10
years after the annuity was purchased — can result in fees known as surrender charges and
could also trigger tax penalties. In fact, under some contracts, if withdrawals are taken
amounts already credited will be forfeited. After paying surrender charges, an investor could
lose money by surrendering the indexed annuity too soon.
Variable Annuities
Variable annuities are long-term financial products designed for retirement purposes. In
essence, annuities are contractual agreements in which payment(s) are made to an insurance
company, which agrees to pay out an income or a lump sum amount at a later date. There are
contract limitations and fees and charges associated with annuities, administrative fees, and
charges for optional benefits. They also may carry early withdrawal penalties and surrender
charges, and carry additional risks such as the insurance carrier's ability to pay claims.
Moreover, variable annuities carry investment risk similar to mutual funds. Investors should
carefully review the terms of the annuity contract before investing.
B. Investment Strategy and Method of Analysis Material Risks
Leverage
Although Providence Wealth, as a general business practice, does not utilize leverage, there may
be instances in which exchange traded funds, other separate account managers and, in very
limited circumstances, Providence Wealth will utilize leverage. In this regard please review the
following:
The use of leverage enhances the overall risk of investment gain and loss to the client’s
investment portfolio. For example, investors are able to control $2 of a security for $1. So if the
price of a security rises by $1, the investor earns a 100% return on their investment. Conversely,
if the security declines by $.50, then the investor loses 50% of their investment. The use of
leverage entails borrowing, which results in additional interest costs to the investor. In addition,
the use of leverage enhances the price volatility of the collateral securities which can result in
significant loss.
Broker-dealers that carry customer accounts have a minimum equity requirement when clients
utilize leverage. The minimum equity requirement is stated as a percentage of the value of the
underlying collateral security with an absolute minimum dollar requirement. For example, if the
price of a security declines in value to the point where the excess equity used to satisfy the
minimum requirement dissipates, the broker-dealer will require the client to deposit additional
collateral to the account in the form of cash or marketable securities. A deposit of securities to
the account will require a larger deposit, as the security being deposited is included in the
computation of the minimum equity requirement. In addition, when leverage is utilized and the
client needs to satisfy a required margin deposit or withdraw cash, the client must sell a
disproportionate amount of collateral securities to release enough cash to satisfy the withdrawal
amount based upon similar reasoning as cited above.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Regulations concerning the use of leverage are established by the Federal Reserve Board and
vary if the client’s account is held at a broker-dealer versus a bank custodian. Broker-dealers and
bank custodians may apply more stringent rules as they deem necessary.
Short-Term Trading
Although Providence Wealth, as a general business practice, does not utilize short-term trading,
there may be instances in which short-term trading may be necessary or an appropriate
strategy. In this regard please read the following:
There is an inherent risk for clients who trade frequently in that high-velocity trading creates
substantial transaction costs that in the aggregate could negatively impact account
performance.
C. Concentration Risks
There is an inherent risk for clients whose investment portfolios lack diversification—that is, they
have their investment portfolios heavily weighted in one security, one industry or industry
sector, one geographic location, one investment manager, one type of investment instrument
(equities versus fixed income). Clients who have diversified portfolios, as a general rule, incur
less volatility and therefore less fluctuation in portfolio value than those who have concentrated
holdings. Concentrated holdings may offer the potential for higher gain, but also offer the
potential for significant loss.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 9: Disciplinary Information
Item 9: Disciplinary Information
A. Criminal or Civil Actions
Providence Wealth has nothing to disclose for this item.
B. Administrative Enforcement Proceedings
Providence Wealth has nothing to disclose for this item.
C. Self-Regulatory Organization Enforcement Proceedings
Providence Wealth has nothing to disclose for this item.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 10: Other Financial Industry Activities and Affiliations
Item 10: Other Financial Industry Activities and Affiliations
A. Broker-Dealer or Representative Registration
Providence Wealth is not registered as a broker-dealer and does not have an application to
register pending.
B. Futures or Commodity Registration
Providence Wealth is not registered as a commodity firm, futures commission merchant,
commodity pool operator, or commodity trading advisor and does not have an application to
register pending.
C. Material Relationships Maintained by this Advisory Business and
Conflicts of Interest
Providence Bank & Trust Company
Providence Wealth’s parent company is Providence Bank & Trust Company. As a result of the
parent-affiliate relationship, Providence Bank & Trust Company exclusively offers Providence
Wealth’s investment advisory and financial planning services to its customers. Please be advised
that there is no obligation for the client to engage Providence Wealth as a condition of its
relationship with Providence Bank & Trust Company. Prospective clients are free to do business
with the investment advisor of their choice.
Insurance Sales
Certain Providence Wealth advisory professionals are licensed insurance agents and may
recommend insurance products offered by such carriers for whom they function as an agent and
where the firm receives a commission for doing so. Please be advised there is a conflict of
interest in that there is an economic incentive to recommend insurance and other products of
such carriers. Please also be advised that Providence Wealth strives to put its clients’ interests
first and foremost, and clients may utilize any insurance carrier or insurance agency they desire.
D. Recommendation or Selection of Other Investment Advisors and
Conflicts of Interest
Providence Wealth does not recommend separate account managers or other investment
products in which it receives any form of compensation from the separate account manager or
investment product sponsor.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading
Item 11: Code of Ethics, Participation or Interest in Client Transactions,
and Personal Trading
A. Code of Ethics Description
In accordance with the Advisers Act, Providence Wealth has adopted policies and procedures
designed to detect and prevent insider trading. In addition, Providence Wealth has adopted a
Code of Ethics (the “Code”). Among other things, the Code includes written procedures
governing the conduct of the firm's advisory and access persons. The Code also imposes certain
reporting obligations on persons subject to the Code. The Code and applicable securities
transactions are monitored by the Chief Compliance Officer of the firm. Providence Wealth will
send clients a copy of its Code of Ethics upon written request.
Providence Wealth has policies and procedures in place to ensure that the interests of its clients
are given preference over those of the firm, its affiliates and its employees. For example, there
are policies in place to prevent the misappropriation of material nonpublic information, and
such other policies and procedures reasonably designed to comply with federal and state
securities laws.
B. Investment Recommendations Involving a Material Financial Interest and
Conflicts of Interest
Providence Wealth does not engage in principal trading (i.e., the practice of selling stock to
advisory clients from a firm’s inventory or buying stocks from advisory clients into a firm’s
inventory). In addition, Providence Wealth does not recommend any securities to advisory
clients in which it has some proprietary or ownership interest.
C. Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
Providence Wealth, its affiliates, employees and their families, trusts, estates, charitable
organizations and retirement plans established by it may purchase the same securities as are
purchased for clients in accordance with its Code of Ethics policies and procedures. The personal
securities transactions by advisory representatives and employees may raise potential conflicts
of interest when they trade in a security that is:
▪ owned by the client, or
▪ considered for purchase or sale for the client.
Such conflict generally refers to the practice of front-running (trading ahead of the client), which
Providence Wealth specifically prohibits. Providence Wealth has adopted policies and
procedures that are intended to address these conflicts of interest. These policies and
procedures:
▪
require our advisory representatives and employees to act in the client’s best interest
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Part 2A of Form ADV: Providence Wealth Brochure
Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading
▪ prohibit fraudulent conduct in connection with the trading of securities in a client
account
▪ prohibit employees from personally benefitting by causing a client to act, or fail to act in
making investment decisions
▪ prohibit the firm or its employees from profiting or causing others to profit on
knowledge of completed or contemplated client transactions
▪ allocate investment opportunities in a fair and equitable manner
▪ provide for the review of transactions to discover and correct any trades that result in an
advisory representative or employee benefitting at the expense of a client.
Advisory representatives and employees must follow Providence Wealth’s procedures when
purchasing or selling the same securities purchased or sold for the client.
D. Client Securities Recommendations or Trades and Concurrent Advisory
Firm Securities Transactions and Conflicts of Interest
Providence Wealth, its affiliates, employees and their families, trusts, estates, charitable
organizations, and retirement plans established by it may effect securities transactions for their
own accounts that differ from those recommended or effected for other of the firm’s clients.
Providence Wealth will make a reasonable attempt to trade securities in client accounts at or
prior to trading the securities in its affiliate, corporate, employee or employee-related accounts.
Trades executed the same day will likely be subject to an average pricing calculation. It is the
policy of Providence Wealth to place the clients’ interests above those of the firm and its
employees.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 12: Brokerage Practices
Item 12: Brokerage Practices
A. Factors Used to Select Broker-Dealers for Client Transactions
Custodian Recommendations
Providence Wealth may recommend that clients establish brokerage accounts with the Schwab
Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-
dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their
accounts. Although Providence Wealth may recommend that clients establish brokerage
accounts with Schwab, Providence Wealth is independently owned and operated and not
affiliated with Schwab. Schwab does not charge separately for custody services, but is
compensated by account holders through commissions and other transaction-related or asset-
based fees for securities trades that are executed through or that settle into Schwab accounts.
In certain instances and subject to approval by the firm, Providence Wealth will recommend to
clients certain broker-dealers and/or custodians based on the needs of the individual client,
taking into consideration the nature of the services required, the experience of the broker-dealer
or custodian, the cost and quality of the services, and the reputation of the broker-dealer or
custodian. The final determination to engage a broker-dealer or custodian recommended by
Providence Wealth will be made by and in the sole discretion of the client. The client recognizes
that broker-dealers and/or custodians have different cost and fee structures and trade execution
capabilities. As a result, there may be disparities with respect to the cost of services and/or the
transaction prices for securities transactions executed on behalf of the client. Clients are
responsible for assessing the commissions and other costs charged by broker-dealers and/or
custodians.
How We Select Brokers/Custodians to Recommend
Providence Wealth seeks to recommend a custodian/broker who will hold client assets and
execute transactions on terms that are overall most advantageous when compared to other
available providers and their services. We consider a wide range of factors, including, among
others, the following:
▪ combination of transaction execution services along with asset custody services
(generally without a separate fee for custody)
▪ capability to execute, clear, and settle trades (buy and sell securities for client accounts)
▪ capabilities to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
▪ breadth of investment products made available (stocks, bonds, mutual funds, exchange-
traded funds (ETFs), etc.)
▪ availability of investment research and tools that assist us in making investment
decisions
▪ quality of services
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Part 2A of Form ADV: Providence Wealth Brochure
Item 12: Brokerage Practices
▪ competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate them
▪
reputation, financial strength, and stability of the provider
▪
their prior service to us and our other clients
▪ availability of other products and services that benefit us, as discussed below
Client’s Custody and Brokerage Costs
For client accounts that the firm maintains, the custodian generally does not charge clients
separately for custody services but is compensated by charging commissions or other fees on
trades that it executes or that settle into the custodian’s accounts. The custodian’s commission
rates applicable to the firm’s client accounts were negotiated based on the firm’s commitment
to maintain a certain minimum amount of client assets at the custodian. This commitment
benefits the client because the overall commission rates paid are lower than they would be if
the firm had not made the commitment. In addition to commissions, the custodian charges a
flat dollar amount as a “prime broker” or “trade away” fee for each trade that the firm has
executed by a different broker-dealer but where the securities bought or the funds from the
securities sold are deposited (settled) into the client’s custodian account. These fees are in
addition to the commissions or other compensation the client pays the executing broker-
dealer. Because of this, in order to minimize the client’s trading costs, the firm has the
custodian execute most trades for the account.
Soft Dollar Arrangements
Providence Wealth does not utilize soft dollar arrangements. Providence Wealth does not
direct brokerage transactions to executing brokers for research and brokerage services.
Institutional Trading and Custody Services
Schwab provides Providence Wealth with access to its institutional trading and custody
services, which are typically not available to Schwab retail investors. These services are
generally available to independent investment advisors on an unsolicited basis, at no charge
to them so long as a certain minimum amount of the advisor’s clients’ assets are maintained in
accounts at Schwab. Schwab’s brokerage 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 that would require a significantly
higher minimum initial investment.
Other Products and Services
Schwab also makes available to Providence Wealth other products and services that benefit
Providence Wealth but may not directly benefit its clients’ accounts. Many of these products
and services may be used to service all or some substantial number of Providence Wealth's
accounts, including accounts not maintained at Schwab. Schwab also makes available to
Providence Wealth its managing and administering software and other technology that
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Part 2A of Form ADV: Providence Wealth Brochure
Item 12: Brokerage Practices
▪ provide access to client account data (such as trade confirmations and account
statements)
▪
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
▪ provide research, pricing and other market data
▪
facilitate payment of Providence Wealth’s fees from its clients’ accounts
▪ assist with back-office functions, recordkeeping and client reporting
Schwab also offers other services intended to help Providence Wealth manage and further
develop its business enterprise. These services may include
▪ compliance, legal and business consulting
▪ publications and conferences on practice management and business succession
▪ access to employee benefits providers, human capital consultants and insurance
providers
Schwab may also provide other benefits, such as educational events or occasional business
entertainment of Providence Wealth personnel. In evaluating whether to recommend that
clients custody their assets at Schwab, Providence Wealth may take into account the
availability of some of the foregoing products and services and other arrangements as part of
the total mix of factors it considers and not solely on the nature, cost or quality of custody and
brokerage services provided by Schwab, which may create a potential conflict of interest.
Independent Third Parties
Schwab may make available, arrange and/or pay third-party vendors for the types of services
rendered to Providence Wealth. Schwab may discount or waive fees it would otherwise charge
for some of these services or all or a part of the fees of a third party providing these services
to Providence Wealth.
Additional Compensation Received from Custodians
Providence Wealth may participate in institutional customer programs sponsored by broker-
dealers or custodians. Providence Wealth may recommend these broker-dealers or custodians
to clients for custody and brokerage services. There is no direct link between Providence
Wealth’s participation in such programs and the investment advice it gives to its clients,
although Providence Wealth receives economic benefits through its participation in the
programs that are typically not available to retail investors. These benefits may 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 Providence Wealth participants
▪ Access to block trading (which provides the ability to aggregate securities transactions
for execution and then allocate the appropriate shares to client accounts)
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Part 2A of Form ADV: Providence Wealth Brochure
Item 12: Brokerage Practices
▪ 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
▪ Discounts on compliance, marketing, research, technology, and practice management
products or services provided to Providence Wealth by third-party vendors
The custodian may also pay for business consulting and professional services received by
Providence Wealth’s related persons, and may pay or reimburse expenses (including client
transition expenses, travel, lodging, meals and entertainment expenses for Providence
Wealth’s personnel to attend conferences). Some of the products and services made available
by such custodian through its institutional customer programs may benefit Providence Wealth
but may not benefit its client accounts. These products or services may assist Providence
Wealth in managing and administering client accounts, including accounts not maintained at
the custodian as applicable. Other services made available through the programs are intended
to help Providence Wealth manage and further develop its business enterprise. The benefits
received by Providence Wealth or its personnel through participation in these programs do
not depend on the amount of brokerage transactions directed to the broker-dealer.
Providence Wealth also participates in similar institutional advisor programs offered by other
independent broker-dealers or trust companies, and its continued participation may require
Providence Wealth to maintain a predetermined level of assets at such firms. In connection
with its participation in such programs, Providence Wealth will typically receive benefits similar
to those listed above, including research, payments for business consulting and professional
services received by Providence Wealth’s related persons, and reimbursement of expenses
(including travel, lodging, meals and entertainment expenses for Providence Wealth’s
personnel to attend conferences sponsored by the broker-dealer or trust company).
As part of its fiduciary duties to clients, Providence Wealth endeavors at all times to put the
interests of its clients first. Clients should be aware, however, that the receipt of economic
benefits by Providence Wealth or its related persons in and of itself creates a potential conflict
of interest and may indirectly influence Providence Wealth’s recommendation of broker-
dealers such as Schwab for custody and brokerage services.
The Firm’s Interest in Schwab’s Services
The availability of these services from the custodian benefits the firm because the firm does
not have to produce or purchase them. The firm does not have to pay for the custodian’s
services so long as a certain minimum of client assets is kept in accounts at the custodian. This
minimum of client assets may give the firm an incentive to recommend that clients maintain
their accounts with the custodian based on the firm’s interest in receiving the custodian’s
services that benefit the firm’s business rather than based on the client’s interest in receiving
the best value in custody services and the most favorable execution of client transactions. This
is a potential conflict of interest. The firm believes, however, that the selection of the custodian
as custodian and broker is in the best interest of clients. It is primarily supported by the scope,
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Part 2A of Form ADV: Providence Wealth Brochure
Item 12: Brokerage Practices
quality, and price of the custodian’s services and not the custodian’s services that benefit only
the firm.
Brokerage for Client Referrals
Providence Wealth does not engage in the practice of directing brokerage commissions in
exchange for the referral of advisory clients.
Directed Brokerage
Providence Wealth Recommendations
Providence Wealth typically recommends Schwab as custodian for clients’ funds and securities
and to execute securities transactions on its clients’ behalf.
Client-Directed Brokerage
Occasionally, clients may direct Providence Wealth to use a particular broker-dealer to execute
portfolio transactions for their accounts or request that certain types of securities not be
purchased for their accounts. Clients who designate the use of a particular broker-dealer
should be aware that they will lose any possible advantage Providence Wealth derives from
aggregating transactions. Such client trades are typically effected after the trades of clients
who have not directed the use of a particular broker-dealer. Providence Wealth loses the
ability to aggregate trades with other Providence Wealth advisory clients, potentially
subjecting the client to inferior trade execution prices as well as higher commissions.
B. Aggregating Securities Transactions for Client Accounts
Best Execution
Providence Wealth, pursuant to the terms of its investment advisory agreement with clients, may
have discretionary authority to determine the nature and type of securities to be bought and
sold and the amount of such securities. Providence Wealth recognizes that the analysis of
execution quality involves a number of factors, both qualitative and quantitative. Providence
Wealth will follow a process in an attempt to ensure that it is seeking to obtain the most
favorable execution under the prevailing circumstances when placing client orders. These factors
include but are not limited to the following:
▪ The financial strength, reputation and stability of the broker
▪ The efficiency with which the transaction is effected
▪ The ability to effect prompt and reliable executions at favorable prices (including the
applicable dealer spread or commission, if any)
▪ The availability of the broker to stand ready to effect transactions of varying degrees of
difficulty in the future
▪ The efficiency of error resolution, clearance and settlement
▪ Block trading and positioning capabilities
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Part 2A of Form ADV: Providence Wealth Brochure
Item 12: Brokerage Practices
▪ Performance measurement
▪ Online access to computerized data regarding customer accounts
▪ Availability, comprehensiveness, and frequency of brokerage and research services
▪ Commission rates
▪ The economic benefit to the client
▪ Related matters involved in the receipt of brokerage services
Consistent with its fiduciary responsibilities, Providence Wealth seeks to ensure that clients
receive best execution with respect to clients’ transactions by blocking client trades to reduce
commissions and transaction costs. To the best of Providence Wealth’s knowledge, these
custodians provide high-quality execution, and Providence Wealth’s clients do not pay higher
transaction costs in return for such execution.
Commission rates and securities transaction fees charged to effect such transactions are
established by the client’s independent custodian and/or broker-dealer. Based upon its own
knowledge of the securities industry, Providence Wealth believes that such commission rates are
competitive within the securities industry. Lower commissions or better execution may be able
to be achieved elsewhere.
Security Allocation
Since Providence Wealth may be managing accounts with similar investment objectives, the firm
may aggregate orders for securities for such accounts. In such event, allocation of the securities
so purchased or sold, as well as expenses incurred in the transaction, is made by Providence
Wealth in the manner it considers to be the most equitable and consistent with its fiduciary
obligations to such accounts.
Providence Wealth’s allocation procedures seek to allocate investment opportunities among
clients in the fairest possible way, taking into account the clients’ best interests. Providence
Wealth will follow procedures to ensure that allocations do not involve a practice of favoring or
discriminating against any client or group of clients. Account performance is never a factor in
trade allocations.
Providence Wealth’s advice to certain clients and entities and the action of Providence Wealth
for those and other clients are frequently premised not only on the merits of a particular
investment but also on the suitability of that investment for the particular client in light of his or
her applicable investment objective, guidelines and circumstances. Thus, any action of
Providence Wealth with respect to a particular investment may, for a particular client, differ or
be opposed to the recommendation, advice or actions of Providence Wealth to or on behalf of
other clients.
Order Aggregation
Orders for the same security entered on behalf of more than one client may be aggregated
where necessary (i.e., blocked or bunched) subject to the aggregation being in the best interests
of all participating clients. Subsequent orders for the same security entered during the same
trading day may be aggregated with any previously unfilled orders. Subsequent orders may also
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Part 2A of Form ADV: Providence Wealth Brochure
Item 12: Brokerage Practices
be aggregated with filled orders if the market price for the security has not materially changed
and the aggregation does not cause any unintended duration exposure. All clients participating
in each aggregated order will receive the average price and, subject to minimum ticket charges
and possible step outs, pay a pro rata portion of commissions.
To minimize performance dispersion, “strategy” trades should be aggregated and average
priced. However, when a trade is to be executed for an individual account and the trade is not in
the best interests of other accounts, then the trade will only be performed for that account. This
is true even if Providence Wealth believes that a larger size block trade would lead to best
overall price for the security being transacted.
Allocation of Trades
All allocations will be made prior to the close of business on the trade date. In the event an
order is “partially filled,” the allocation will be made in the best interests of all the clients in the
order, taking into account all relevant factors including, but not limited to, the size of each
client’s allocation, clients’ liquidity needs and previous allocations. In most cases, accounts will
get a pro forma allocation based on the initial allocation. This policy also applies if an order is
“over-filled.”
Providence Wealth acts in accordance with its duty to seek best price and execution and will not
continue any arrangements if it determines that such arrangements are no longer in the best
interest of its clients.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 13: Review of Accounts
Item 13: Review of Accounts
A. Schedule for Periodic Review of Client Accounts or Financial Plans and
Advisory Persons Involved
Financial planning client accounts will be reviewed by their investment adviser representative in
accordance with the terms set forth in their investment advisory agreement. In the case of
investment services rendered to high-net-worth/affluent individuals, monitoring of clients'
accounts is conducted on a continual basis. Meetings with clients are conducted on an as-
needed basis, but not less than once per year. Such meetings may be conducted in person or by
telephone. Reviews are intended to assess the effect on the client, if any, of significant changes
in the national or global economy, in the market, or in the legal environment (e.g., with respect
to federal and state tax laws), and to revisit the client's goals and circumstances. In addition, a
review is conducted of the client's quarterly performance report including, and in particular, the
details concerning the client's investment objectives, goals, tolerance for risk, personal and
financial circumstances, and investment constraints and/or limitations imposed by such client.
Any changes in the client's goals and circumstances or investment constraints or limitations are
noted for any necessary adjustments to the client’s portfolio and for future advisory services
rendered to the client. Any of the foregoing factors may lead to changes in the client's asset
allocation target, mutual funds, separate account manager, or security holdings selected or
recommended to the client.
B. Review of Client Accounts on Non-Periodic Basis
Providence Wealth may perform ad hoc reviews on an as-needed basis if there have been
material changes in the client’s investment objectives or risk tolerance, or a material change in
how Providence Wealth formulates investment advice.
C. Content of Client-Provided Reports and Frequency
Reports of changes in the performance of a client's portfolio are provided to the client by
Providence Wealth on a quarterly basis (unless otherwise agreed to by client and Providence
Wealth). Clients that determine to implement Providence Wealth’s advice regarding income
generation techniques will receive monthly statements from the executing broker-dealer and/or
custodian selected by the client in connection with such strategy. Providence Wealth will review
client custodian statements with such clients on a quarterly basis, or more often as necessary.
The review will assess whether to continue or to discontinue the strategy, as well as possible
outcomes which could affect the client’s tax and estate situation.
Providence Wealth investment advisory clients also receive monthly account statements from
their custodian (no less frequently than quarterly). Clients are urged to compare the reports
issued by Providence Wealth against the reports issued by the custodian, and to notify
Providence Wealth of any discrepancies. The custodian’s report is the official record of the
client’s account.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 14: Client Referrals and Other Compensation
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided to the Advisory Firm from External Sources
and Conflicts of Interest
Other than as described in Items 10 and 12 of this Brochure, Providence Wealth does not receive
economic benefits from external sources.
B. Advisory Firm Payments for Client Referrals
The firm does not engage solicitors.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 15: Custody
Item 15: Custody
Providence Wealth is considered to have custody of client assets for purposes of the Advisers
Act for the following reasons:
▪ The client authorizes us to instruct their custodian to deduct our advisory fees directly
from the client’s account. The custodian maintains actual custody of clients’ assets.
▪ Our authority to direct client requests, utilizing standing instructions, for wire transfer of
funds for first-party money movement and third-party money movement (checks and/or
journals, ACH, Fed-wires). The firm has elected to engage an independent public
accountant to annually conduct a surprise custody exam audit.
Individual advisory clients will receive at least quarterly account statements directly from their
custodian containing a description of all activity, cash balances, and portfolio holdings in their
accounts. Clients are urged to compare the account balance(s) shown on their account
statements to the quarter-end balance(s) on their custodian's monthly statement. The
custodian’s statement is the official record of the account. Private fund investors will receive
fund level statements of all activity, cash balances, and portfolio holdings on a quarterly basis
from their qualified custodian.
Providence Wealth’s parent, Providence Bank & Trust Company, serves as corporate trustee for
several of Providence Wealth’s investment advisory clients. As a result, Providence Wealth is
deemed to have custody of those assets and is required to undergo an annual surprise custody
audit.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 16: Investment Discretion
Item 16: Investment Discretion
Clients may grant a limited power of attorney to Providence Wealth with respect to trading
activity in their accounts by signing the appropriate custodian limited power of attorney form. In
such cases, Providence Wealth will exercise full discretion as to the nature and type of securities
to be purchased and sold and the amount of securities for such transactions. Investment
limitations may be designated by the client as outlined in the investment advisory agreement.
In addition, subject to the terms of its investment advisory agreement, Providence Wealth may
be granted discretionary authority for the retention of independent third-party investment
managers. Under such terms, the firm would also exercise discretion as to the executing broker
to be used for securities transactions and the amount of commissions to be paid.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 17: Voting Client Securities
Item 17: Voting Client Securities
Providence Wealth, as a Securities and Exchange Commission registered investment adviser,
often has voting power with respect to securities in client accounts. As such, Providence Wealth
owes certain fiduciary duties with respect to the voting of proxies. These fiduciary duties include
(i) the duty of care, which requires Providence Wealth to monitor corporate events and to vote
the proxies; and (ii) the duty of loyalty, which requires Providence Wealth to vote proxies in a
manner consistent with the best interests of the client and to put the client's interests before the
firm's own interests. In keeping with its fiduciary duties, Providence Wealth has adopted a Proxy
Voting Policy, which sets forth the firm's policies and procedures designed to ensure that it
votes each client's securities in the best interests of the client.
Providence Wealth will be authorized to take action and render any advice with respect to the
voting of proxies for securities held in the client’s account. Providence Wealth will make an
independent valuation for each applicable company held in the client’s account in accordance
with its fiduciary obligations as detailed in this policy. Clients may contact Providence Wealth’s
Managing Member for information about how Providence Wealth voted with respect to any of
the securities held in their accounts.
Except as required by applicable law, Providence Wealth will not be obligated to render advice
or take any action on behalf of clients with respect to assets presently or formerly held in their
accounts that become the subject of any legal proceedings, including bankruptcies.
As a general rule, Providence Wealth will vote all proxies relating to a particular proposal the
same way for all client accounts holding the security in accordance with Providence Wealth’s
Proxy Voting Policy, unless a client specifically instructs in writing to vote such client's securities
otherwise. When making proxy voting decisions, Providence Wealth may seek advice or
assistance from third-party consultants, such as proxy voting services or legal counsel.
A copy of Providence Wealth’s Proxy Voting Policy will be provided upon receipt of a written
request to the firm.
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Part 2A of Form ADV: Providence Wealth Brochure
Item 18: Financial Information
Item 18: Financial Information
A. Balance Sheet
Providence Wealth does not require the prepayment of fees of $1,200 or more, six months or
more in advance, and as such is not required to file a balance sheet.
B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability
to Meet Commitments to Clients
Providence Wealth does not have any financial issues that would impair its ability to provide
services to clients.
C. Bankruptcy Petitions During the Past Ten Years
There are no bankruptcy petitions to report.
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Part 2A of Form ADV: Providence Wealth Brochure