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ITEM 1 – COVER PAGE
FORM ADV PART 2A
DISCLOSURE BROCHURE
JANUARY 15, 2026
CRD#: 148816
SEC#: 801-70555
1984 Isaac Newton Square W.
Suite 107
Reston, VA 20190
This Disclosure Brochure provides information about the qualifications and
business practices of Reston Wealth Management LLC. If you have any
questions about the contents of this Disclosure Brochure, please contact us;
our contact information is listed to the right. Additional information about
Reston Wealth Management, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Tel: (703) 481-2280
Fax: (703) 935-6402
www.restonwealth.com
The information contained in this Disclosure Brochure has not been
approved or verified by the United States Securities and Exchange
Commission or by any State Securities Administrator. Furthermore, the
term “registered investment advisor” is not intended to imply that Reston
Wealth Management, LLC has attained a certain level of skill or training.
FORM ADV PART 2A: DISCLOSURE BROCHURE
ITEM 2 – MATERIAL CHANGES
While there are no material changes to report since the annual update filing on March 26, 2025, this Disclosure Brochure has
been reformatted and rewritten to provide clearer, more detailed information about our advisory practice. This Disclosure Brochure
has also been amended since that time to reflect that Robert E. Tucker has assumed the role of Chief Compliance Officer.
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ITEM 3 – TABLE OF CONTENTS
Item 2 – Material Changes ............................................................................................................................................ 2
Item 3 – Table of Contents ............................................................................................................................................ 3
Item 4 – Advisory Business ........................................................................................................................................... 4
Item 5 – Fees & Compensation .................................................................................................................................... 7
Item 6 – Performance-Based Fees & Side-By-Side Management ............................................................................... 9
Item 7 – Types of Clients .............................................................................................................................................. 9
Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss ........................................................................... 9
Item 9– Disciplinary Information.................................................................................................................................. 10
Item 10– Other Financial Industry Activities & Affiliations ........................................................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions & Personal Trading .................................. 11
Item 12 – Brokerage Practices.................................................................................................................................... 12
Item 13 – Review of Accounts..................................................................................................................................... 13
Item 14 – Client Referrals & Other Compensation ..................................................................................................... 13
Item 15 – custody ........................................................................................................................................................ 14
Item 16 – Investment Discretion ................................................................................................................................. 14
Item 17 – Voting Client Securities ............................................................................................................................... 14
Item 18 – Financial Information................................................................................................................................... 15
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ITEM 4 – ADVISORY BUSINESS
Who We Are
Reston Wealth Management, LLC1 (hereinafter referred to as “the Firm”, “we”, “us,” and “our”) is a fee-based registered
investment advisor offering a wide range of financial services2 designed to assist you, our client, achieve the financial stability,
security, and independence you desire.
The following persons own and control the Firm:
Name
Title
CRD#
Robert E. Tucker III
Managing Member & Chief Compliance Officer
1610751
Alexander C. Voorhees
Partner
6153993
Our mission is to foster a lasting relationship with you, founded on mutual trust, concern, respect, and to honor God in all we do.
Together we will come alongside you . . . to hold in trust your financial future as if it were our own . . . to be the resource you turn
to for clear, objective, and sound investment advice . . . to guide you as we explore what you value to ultimately set a course to
pursue tomorrow’s dreams, and a strategy to build a lasting legacy for future generations.
We will do our best to keep you focused on where you want to go, offer advice on how best to get there, and continually remind
you of the importance of maintaining a disciplined financial strategy to realize your dreams.
Assets Under Management
As of December 31, 2024, our assets under management were as follows:
Discretionary Accounts:
$464,195,744
Non-Discretionary Accounts:
$12,900,564
What We Do
We provide wealth services that stress the importance of you making fiscally responsible decisions and disciplined economic
choices in your personal life, so we can effectively help you achieve your monetary goals.
The focus of our advice begins with identifying your standards of living and quality of lifestyle expectations. We will accomplish
this through an initial Discovery Meeting, where we will review the financial documents we asked you to bring for discussion.
Together, questions will be asked, information shared, and an evaluation made as to whether we should move to the next step.
During our meeting(s), we will:
Learn about your core values and guiding principles
Seek to understand your financial concerns and how you have been addressing them
Discover your financial objectives and what success looks like for you
Create an internal profile consisting of your concerns, objectives, relationships, values, interests, assets, professional
advisors, and process preferences
Moving forward from the Discovery Meeting, should you choose to engage us for our wealth services, we will begin the process
of identifying your life goals (i.e., core values, family, monetary needs, future plans, etc.). Our services include:
Account Management Services
Our account management services focus on designing and managing a diversified allocation of Investment Company (“mutual
funds”) products, Exchange-Traded Funds (“ETFs”), along with the occasional mix of equity (“stock”) positions and fixed-
income/debt (“bond”) instruments, and third-party money managers to pursue a return on your investment capital consistent with
your objectives3.
Third Party Money Manager (TPM) Services
We may recommend that you use the services of a third-party money manager (“TPM”) to manage a portion of your account.
Factors that we take into consideration when making our recommendation include, but are not limited to, the following: the TPM’s
performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will
1 Reston Wealth Management, LLC was organized as a Limited Liability Company in the Commonwealth of Virginia in 2003.
2 Reston Wealth Management, LLC is a fiduciary, as defined within the meaning of the Employer Retirement Income Security Act of 1974 (“ERISA”) or as defined
under the Internal Revenue Code of 1986 (the “Code”) for any financial services provided to a client who is: (i) a plan participant or beneficiary of a retirement plan
subject to ERISA or as described under the Code; or, (ii) the beneficial owner of an Individual Retirement Account (“IRA”).
3 You may, at any time, impose restrictions in writing on the securities we may recommend (i.e., limit the types/amounts of particular securities purchased for your
account, etc.).
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monitor the money manager’s performance to ensure its management and investment style remain aligned with your investment
goals and objectives.
The TPM will actively manage your account and will assume discretionary investment authority over a portion of your account. We
will assume discretionary authority to hire and fire the TPM and/or reallocate your assets to other TPMs where we deem such
action appropriate.
Information regarding our management fee structure is disclosed under “Account Management Fee” in Item 5 - Fees &
Compensation, and further description of our investment strategies under Item 8 - Methods of Analysis, Investment Strategies &
Risk of Loss.
Wealth Planning
Wealth planning is an essential tool to help navigate unexpected events with the ultimate goal of providing the confidence and
security necessary during both the working years (wealth accumulation) and retirement years (wealth distribution) of your life.
However, such planning requires a lifetime commitment, not only from you but from us as well, your Wealth Advisor.
What is a Wealth Plan?
Wealth planning is an evaluation of the investment and financial options available to you based upon your defined life goals and
choices. A well-designed plan is a step-by-step process intended to identify and clarify purpose, personal and family core values,
needs, and priorities to align your financial decisions with your goals in all areas of your life and business. Planning includes:
Arriving at a series of decisions and action items based on current and future financial circumstances and defined goals
and objectives;
Projecting the consequences of these decisions for you in the form of an economic plan – a working blueprint;
and,
Implementing the protocols outlined in the plan to achieve the plan's objectives.
Once complete, the wealth plan, or working blueprint, becomes the benchmark that is used to help us evaluate where you are in
achieving your financial goals, needs, and objectives.
Wealth Planning Composition
All forms of wealth planning are a mutually defined review, analysis and evaluation of your personal financial needs and goals. In
general, our wealth planning may encompass one or more of the following areas of financial need as communicated by you:
Identify and clarify personal and family core values, mission, vision, and goals.
Preparation of the wealth plan, which encompasses your:
Liquidity and asset preservation needs
o Current financial situation
o
o Wealth accumulation and growth
o Wealth distribution and transfer
More specifically planning may include, but is not limited to, the following modules:
o Financial Statements – Cash Flow and Balance Sheet
o Savings and Emergency Reserves
o Asset Allocation and Investment Portfolio Analysis
o Potential Income Tax consequences in collaboration with your tax advisor
o Risk Management and Insurance Analysis
o
529 College Education Plans
o Retirement Income Analysis
o
Long-Term Healthcare
o Estate and Family Legacy Planning in collaboration with your estate attorney
o Business Succession Planning
Outline of recommendations, strategies, solutions and resources
Prioritizing and implementing the written action plan
Investment consultations that allow us to create and implement a customized investment strategy tailored to your long-
term investment goals
Facilitate meetings with you and/or other specialists within our network
Coordinate and facilitate meetings with family members, business associates, partners or other key individuals to assist
with implementing your action plan
Preparing the Wealth Plan
In the development of your unique plan we will follow the six (6) step Financial Planning Practice Standards process established
by the Certified Financial Planner Board of Standards, Inc. These steps are defined as follows:
Step 1: Establish and define a mutual relationship.
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The first step is to conduct an introductory Discovery Meeting. During this meeting, we will learn about each other and
whether we can work together to achieve your financial objectives. We will listen as you share your needs, concerns,
priorities, and what success looks like for you. We will in-turn, share how we can help you meet your stated personal and
financial objectives, and the responsibilities we have as a fiduciary to guide you on this journey.
In the end, we will explain the cost of completing the desired wealth planning service for you to decide whether you want to
move forward with the next step in the planning process.
Step 2: Gathering data and determining goals and objectives.
In the second step of the planning process, we learn about you and what you want to achieve. This is accomplished through
personal interviews and questionnaires4, which are designed to address your unique wealth planning needs. You will have
the opportunity to prioritize objectives and to remove from the process any areas that are not applicable to your
circumstances. The time we invest listening and catering to your wants and needs is critical for developing a strong wealth
planning foundation.
Step 3: Analyze and evaluate your financial status.
In this third step, we analyze the information you provided to determine your current financial situation and what you should
do to meet your goals. Depending on the services you requested, this might include analyzing: (i) your assets, liabilities and
cash flow; (ii) your current insurance coverage and investments; and, (iii) your tax strategies and estate planning documents.
Step 4: Develop and present wealth planning recommendations and/or alternatives.
Once the analysis has been completed, we begin formally documenting your goals and objectives. We define the plan as a
road map (a series of blueprints) designed to take you from where you currently are financially, to where you want to be at
some point in the future. This is the creative portion of the process.
There are usually several ways to accomplish a given goal. The objective, however, is to integrate financial instruments and
strategies into a plan that you will be comfortable executing. In some cases, the drafting of the plan reveals the need for us
to help you reconcile the gap between your expectations and your financial realities. Once a viable plan has been drafted,
it is presented to you and reviewed. The draft and review process may be repeated until you are satisfied with the wealth
plan or the scope of work has been completed.
There may be additional costs for you to implement your plan under steps 5 and 6. You have the choice to allow us to
implement your wealth plan, or you can use another outside professional.
Step 5: Implement the planning recommendations.
A wealth plan is of limited value if it is not put into action. Accordingly, we assist you with implementing5 the plan. The action
plan schedule provides you with a list of tasks and deadlines designed to ensure that you put your plan into action. The
following are some examples of implementation:
Drafting of appropriate estate documents (performed in conjunction with an estate attorney).
Purchase of various insurance policies (provided by our licensed insurance agents or another independent
insurance agent of your choice).
Investment advisory services and implementation of your asset allocation strategy (performed by us, or another
investment adviser/broker-dealer of your choice).
Ongoing income tax planning (performed in conjunction with an independent Certified Public Accountant or tax
accountant).
Step 6: Monitor the planning recommendations.
Once the plan has been built and the recommendations have been implemented, it is critical that these recommendations
be monitored on a continuing basis to ensure that they remain consistent with your financial parameters. Material changes
in your personal circumstances, the general economy, changes in the way you want your investments allocated, or tax law
changes are some of the reasons why the recommendations should be reviewed periodically and possibly adjusted.
For information on our fees for wealth planning, see “Wealth Planning Fees” under Item 5 - Fees & Compensation.
4 The information we gather from you through personal interviews and questionnaires is vital for us to effectively advise you on your unique financial needs and help
you plan for your future. Electing to dismiss certain requested documents or respond to questions with limited input can put us at a disadvantage and handicap our
ability to successfully meet your financial expectations. Therefore, if you want the best advice we can offer in designing a wealth plan or with any account management,
you should make every effort to provide us with detailed personal information and be as accurate with your responses as you possibly can.
5 Implementing the recommendations made in a wealth plan often requires consultation or coordination with one or more outside professionals (e.g. attorneys, CPAs,
insurance agents, and securities representatives). All personal and private information received from you will be kept entirely confidential, not only by us, but by the
outside professionals as well. Your confidential information will be disclosed to third parties only with your consent or as may be permitted or required by law.
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ITEM 5 – FEES & COMPENSATION
Account Management Fees
Account management services are offered on an asset-based, tiered fee schedule. Depending on your account’s custodian, the
management fee is billed either in advance or in arrears. The fee is calculated using the market value of your account - including
investments/securities, cash, and cash equivalents - on the last business day of the previous calendar quarter (March 31, June
30, September 30, and December 31), as reported by the account’s custodian, multiplied by one-fourth the corresponding annual
percentage rate (e.g., 1.00% ÷ 4 = 0.25%) for each portion of your account assets that fall within each tier. Our tiered fee schedule
for managed accounts is as follows:
Account Value
Annual Fee
Rate
Not to Exceed
1.25%
First $500,000
1.20%
1.10%
0.95%
0.80%
Next $500,000
.................................................
Next $1,000,000
..............................................
Next $3,000,000
..............................................
Over $5,000,000
..............................................
For managed accounts opened between billing periods, our fee will be prorated from inception through the end of the quarterly
billing period.
Our management fees will be withdrawn from your account quarterly by the custodian following our instructions. These fees will
be taken first from any money market funds or cash balances. If these assets are insufficient to cover the fees, a portion of the
account assets will be liquidated to cover the fees.
Unless otherwise agreed to in writing, we will combine the account values of family members living in the same household to
determine the applicable management fee. For example, we will combine the value of your managed account(s) with the values
of managed accounts held by your spouse or partner and dependent children. Combining account values may increase the
managed assets total, which could result in a reduced management fee based on the breakpoints in our tiered fee schedule.
At our discretion, we reserve the right to negotiate, waive, or reduce the management fee within each tier on a per-client basis,
depending on the size and complexity of the account managed. Pre-existing advisory clients are subject to our minimum account
requirements and advisory fee arrangements in effect at the time the client entered into the advisory relationship. Therefore, some
clients may be subject to a more favorable fee schedule than the one shown above.
Cash Balances
Cash is considered to be an asset class and is included in our fee calculations. At times, our fees will exceed the money
market yield on the cash balance of your account. When this happens, the advisory fee will be higher than the interest a
client will earn on their cash balance or the return earned on money market funds.
Deposits & Withdrawals
For new managed accounts opened mid-quarter, our fee will be a prorated calculation of your assets to be managed for the
current calendar quarter. For existing management accounts (except for annuity accounts), pro-rated adjustments will be
made for partial deposits and/or withdrawals between billing cycles.
Fee Exclusions
The fees for our account management services do not include any charges imposed by the custodian holding your account.
This includes, but is not limited to: (i) any exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges such
as postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot
differentials, and mutual fund short-term redemption fees; and (iv) brokerage and execution costs related to securities in your
managed account. Other fees may be charged to your account that are not related to our management services.
In addition to our management fee, you will also pay all mutual fund and ETF charges that are directly imposed by the mutual
funds and ETFs. These expenses include management fees, and, if applicable, 12b-1 fees, redemption fees, contingent
deferred sales charges, and other related fees. A detailed explanation of these costs imposed by the mutual funds and ETFs
can be found in each mutual fund’s or ETF’s prospectus. You are encouraged to review these prospectuses carefully.
For more information about the custodian we recommend for holding your managed accounts, please see Item 12 - Brokerage
Practices.
Third Party Manager (TPM) Fees
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For any portion of your account managed by a TPM, our management fee schedule and billing practices, as previously outlined,
may not be applicable. Detailed information regarding the TPM’s management services, fee schedules, billing procedures, our
fee-sharing arrangements with the TPM, and other relevant details will be furnished to you prior to engaging the TPM to oversee
your account. Please be advised that the TPM’s management fees are determined by the TPM, which may be incorporated with
or in addition to our fees and may be billed either in advance or arrears. The TPM’s Form ADV Part 2A: Disclosure Brochure, a
copy of which will be provided to you before the engagement, contains all necessary disclosures concerning their management
services, fee structure, and termination provisions. You are strongly encouraged to review the TPM’s Disclosure Brochure
thoroughly.
When using TPMs to manage all or part of your account, we receive compensation through a fee-sharing agreement with the
TPM. Since these fee-sharing arrangements can differ among TPMs, there is an incentive for us to choose TPMs based on a
higher fee share rather than your best interest. To address and manage this conflict of interest, our policy is to select TPMs based
on your goals and objectives.
Please note that the fee schedules among TPMs will vary and may be higher or lower than our fee schedule. Therefore, client
accounts managed by a TPM may incur fees that are either higher or lower than those managed solely by us.
Termination of Account Management Services
You may terminate your Investment Advisory Agreement with us within 5 business days of signing the agreement without
penalty. After that, either party may cancel the agreement at any time by providing written notice to the other party. This notice
should specify the date when the termination will take effect and may include final instructions for the account, such as
liquidate the account, complete all transactions, or stop all investment activity.
If termination does not occur at the end of a calendar quarter, accounts billed in advance will receive a prorated refund based
on the remaining days of the billing period. Refunds are issued by direct deposit to your investment account, by check to your
address of record, or electronic funds transfer. Accounts billed in arrears will be charged a prorated amount based on the
number of days the account was managed during that period. If your account is managed by a TPM, please refer to the
termination policies set forth in the TPM’s ADV Part 2A: Firm Brochure.
Wealth Planning Fee
In addition to the account management fee, you may also be charged a wealth planning fee. Wealth planning fees are usually
waived if we manage over $1,000,000 of your portfolio account(s). If assets in your managed account(s) are less than
$1,000,000, the following billing arrangements are applicable, depending on the service you desire and the complexity of the
wealth plan we design.
Wealth planning is a mutually defined planning project offered for a negotiable fixed fee not to exceed $20,000 annually,
billed on a quarterly basis. The fee will be fully disclosed in a Wealth Planning Agreement, which will include the cost6 to review
your financial information and prepare the comprehensive wealth plan.
It is important to note that any planning is dynamic – never static. It therefore must be periodically re-evaluated. A wealth plan is a
roadmap that is only as good as how well it reflects your current financial position, to then guide you on a clear path to a future
financial destination. Changing circumstances in your life often necessitate periodic reviews designed to systematically address
these unexpected diversions and continually keep you on the right road towards your future financial destination.
Once the initial wealth plan has been completed, we will establish future “Review” dates if you choose to continue as a wealth
planning client. The Reviews generally occur after each one-year anniversary and will be used to review and make adjustments,
if necessary, to the wealth plan. Together, we will set the calendar dates for your future reviews; inasmuch as a Review may consist
of three or four reviews during the calendar year.
If we are not managing your investment account and you want us to review your wealth plan, we will notify you of the cost to
perform the desired work before commencing with any planning.
Termination of Wealth Planning Services
You can terminate the Wealth Planning Agreement at any time prior to the presentation of any final planning documents. We
will be compensated through the date of termination for time spent designing such financial documents at an agreed upon
hourly rate. If you have prepaid any fees, such unearned fees will be returned on a pro-rata basis. Once the wealth plan has
been completed and presented to you, termination of the Wealth Planning Agreement is no longer an option.
529 College Savings Plan Administrative Fee
We do not charge an account management fee for 529 college savings plan accounts. Instead, we impose an annual
administration fee to manage each beneficiary’s college savings plan account. The account balance on the last trading day of
June each year determines this administration fee.
6 Rarely will a fee exceed those costs outlined in the Agreement. However, there can be instances where we did not contract with you to perform a particular task and
therefore merits notifying you of the additional cost prior to beginning such services.
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Account Value
Annual Administration Fee
Per Beneficiary
$25
Below $5,000
$50
$100
$5,000 - $10,000
.................................................
Over $10,000
The maximum fee per family is $250.
This administration fee is not prorated, and you are expected to pay it annually in arrears by check. The fee is separate from the
charges by the 529 plan itself. Please review each plan’s prospectus to understand the fees and expenses for your specific plan.
Other than the management fees listed in Item 5 - Fees & Compensation, we do not charge you any additional fees.
ITEM 6 – PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
We do not charge fees based on a share of capital gains or the capital appreciation of the assets held in your accounts.
ITEM 7 – TYPES OF CLIENTS
We primarily offer financial services to individuals and their families. We may also advise foundations, charitable organizations,
corporations, small businesses, trusts, guardianships, estates, or other entities we choose to advise.
We generally require a minimum initial investment of $1,000,000 to open or maintain a managed account with us. We retain the
right to waive or reduce this minimum if we feel circumstances are warranted.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS
Our account management services are designed to build, manage, and preserve wealth while maintaining risk levels acceptable
to you. We combine your financial needs, investment objectives, time horizon, and risk tolerance to develop an effective investment
strategy.
Methods of Analysis
Fundamental Analysis
Fundamental analysis considers: efficiency ratios, growth rates, enterprise value, economic conditions, earnings, cash flow,
book value projections, industry outlook, politics (as it relates to investments), historical data, price-earnings ratios, dividends,
overall interest rate levels, company management, debt ratios, and tax benefits.
Fundamental analysis focuses on the long-term financial structure and overall health of a company, which may have limited
relevance to current market conditions. Investing in companies with robust financial data and a history of consistent returns
can be a prudent long-term strategy for portfolio inclusion; however, such fundamental indicators do not necessarily
correspond to the stock's market trading value. In the short term, the stock's value may decline. Additionally, the risks of
fundamental analysis may include incomplete or inaccurate information, unexpected market reactions, and the inability to
predict future events or changes in market sentiment accurately. Economic, political, or industry shifts can also undermine
the validity of fundamental assessments.
Fundamental analysis offers a comprehensive long-term perspective on a security, starting with the assessment of a
company’s value and the robustness of its financial position.
Investment Strategies
A Portfolio Built Uniquely for You
We believe in investing in a way that balances your long-term growth needs with short-term stability. We don’t believe in
timing the market. Instead, we create a financial plan tailored to your goals and then allocate your investments accordingly.
How We Manage Client Investments
Tailored to you
Globally diversified
Utilizing Institutional research
Low transparent fees
Tax-efficient
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We invest your portfolio based on your unique goals and risk tolerance, primarily with low-cost funds. Using our investment
philosophy as a baseline, we choose a mixture of stocks, bonds, ETFs, mutual funds, and alternative investments, with a
focus on lower expense ratios.
Our Process
Start With a Strong Foundation for Success
We begin by outlining a plan to achieve your goals. We design a portfolio that gives you the highest probability of reaching
them.
Distinct Portfolio Strategy
We invest in a globally diversified portfolio and rebalance when it deviates significantly from its target.
Long-term Perspective
We believe in a long-term strategic asset allocation that is revised annually based on 10+year projections by Fidelity,
Schwab, and other Institutional money managers.
Lower Cost Investments
We attempt to control taxes and fees by investing predominantly in low-cost, tax-efficient investments, such as ETFs and
index funds.
Rebalance Regularly
We are emotional beings, but your investment plan must promote logical decision-making, such as rebalancing when
market volatility is high.
Managing Risks
The biggest risk to you is the chance that your account’s value will decline due to market movements. This risk is known as market
risk, also called variability or volatility risk. Other significant risk factors generally include:
Interest Rate Risk – Interest rate risk impacts bond values more than stocks. Essentially, when interest rates rise, bond
prices fall; when interest rates decline, bond prices increase.
Equity Risk – Equity risk is the chance that your stocks will decrease in value due to stock market fluctuations, potentially
leading to a loss of money.
Currency Risk – Currency risk is the risk that results from fluctuations in the value of one currency compared to another.
Investment values in international securities can be influenced by changes in exchange rates.
Inflation Risk – The decrease in the purchasing power of investments over time.
Commodity Risk – Commodity risk refers to the uncertainties of future market values and the potential variation in future
income caused by fluctuations in commodity prices (such as grains, metals, food, electricity, etc.).
Liquidity Risk – A financial risk where a company is unable to meet short-term financial obligations without selling either
hard assets or finding another way to reduce the discrepancy between cash flow and debt obligations.
Foreign Securities Risk - Foreign securities come with risks not typically found in domestic investments, such as
currency fluctuations, political instability, economic turmoil, trade restrictions, and weaker regulation. They may also face
limited market liquidity, less transparency, and greater volatility.
Alternative Investment Risk - Alternative Investments are generally considered investments in asset classes that do
not fall into a conventional investment category, such as stocks, bonds, or cash. Because alternative investments are
illiquid investments, with no guarantee of returns, distributions, or interest payments, they are intended for investors who
meet the accredited investor or qualified purchaser standards and are willing to bear the high degree of various risks
associated with the investments.
The risk factors identified herein are not intended to be an exhaustive list but rather the most prevalent risks that your account
may encounter. Additional risks not explicitly outlined may include political instability, over-concentration, and liquidity concerns,
among others. Nevertheless, notwithstanding these risk factors, it is imperative that you comprehend that, regardless of the
analytical methods or investment strategies employed in managing your account, investing in securities involves a risk of loss that
you should be prepared to bear. Furthermore, it is important to note that past market performance does not guarantee similar or
superior future returns on your investments.
ITEM 9– DISCIPLINARY INFORMATION
We have no legal or disciplinary events to report.
ITEM 10– OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS
Independent Insurance Agents
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Certain of our Investment Adviser Representatives (“IARs”) are licensed insurance agents and will, from time to time, sell
insurance-related products, earning commissions from these sales. Although the Firm does not sell insurance products, the IARs,
in their individual capacity as licensed insurance agents, are authorized to offer insurance products to the Firm’s clients. A conflict
of interest arises when an IAR recommends insurance products and receives commissions from the Firm’s clients. Any such
conflict is fully disclosed to the client. Before accepting their recommendation to purchase an insurance product, you are
encouraged to consider other options to ensure that the insurance is comparable or equivalent to products offered by other
independent firms or agents.
Nevertheless, should you choose to proceed with the purchase of the insurance, regardless of the provider, such individual shall
be entitled to receive a commission.
Apart from the financial activities and arrangements disclosed above, there are no other financial industry affiliations, relationships,
or arrangements with security issuers to disclose.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING
Code of Ethics
As a fiduciary, we have an affirmative duty to provide continuous, unbiased investment advice and always act in your best interest.
To uphold this ethical responsibility, we have adopted a Code of Ethics that sets forth the fundamental principles of conduct and
professionalism expected from all personnel in performing their duties. This Code of Ethics serves as a value-driven guide that
obligates individuals to uphold the highest ethical standards, based on the simplest maxim. Our Code of Ethics is designed to
discourage inappropriate behavior and increase awareness of what is right, fair, just, and good by promoting:
honest and ethical conduct;
full, fair, and accurate disclosure;
compliance with applicable rules and regulations;
reporting of any violation of the Code of Ethics; and
accountability.
To help you understand our ethical culture and standards, how we manage sensitive information, and what steps have been taken
to prevent personnel from abusing their positions with the Firm, a copy of our Code of Ethics is available for review upon request.
Client Transactions
We have a fiduciary duty to ensure that your welfare is not subordinated to any interests of ours. The following disclosures are
internal guidelines we have adopted to help us protect all our clients.
Participation or Interest
It is against our policies for any owners, officers, directors, and employees to invest with you or with a group of clients, or to
advise you or a group of clients to invest in a private business interest or other non-marketable investment unless pre-
approved by our Chief Compliance Officer and such investment is not in violation of any SEC and/or State rules and
regulations.
Insider Trading Policy
We have implemented an Insider Trading Policy to prevent misuse of material non-public information by our Firm and
employees, whether for client or personal gain. Employees must not disclose or act on such information, as defined by
securities laws and our policy. This applies to all employees, both in professional and personal activities.
Personal Trading
Employees can invest in securities, which they may occasionally recommend to you. These investments are often made
independently of decisions made for you, but sometimes employees’ purchases may occur at the same time as your transactions.
This can create a conflict of interest, as employees could benefit from those trades. To preserve fiduciary integrity, we adhere to
the following guidelines:
No employee acting as an Investment Advisor Representative (“IAR”), or who has discretion over your account, shall buy
or sell securities for their personal account(s) where their decision is substantially derived, in whole or in part, by reason
of their employment, unless the information is also available to the investing public through reasonable inquiry. No
employee of ours shall favor their own interests over those of you or any other advisory client.
Our Chief Compliance Officer or a designated supervisor regularly reviews securities holdings for employees with access
to certain trade information.
We require all employees to comply with all applicable federal and state regulations governing registered investment
advisory practices.
Bunched orders (see “Aggregating Trade Orders” below under Item 12 - Brokerage Practices) may include employee
accounts. In such cases, all client and employee accounts will share an average share price, and any transaction costs
will be divided equally, on a pro rata basis. If a bunched trade is not fully filled, shares will be allocated fairly and equitably.
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Any individual who fails to comply with the above may be terminated.
Our Chief Compliance Officer oversees employee trading activities in relation to client trading to ensure employees do not
participate in inappropriate transactions.
ITEM 12 – BROKERAGE PRACTICES
Custodial Services
We typically require that you establish your account with one of the following qualified custodians:
Charles Schwab & Company, Inc. (“Schwab”)
Fidelity Brokerage Services, LLC and its affiliate National Financial Services, LLC (“Fidelity”)
Interactive Brokers LLC (“IB”)
Schwab, Fidelity, and IB (collectively, the “Custodians”) offer us services that include custody of securities, trade execution,
clearance, and settlement of transactions.
Our recommendation for you to custody your assets with one of the Custodians has no direct correlation to the services we receive
and the investment advice we offer you, although we do receive economic benefits for which we do not have to pay through our
relationship with these institutions that are typically not available to retail clients. This creates an incentive for us to recommend
Schwab, Fidelity, or IB based on the economic benefits we receive rather than on your interest in receiving most favorable
execution. These economic benefits include the following products and services provided without cost or at a discount:
Receipt of duplicate client statements and confirmations;
Research related products, tools, and consulting services;
Access to a dedicated trading desk;
Access to batch trading (which provides the ability to aggregate securities transactions for execution and then allocate
the appropriate shares to accounts);
The ability to have advisory fees deducted directly from accounts;
Access to an electronic communications network for order entry and account information; and,
Access to mutual funds and ETFs with no transaction fees and to certain institutional money managers.
The advisory support services we receive from the Custodians provide an economic benefit to us and could create a potential
conflict of interest for you because our recommendation to custody your account with Schwab, Fidelity, or IB might be influenced
by these arrangements or services. However, this is not the case. We have a fiduciary duty to prioritize your interests above our
own. We chose the Custodians as our qualified custodians based on:
1. Their competitive transaction fees, trading platform, and online services for account management and operational
support.
2. Their overall reputation, trading capabilities, investment holdings, financial strength, and our personal experience working
with their back-office staff.
Since we do not recommend or suggest custodians or broker-dealers other than the Custodians, best execution may not always
be achieved, which could cost you more money. Therefore, you are not required to accept our recommendation to use the
Custodians as your custodian or broker-dealer. Not all investment advisors direct clients to specific custodians or broker-dealers.
If you choose to direct us to use another custodian or broker-dealer, we may not be able to provide you with full institutional
services, and such services might cost you more in transaction fees.
We are not a subsidiary or affiliated entity of the Custodians. We have sole responsibility for the investment advice we provide,
and our wealth services are given separately and independently from the Custodians.
Aggregating Trade Orders
Our goal in order execution is to act fairly, impartially, and to take all reasonable steps to achieve the best possible results (known
as “best execution”) for our clients. Therefore, we may aggregate orders for a block trade when: (i) the aggregation of orders is
done to achieve best execution; and (ii) no client is systematically advantaged or disadvantaged by grouping the orders.
In consideration of these objectives, we will consider the unique execution factors of the buy/sell order before aggregating accounts
for a block trade. Some of these factors include:
Security Trading Volume – Bunching orders in a block trade can secure price parity and continuity for our clients during
heavy trading activity.
Number of Clients – The fewer the number of client accounts involved in the bunched order, the less likely it is that it
will yield better pricing or order execution; it may be more advantageous to perform an individual market order for each
client. In addition, preparing individual market orders for the small number of accounts involved may be quicker to
complete than preparing an aggregated order.
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Financial Instruments – The type of security involved, as well as the complexity of the order, can affect our ability to
achieve best execution.
Therefore, the Firm may choose not to aggregate certain transactions based on factors such as trade size, the number of client
accounts involved, timing considerations, and the liquidity of the securities being traded. When orders are not aggregated, clients
who trade in the same security at or around the same time may receive different execution prices. As a result, the decision not to
aggregate trades may lead some clients to incur higher costs than others.
ITEM 13 – REVIEW OF ACCOUNTS
Account Management Reviews
The investment strategies for the Firm are monitored by our President, Robert E. Tucker, III, and by Wealth Advisor, Alexander
Voorhees. Your investment account is also reviewed on an ongoing basis by the Investment Advisor Representative (“IAR”) over
your account. The general economy, market conditions, and/or changes in tax law can trigger more frequent reviews. Cash needs
will be adjusted as necessary. Material changes in your personal/financial situation and/or investment objectives will require
additional review and evaluation for us to properly advise you on revisions to previous recommendations and/or services. However,
it is your responsibility to communicate these changes for us to make the appropriate corrections to your management account(s).
You will receive statements, at least quarterly, from the custodian where your account(s) is/are held. Such statements will identify
your current investment holdings, the cost of each of those investments, and their current market values.
You are encouraged to review the trading activities disclosed on your account statements, which summarize your portfolio account
value, current holdings, and all account transactions made during the quarter. It is important for you to review these documents
for accurate reporting and to determine whether we are meeting your investment expectations.
Wealth Planning Reviews
The IAR who has/is designed/designing your wealth plan will work closely with you to be sure the action points identified in the
wealth plan have been or are being properly executed. Once the action points have been completed, the wealth plan should be
reviewed at least annually. Material changes in your lifestyle choices, personal circumstances, the general economy, or tax law
changes can trigger more frequent reviews. However, it is your responsibility to communicate these changes to us so that the
appropriate adjustments can be made.
ITEM 14 – CLIENT REFERRALS & OTHER COMPENSATION
Referral Compensation
We do not receive any economic benefit from an independent party for managing your account.
We will, from time to time, compensate individuals or firms directly for client referrals, provided these persons or firms are qualified
and have entered into a solicitation agreement with us. Under such arrangements, if a solicitor referred you to us, you will be given
complete information about our relationship and the compensation the solicitor will receive if you choose to open an account. The
referral fee paid to the solicitor does not result in any additional charge to you. Any such arrangements involving referral fees or
other compensation, including the solicitor agreement and related activities, will be in compliance with applicable federal and state
rules
Other Compensation (Indirect Benefit)
Please refer to Item 12 - Brokerage Practices for more detailed information on the indirect economic benefits received from the
Custodians.
Wealth Planning Compensation
As previously mentioned, certain of our Investment Advisor Representatives (“IARs”) are licensed insurance agents (See Item
10 - Other Financial Industry Activities & Affiliations for more information.). This can create a conflict of interest when
recommending for a fee, through a wealth plan, that you purchase an insurance product where they can also earn a commission.
There are also potential conflicts of interest when our IARs suggest the need for outside consultations and professional services
(i.e., attorneys, accountants, brokers, etc.) to implement certain aspects of your wealth plan. Even though we do not share in
any fees earned by the outside professionals when implementing a wealth plan, it does create an incentive on our part to refer
your business to only those entities that may, in turn, refer potential clients to us.
In both cases, there is potential for divided loyalty, and the objectivity of the advice we render could be subjective and create a
disadvantage to you. Therefore, to ensure you understand the choices and risks you have in receiving wealth planning, along
with all other investment recommendations, the following disclosures are provided to assist you with your decisions:
If requested by you to implement any insurance recommendations made in the wealth plan, the IAR will write the policy
with those insurance companies where they are a licensed insurance agent. In such cases, they will receive the normal
commissions associated with such insurance transactions.
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You are under no obligation to have any professional that we recommend prepare planning documents (i.e.; financial,
estate, tax, etc…). You are free to choose those outside professionals to implement the recommendations made in the
wealth plan.
You are under no obligation to accept our IARs’ advice and purchase the insurance products they recommend. You are
free to reject our recommendation and make your own choice.
Notwithstanding such potential conflicts of interest, we strive to serve your best interest and ensure such disclosure is being
properly made to you in compliance with the Investment Advisers Act of 1940, Rule 275.206.
Retirement Rollover Compensation
When leaving an employer, you have four options to consider for your existing retirement plan:
Leave the account assets in the former employer’s plan, if permitted;
Rollover the assets to the new employer’s plan, if one is available and rollovers are permitted;
Rollover the account assets to an Individual Retirement Account (an “IRA”); or,
Cash out the retirement account assets (There may be tax consequences and/or IRS penalties depending on your age).
You may also engage in a combination of the options listed above.
If you ask us for advice on the best option for your specific situation, we may have an economic incentive to recommend that you
roll over your retirement account into a managed IRA with us, where we would earn a management fee on the assets. This creates
a potential conflict of interest and could make the advice we give seem subjective and potentially disadvantageous to you.
Therefore, if we suggest you rollover your retirement account to an individually managed IRA, you are not obligated to engage us
to manage your assets.
ITEM 15 – CUSTODY
We do not take possession of or maintain custody of your funds or securities, but will simply monitor the holdings within your
account and trade your account based on your stated investment objectives and guidelines. Physical possession and custody of
your funds and/or securities are maintained with the custodian as indicated above in Item 12 - Brokerage Practices.
We do, however, meet the definition of custody since you have authorized us to deduct our advisory fees directly from your
account. Therefore, to comply with the custody requirements for investment advisers registered under the SEC Rule 206(4)-2,
and to protect you as well as to protect our advisory practice, we have implemented the following regulatory safeguards:
Your funds and securities will be maintained with a qualified custodian in a separate account in your name.
Authorization to withdraw our management fees directly from your account must be obtained from you before engaging
in any account management services.
In addition, the qualified custodian is required by law to send you, at least quarterly, brokerage statements summarizing
the specific investments currently held in your account, the value of your account, and account transactions. You are
encouraged to compare the financial data contained in our report to the account statement from the qualified custodian
to verify the accuracy of our reporting.
ITEM 16 – INVESTMENT DISCRETION
We provide account management services primarily on a discretionary basis, but can also provide services on a non-discretionary
basis7. If you engage us for discretionary account management services, we will have the authority to determine the types and
amounts of securities to buy or sell in your account. You may place limitations, in writing, on our discretionary authority to the
extent that the limitations do not adversely affect our ability to manage your account properly. Before we exercise discretionary
authority in your account, you will be required to execute an investment advisory agreement or a limited power of attorney granting
authority to buy, sell, or otherwise execute investment transactions in your account.
ITEM 17 – VOTING CLIENT SECURITIES
We do not vote client proxies. You understand and agree that you retain the right to vote all proxies solicited for securities held in
your managed accounts. The custodian of your managed accounts will send you all proxy solicitations. Any proxy solicitations
we inadvertently receive will be promptly forwarded to you for your evaluation and decision.
However, if you have specific questions about an action being solicited by the proxy that you do not understand or need
clarification, you may contact us, and we will explain the details. Please note that we will not advise you on how to vote; the final
decision on your vote is yours to make.
7 Managing your account on a non-discretionary basis means we cannot execute securities transactions in your account without first obtaining your verbal consent to
perform the trades. Therefore, you understand that in the event of a market correction, if we are unable to communicate our intent, your account could experience
greater market volatility than accounts managed on a discretionary basis.
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Class Action Lawsuits
We do not participate in class action proceedings on your behalf. Such decisions are your own or are made in conjunction with an
entity you designate. However, if you have specific questions, you may contact us, and we will assist in clarifying the details. Any
final decision regarding participation, as well as the completion and monitoring of any related documentation, shall be your
responsibility.
ITEM 18 – FINANCIAL INFORMATION
We are not required to include financial information in this Disclosure Brochure, as we do not take physical custody of client funds
or securities, nor do we bill client accounts six (6) months or more in advance for an amount exceeding $1,200.
We are unaware of any current financial conditions that could impair our ability to fulfill our contractual commitments to you.
Additionally, neither the Firm nor any of our officers or directors has been the subject of a bankruptcy petition in the past 10 years.
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