Overview
- Headquarters
- Skokie, IL
- Average Client Assets
- $4.7 million
- Minimum Account Size
- $1,000,000
- SEC CRD Number
- 117527
Fee Structure
Primary Fee Schedule (ADV PART II BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.25% |
| $1,000,001 | $2,000,000 | 1.00% |
| $2,000,001 | $4,000,000 | 0.75% |
| $4,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $42,500 | 0.85% |
| $10 million | $67,500 | 0.68% |
| $50 million | $167,500 | 0.34% |
| $100 million | $292,500 | 0.29% |
Clients
- HNW Share of Firm Assets
- 95.05%
- Total Client Accounts
- 675
- Discretionary Accounts
- 674
- Non-Discretionary Accounts
- 1
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
Primary Brochure: ADV PART II BROCHURE (2026-03-24)
View Document Text
Part 2A of Form ADV: Firm Brochure
ShankerValleau Wealth Advisors, Inc.
5215 Old Orchard Road
Suite 850
Skokie, Illinois 60077
Telephone: 847-475-2900
Email: jvalleau@shankervalleau.com
Web Address: www.shankervalleau.com
12/31/2025
This brochure provides information about the qualifications and business
practices of ShankerValleau Wealth Advisors, Inc. If you have any
questions about the contents of this brochure, please contact us at 847-
475-2900 or jvalleau@shankervalleau.com. The information in this
brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Additional information about ShankerValleau Wealth Advisors, Inc. is
available on the SEC's website at www.adviserinfo.sec.gov. You can
search this site by a unique identifying number, known as a CRD number.
Our firm's CRD number is 117527.
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Item 2 MATERIAL CHANGES
This Firm Brochure, dated 12/31/2025, provides you with a summary of ShankerValleau
Wealth Advisors, Inc.'s advisory services, fees, professionals, certain business practices
and policies, actual or potential conflicts of interest, and other information.
This Brochure is used to provide our clients with a summary of new and/or updated
information; we will notify regarding revision(s) based on the nature of the information
as follows.
1. Annual Update: We are required to update certain information at least annually,
within 90 days of our firm's fiscal year end (FYE) of December 31. We will provide
you with either a summary of the revised information with an offer to deliver the full
revised Brochure within 120 days of our FYE or we will provide you with our revised
Brochure that will include a summary of those changes in this Brochure.
2. Material Changes: Should a material change in our operations occur, depending on
its nature, we will promptly communicate this change to clients (and it will be
summarized in this Item). "Material changes" requiring prompt notification will
include changes of ownership or control; location; disciplinary proceedings;
significant changes to our advisory services or advisory affiliates - any information
that is critical to a client's full understanding of who we are, how to find us, and how
we do business.
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Item 3
Table Of Contents
Item 1 Cover Page
1
Item 2 Material Changes
2
Item 3
Table Of Contents
3
Item 4
Advisory Business
4
Item 5
Fees and Compensation
6
Item 6
Performance-Based Fees and Side-By-Side Management
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Item 7
Types of Clients
9
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
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Item 9 Disciplinary Information
11
Item 10 Other Financial Industry Activities and Affiliations
11
12
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Item 12 Brokerage Practices
13
Item 13 Review of Accounts
16
Item 14 Client Referrals and Other Compensation
16
Item 15 Custody
16
Item 16 Investment Discretion
17
Item 17 Voting Client Securities
17
Item 18 Financial Information
18
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Item 4
ADVISORY BUSINESS
ShankerValleau Wealth Advisors, Inc. is an SEC-registered investment adviser with its
principal place of business located in Skokie, Illinois. ShankerValleau Wealth Advisors,
Inc. began conducting business in January 1993.
Listed below are the firm's principal shareholders (i.e., those individuals and/or entities
controlling 25% or more of this company).
John D. Valleau, Jr. Declaration of Trust, Dated 12-9-22 (owned by John David Valleau,
Jr.)
ShankerValleau Wealth Advisors, Inc. (SV) sponsors a wrap fee program. A wrap fee
program is an advisory program under which a specified fee or fees not based directly
on transactions in the client's account is charged for advisory services, which includes
portfolio management and the execution of client transactions.
SV sponsors and acts as the sole investment manager to the wrap fee program. SV
manages assets for many different types of clients to help meet their financial goals
while remaining sensitive to risk tolerance and time horizons. As a fiduciary it is SV's
duty to always act in the client's best interest. SV does this by knowing the client,
maintaining open lines of communication, and by working with clients to understand
their investment objectives, while educating them about SV's process.
Please note, for certain non-discretionary employee benefit plans, SV maintains non-
wrap fee accounts. As of 12/31/2025, these accounts comprise less than 1% of SV
assets under management.
INVESTMENT SUPERVISORY SERVICES (“ISS”)
INDIVIDUAL PORTFOLIO MANAGEMENT
SV provides continuous Wrap Advisory Services advice to each client regarding the
investment of client funds based on the individual needs of the client. Through personal
discussions with the client, goals and objectives based on a client's particular
circumstances are established, including the client's time horizon, and such items as
education funding, home purchase, retirement, and legacy planning. We then develop
a client's personal investment goals and create and manage a portfolio based on those
goals. During our data-gathering process, we determine the client's individual
objectives, risk tolerance, liquidity needs and, in some cases, other available resources
(including external retirement plans, projected social security, outside investments, real
estate, and insurance). Each client's financial objectives, risk tolerance, and liquidity
needs, along with a recommended asset allocation, are incorporated into their ongoing
investment strategy. As appropriate, we also review and discuss a client's prior
investment history, as well as family composition and background.
SV's wrap fee program allows clients to pay a single fee for investment advisory
services and associated custodial transaction costs. Custodians make other products
and services available to SV.
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SV has an incentive to recommend that a client participate in SV's wrap fee program
and open account(s) with the custodian. SV believes that the recommendation to the
wrap fee program, including the use of an independent custodian and broker, is in the
best interests of those clients to whom SV recommends it. Recommendations are made
based on (a) an assessment of client investment objectives, financial situation and all
other relevant factors; as well as SV's investment plans and anticipated trading activity,
and (b) the scope, quality, and price of the custodian's services.
SV manages program accounts on a discretionary basis except for certain employee
benefit plans which we manage on a non-discretionary basis. Account supervision is
guided by the client's stated goals as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain types of asset
classes.
SV's investment recommendations will primarily include advice regarding mutual fund
shares, exchange traded fund shares, and may also include advice regarding:
Exchange-listed securities
Securities traded over-the-counter
Foreign issuers
Corporate debt securities (other than commercial paper)
Certificates of deposit
Municipal securities
Variable annuities
United States governmental securities
Because some types of investments involve additional degrees of risk, they will only be
implemented when consistent with the client's stated investment objectives, tolerance
for risk, liquidity and suitability.
FINANCIAL PLANNING
We offer financial planning services to our advisory clients. Financial planning is a
comprehensive evaluation of a client's current and future financial state by using
currently known variables to predict future cash flows, asset values and withdrawal
plans. Through the financial planning process, all questions, information and analysis
are considered as they impact the entire financial and life situation of the client. This
service is included in the advisory fee paid by clients and there are no additional fees
associated with this service.
In general, the financial plan can address any or all of the following areas:
PERSONAL: We review family records, budgeting, personal liability, estate
information and financial goals.
TAX & CASH FLOW: We analyze the client's income tax and spending and planning
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for past, current and future years.
INVESTMENTS: We analyze investment alternatives and their effect on the client's
portfolio.
INSURANCE: We review existing policies to ensure proper coverage for life, health,
disability, long-term care, liability, home and automobile.
RETIREMENT: We analyze current strategies and investment plans to help the client
achieve his or her retirement goals.
DEATH & DISABILITY: We review the client's cash needs at death, income needs of
surviving dependents, estate planning and disability income.
ESTATE: We assist the client in assessing and developing long-term strategies,
including as appropriate, living trusts, wills, review estate tax, powers of attorney,
asset protection plans and nursing homes.
Gathering client information: We gather required information through in-depth
personal interviews. Information gathered includes the client's current financial status,
tax status, future goals, return objectives and attitudes towards risk. We carefully
review documents supplied by the client and prepare a written report.
Use of Artificial Intelligence: We utilize artificial intelligence (AI) tools internally to
assist in summarizing and organizing notes from meetings to enhance record-keeping
and efficiency. These AI tools do not replace human oversight, and all notes are
reviewed for accuracy and compliance with regulatory standards. AI is not used to
make investment decisions. We conduct thorough due diligence upfront and ongoing
assessments of our AI tools' privacy and cybersecurity protocols to ensure they meet
standards of security and confidentiality.
Firm Recommendations: We work with the client to implement our recommendations
and we suggest the client work closely with his/her attorney, accountant and insurance
agent. Implementation of financial recommendations is entirely at the client's
discretion.
We also provide general non-securities advice on topics that may include tax and
budgetary planning, estate planning and business planning.
Financial Planning recommendations are not limited to any specific product or service
offered by a broker-dealer or insurance company.
AMOUNT OF MANAGED ASSETS
As of 12/31/2025, we were managing $645 million of clients' assets on a
discretionary and non-discretionary basis.
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Item 5
FEES AND COMPENSATION
INVESTMENT SUPERVISORY SERVICES WRAP FEE PROGRAM
INDIVIDUAL PORTFOLIO MANAGEMENT FEES
The annualized fee for Investment Supervisory Services will be charged as a
percentage of assets under management, according to the following schedule:
Annual Fee
First
Next
Next
Next
Assets Under
Management
$2,000,000
$2,000,000
$6,000,000
$10,000,0000 +
1.00%
.75%
.50%
.25%
For all relationships under $1 million our annual fee is 1.25%.
Clients will be invoiced, and their account directly debited, as authorized, in arrears at
the end of each calendar quarter based upon the value (market value or fair market
value in the absence of market value), of the clients account at the end of the quarter.
A minimum of $1,000,000 of assets under management is generally required for this
service. This account size may be negotiable under certain circumstances. For certain
relationship platforms, minimums may vary. ShankerValleau Wealth Advisors, Inc. may
group certain related client accounts for the purposes of achieving the minimum account
size and determining the annualized fee.
Adviser charges an advisory fee on all assets held in a clients' account unless otherwise
agreed upon in writing by the adviser and client.
Adviser reserves the right to pay authorized persons a portion of Client's fee in return for
having referred such client to Adviser. In such instances, Adviser will inform Client of
such an agreement prior to the establishment of an advisory relationship in accordance
with the Investment Adviser Act of 1940.
Discounts, not generally available to our advisory clients, may be offered to nonprofit
organizations, family members and employees of our firm.
GENERAL INFORMATION
WRAP FEE PROGRAM
Services that are covered by the Program fees: The Program fees pay for the firm's
advisory services to clients under the Program, the administrative expenses of the
Program, and the trade execution charges for trades on the clients' assets held at the
recommended Custodians.
Services that are not covered by the Program fees: The Program fees do not include
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the expenses associated with mutual funds, Exchange Traded Funds (such as fund
management fees charged to each fund's investors), mark-ups, mark-downs, spreads
paid to market makers, and/or odd-lot differential fees. SV does not retain any portion
of these charges.
Other Fees and Expenses: Clients may incur charges from the Custodian for other
account services provided not directly related to the execution and clearing of
transactions, including, but not limited to interest charges on margin loans. SV does not
retain any portion of these charges.
Additional Information about Program Fees: Under the Program, the participant
receives investment advisory services, the execution of securities brokerage
transactions, and reporting services for a single specified Program Fee. Clients are
cautioned that depending on the fees charged by the executing broker-dealer, and the
amount of portfolio activity in the clients' account, the value of the services provided
under this Program may exceed the total cost of such services had they been provided
separately. In addition, the Program Fee may be higher or lower than that charged by
other sponsors of comparable wrap fee programs. In as much as SV will pay the
execution costs of securities transactions executed in Program client accounts, a
disincentive exists to enter trades on behalf of Program participants. Further, the
Custodian charges different execution costs for different but similar securities. While SV
endeavors to always make investment decisions based on the needs of the client, it
should be noted that an incentive exists to utilize lower execution cost funds.
Termination of the Advisory Relationship: A client agreement may be canceled at
any time, by either party, for any reason upon written notice to the other party at its
designated address. The Advisor's pro-rated management fee will be applied to the
value of the account one business day prior to the date the assets are to be
transferred. ShankerValleau Wealth Advisors, Inc. will not charge a termination fee.
Fund Fees: All fees paid to ShankerValleau Wealth Advisors, Inc. for investment
advisory services are separate and distinct from the fees and expenses charged by
mutual funds and exchange traded funds to their shareholders. These fees and
expenses are described in each fund's prospectus. These fees will generally include a
management fee, other fund expenses, and a possible distribution fee. If the fund also
imposes sales charges, a client may pay an initial or deferred sales charge.
ShankerValleau Wealth Advisors, Inc. generally invests in no-load mutual funds and
exchange traded funds. Please note that ShankerValleau Wealth Advisors, Inc. may
invest in mutual funds that require an approved registered investment adviser;
therefore, any transfer of these funds may require a relationship with an investment
adviser approved by the mutual fund.
Additional Fees and Expenses: Other than the advisory fee referenced above,
ShankerValleau Wealth Advisors, Inc. does not charge advisory clients any additional
fees for Investment Supervisory Services.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients
are subject to ShankerValleau Wealth Advisors, Inc.'s minimum account requirements
and advisory fees in effect at the time the client entered into the advisory relationship.
Therefore, our firm's minimum account requirements will differ among clients.
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ERISA Accounts: ShankerValleau Wealth Advisors, Inc. is deemed to be a fiduciary to
advisory clients that are employee benefit plans or individual retirement accounts (IRAs)
pursuant to the Employee Retirement Income and Securities Act ("ERISA"). As such,
our firm is subject to specific duties and obligations under ERISA and the Internal
Revenue Code that include among other things, restrictions concerning certain forms of
compensation. To avoid engaging in prohibited transactions, ShankerValleau Wealth
Advisors, Inc. may only charge fees for investment advice about products for which our
firm and/or our related persons do not receive any commissions or 12b-1 fees.
Advisory Fees in General: Clients should note that similar advisory services may be
available from other registered investment advisers for similar or lower fees.
Limited Trade Aggregation: SV may purchase or sell the same securities for several
Program clients at approximately the same time. SV may combine such orders to
improve transaction execution, or to allocate equitably among SV's Program client’s
differences in prices or other transaction costs that might been obtained had such
orders been placed independently. Under this procedure, transactions will generally be
averaged as to price and allocated among SV's clients pro rata to the purchase and sale
orders placed for each client on any given day. To the extent that SV determines to
aggregate client orders for the purchase of sale of securities SV shall generally do so in
accordance with applicable rules promulgated under the Advisers Act and no-action
guidance provided by the staff of the U.S. Securities and Exchange Commission.
Limited Prepayment of Fees: Under no circumstances do we require or solicit
payment of fees more than six months in advance of services rendered.
NON-DISCRETIONARY EMPLOYEE BENEFIT PLANS
For certain non-discretionary employee benefit plans, ShankerValleau maintains non-
wrap fee accounts which are billed on a different basis. The fee schedule is disclosed
on the plan agreements.
Item 6
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
ShankerValleau Wealth Advisors, Inc. does not charge performance-based fees.
Item 7
TYPES OF CLIENTS
ShankerValleau Wealth Advisors, Inc. provides advisory services to the following types
of clients:
Individuals (other than high net worth individuals)
High net worth individuals
Pension and profit sharing plans(other than plan participants)
Charitable organizations
Corporations or other businesses not listed above.
As previously disclosed in Item 5, our firm has established certain initial minimum
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account requirements, based on the nature of the service(s) being provided. For a more
detailed understanding of those requirements, please review the disclosures provided
for each applicable service.
Item 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND
RISK OF LOSS
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
Our entire approach to investing is designed to provide you with the greatest likelihood
of achieving your goals. We have learned that gain is rarely accomplished without
taking a chance, but all risks do not provide a reliable reward. Financial science over the
last fifty years has helped to identify the risks worth taking and the risks that are not.
Stock Investment Philosophy. We believe in the efficiency of capital markets. We
understand that, at any given time, the price of a security reflects all of the available
information in the marketplace. Thus trying to outperform the market is a futile task.
Instead, we capture risks that have been identified by scientific research that are most
likely to provide a reliable reward and at minimal cost. We primarily use structured
strategies designed by Dimensional Fund Advisors to accomplish these goals. These
strategies involve considerable diversification not only in the amount of securities held
but also in the range of capital markets utilized. Small capitalization strategies target
smaller company stocks more consistently. Value strategies target value stocks with
greater focus. As a result, you achieve a more consistent portfolio structure.
Investors are often surprised to learn how well they can do by simply capturing the
returns the markets provide. Over the near-term markets are unpredictable yet over the
long-term markets have posted surprisingly, predictable returns. Therefore, for those
investors able to focus on the long-term, investing becomes more of a science than a
gamble.
Bond Investment Philosophy. In addition to investing in stocks, through stock funds,
we recommend that a portion of each portfolio be allocated to bonds, through bond
funds. The bond portion of the portfolio serves as the portfolio's anchor by reducing
volatility.
We do not believe that the risks in investing in either lower credit risk or in longer term
obligations are worth the expected return. Also, we feel a diversified approach again,
not only in the number of obligations but also in the range of markets included will
further reduce risk.
Thus, our recommended bond portion of the portfolio generally consists of short-term
and intermediate-term, high-quality, domestic and foreign bonds. We employ a lower
risk bond strategy so you can take more risk in stocks, where expected returns are
greater. Finally, the portfolio's stock and bond elements are then rebalanced quarterly to
ensure adherence to your specific asset allocation goal.
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Risk of Loss. Securities investments are not guaranteed, and you may lose money on
your investments. We ask that you work with us to help us understand your liquidity
needs and tolerance for risk.
Portfolio rebalancing: Portfolio rebalancing represents an important risk-control
strategy. A portfolio's asset allocation determines the portfolio's risk and return
characteristics. The purpose of establishing an asset allocation strategy is to achieve
target rates of return with acceptable levels of risk. Asset allocation is a risk
management technique that mixes a wide variety of investments within a portfolio. Due
to market fluctuations, a portfolio must be rebalanced according to the risk tolerance,
time horizon, and financial goals of the individual client. SV monitors client portfolios
carefully and rebalances portfolios on a quarterly basis. Additional factors SV will
consider when implementing a rebalancing strategy include client preferences, and
potential tax implications.
Margin transactions: For certain clients, SV may purchase securities for the portfolio
with money borrowed from the brokerage account. This allows clients to purchase more
securities than they would be able to with their available cash and allows SV to
purchase securities without selling other holdings. The use of margin involves leverage
and special risks. Accordingly, the use of margin requires specific approval on an
account-by-account basis. Most clients will not participate in margin related activities.
Item 9
DISCIPLINARY INFORMATION
We are required to disclose any legal or disciplinary events that are material to a client's
or prospective client's evaluation of our advisory business or the integrity of our
management.
Our firm and our management personnel have no reportable disciplinary events to
disclose.
Item 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Management personnel of our firm also own the accounting firm of ShankerValleau
Accountants, Inc., providing accounting services for separate and typical compensation.
ShankerValleau Accountants, Inc. typically recommends ShankerValleau Wealth
Advisors, Inc. to accounting clients in need of advisory services. Conversely,
ShankerValleau Wealth Advisors, Inc. typically recommends ShankerValleau
Accountants, Inc. to advisory clients in need of accounting services. Accounting
services provided by ShankerValleau Accountants, Inc. are separate and distinct from
our advisory services, and are provided for separate and typical compensation. There
are no referral fee arrangements between our firms for these recommendations. No
ShankerValleau Wealth Advisors, Inc. client is obligated to use ShankerValleau
Accountants, Inc. for any accounting services and conversely, no accounting client is
obligated to use the advisory services provided by us. ShankerValleau Accountants,
Inc.'s accounting services do not include the authority to sign checks or otherwise
disburse funds on any of our advisory client's behalf.
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Item 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Our firm has adopted a Code of Ethics which sets forth high ethical standards of
business conduct that we require of our employees, including compliance with
applicable federal securities laws.
ShankerValleau Wealth Advisors, Inc. and our personnel owe a duty of loyalty, fairness
and good faith towards our clients, and have an obligation to adhere not only to the
specific provisions of the Code of Ethics but to the general principles that guide the
Code.
ShankerValleau Wealth Advisors, Inc.'s Code of Ethics further includes the firm's policy
prohibiting the use of material non-public information. While we do not believe that we
have any particular access to non-public information, all employees are reminded that
such information may not be used in a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients.
You may request a copy by email sent to jvalleau@shankervalleau.com, or by calling us
at 847-475-2900.
ShankerValleau Wealth Advisors, Inc. and individuals associated with our firm are
prohibited from engaging in principal transactions.
ShankerValleau Wealth Advisors, Inc. and individuals associated with our firm are
prohibited from engaging in agency cross transactions.
Our Code of Ethics is designed to assure that the personal securities transactions,
activities and interests of our employees will not interfere with (i) making decisions in the
best interest of advisory clients and (ii) implementing such decisions while, at the same
time, allowing employees to invest for their own accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal
accounts securities identical to or different from those recommended to our clients. In
addition, any related person(s) may have an interest or position in a certain security(ies)
which may also be recommended to a client.
We may aggregate our employee trades with client transactions where possible and
when compliant with our duty to seek best execution for our clients. In these instances,
participating clients will receive an average share price and transaction costs will be
shared equally and on a pro-rata basis. In the instances where there is a partial fill of a
particular batched order, we will allocate all purchases pro-rata, with each account
paying the average price. Our employee accounts will be excluded in the pro-rata
allocation.
As these situations represent actual or potential conflicts of interest to our clients, we
have established the following policies and procedures for implementing our firm's Code
of Ethics, to ensure our firm complies with its regulatory obligations and provides our
clients and potential clients with full and fair disclosure of such conflicts of interest:
1. No principal or employee of our firm may put his or her own interest above the
interest of an advisory client.
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2. No principal or employee of our firm may buy or sell securities for their personal
portfolio(s) where their decision is a result of information received as a result of his
or her employment unless the information is also available to the investing public.
3. We have established procedures for the maintenance of all required books and
records.
4. All of our principals and employees must act in accordance with all applicable Federal
and State regulations governing registered investment advisory practices.
5. We require delivery and acknowledgement of the Code of Ethics by each supervised
person of our firm.
6. We have established policies requiring the reporting of Code of Ethics violations to
our senior management.
7. Any individual who violates any of the above restrictions may be subject to
termination.
Item 12
BROKERAGE PRACTICES
ShankerValleau Wealth Advisors, Inc. requires that it be provided with written authority
to determine the custodian to use for client transactions and the fees that will be
charged for these transactions.
Clients must include any limitations on this discretionary authority in this written
authority statement. Clients may amend these limitations as required. Such
amendments must be provided to us in writing.
In addition to compensating the firm for portfolio management and other services to
clients, the wrap fees clients pay the firm also allow us to pay the Custodian for the
brokerage services it provides to clients. The fees the firm pays the Custodian consist
of fees that would otherwise be charged to clients. These fees may include (a) account
fees, (b) flat dollar per trade fees, (c) transaction-based fees imposed on the Custodian
by regulatory organizations and exchanges and (d) fees to offset processing costs
incurred by the Custodian.
ShankerValleau Wealth Advisors, Inc. will utilize block trades where possible. This
blocking of trades permits the trading of aggregate blocks of securities composed of
assets from multiple client accounts.
ShankerValleau Wealth Advisors, Inc.'s block trading policy and procedures are as
follows:
1) Transactions for any client account may not be aggregated for execution if the
practice is prohibited by or inconsistent with the client's advisory agreement with
ShankerValleau Wealth Advisors, Inc., or our firm's order allocation policy.
2) The portfolio manager must determine that the purchase or sale of the particular
security involved is appropriate for the client and consistent with the client's
investment objectives and with any investment guidelines or restrictions applicable to
the client's account.
3) The portfolio manager must reasonably believe that the order aggregation will benefit
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the client, and will enable ShankerValleau Wealth Advisors, Inc. to seek best execution
for each client participating in the aggregated order. This requires a good faith judgment
at the time the order is placed for the execution. It does not mean that the determination
made in advance of the transaction must always prove to have been correct in the light
of a "20-20 hindsight" perspective. Best execution includes the duty to seek the best
quality of execution, as well as the best net price.
4) Prior to entry of an aggregated order, a written order ticket must be completed which
identifies each client account participating in the order and the proposed allocation of
the order, upon completion, to those clients.
5) If the order cannot be executed in full at the same price or time, the securities
actually purchased or sold by the close of each business day must be allocated pro
rata among the participating client accounts in accordance with the initial order ticket
or other written statement of allocation. However, adjustments to this pro rata
allocation may be made to participating client accounts in accordance with the initial
order ticket or other written statement of allocation. Furthermore, adjustments to this
pro rata allocation may be made to avoid having odd amounts of shares held in any
client account, or to avoid excessive ticket charges in smaller accounts.
6) Generally, each client that participates in the aggregated order must do so at the
average price for all separate transactions made to fill the order and must share in any
transaction costs on a pro rata basis in proportion to the client's participation. Under the
client's agreement with the custodian/broker, transaction costs may be based on the
number of shares traded for each client.
7) If the order will be allocated in a manner other than that stated in the initial statement
of allocation, a written explanation of the change must be provided to and approved by
the Chief Compliance Officer no later than the morning following the execution of the
aggregate trade.
8) ShankerValleau Wealth Advisors, Inc.'s client account records separately reflect, for
each account in which the aggregated transaction occurred, the securities which are
held by, and bought and sold for, that account.
9) Funds and securities for aggregated orders are clearly identified on ShankerValleau
Wealth Advisors, Inc.'s records and to the broker-dealers or other intermediaries
handling the transactions, by the appropriate account numbers for each participating
client.
10) No client or account will be favored over another.
11) If a trade error occurs, the client will be notified in writing of the error, along with the
steps taken to correct that error and make the client whole. ShankerValleau is not entitled
to retain any gains due to trade errors. Any trade error gains will automatically be swept to
a designated custodian error account each business day and the proceeds will be donated
to charity.
ShankerValleau Wealth Advisors, Inc. utilizes Schwab Advisor Services™
(“Custodian”) which includes custody, trading and support services. Charles
Schwab & Co., Inc. ("Schwab") is a member of the SIPC and is a separate but
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affiliated company and subsidiary of The Charles Schwab Corporation.
ShankerValleau Wealth Advisors, Inc. is not owned by, affiliated with, or
supervised by Schwab.
The custodian offers services to independent investment advisers which include
custody of securities, trade execution, clearance and settlement of transactions.
ShankerValleau Wealth Advisors, Inc. receives some benefits from Schwab
through Schwab Advisor Services™.
ShankerValleau Wealth Advisors, Inc. may require clients to maintain accounts with
the custodian and brokerage services. There is no direct link between our firm's
utilization of Schwab Advisor Services™ and the investment advice we give to our
clients, although we receive economic benefits from Schwab that are typically not
available to the custodian’s retail investors.
These benefits include the following products and services (provided without cost or at a
discount): duplicate client statements and confirmations; research related products and
tools; consulting services access to a trading desk serving adviser participants; access
to block trading (which provides the ability to aggregate securities transactions for
execution and then allocate the appropriate shares to client accounts); the ability to
have advisory fees deducted directly from client accounts; access to an electronic
communications network for client order entry and account information; access to
securities with no transaction fees and to certain Institutional money managers; and
discounts on compliance, marketing, research, technology, and practice management
products or services provided to ShankerValleau Wealth Advisors, Inc. by third party
vendors. The custodian may also pay for meal expenses for ShankerValleau Wealth
Advisors, Inc.'s personnel while attending conferences or meetings relating to the
custodian’s adviser custody and brokerage services.
Some of the products and services made available by the custodian may benefit
ShankerValleau Wealth Advisors, Inc. but may not benefit our client accounts. These
products or services may assist us in managing and administering client accounts,
including accounts not maintained by the custodian. Other services made available by
the custodian are intended to help us manage and further develop our business
enterprise. The benefits received by ShankerValleau Wealth Advisors, Inc. through
Schwab Advisor Services™ do not depend on the amount of brokerage transactions
directed to the custodian. Clients should be aware, however, that the receipt of
economic benefits by ShankerValleau Wealth Advisors, Inc. or our related persons in
and of itself creates a potential conflict of interest and may indirectly influence our
choice of custodian and brokerage services.
ShankerValleau Wealth Advisors, Inc., consequently, may have an incentive to
recommend to our clients that the assets under management by us be held in custody
with Schwab and to place transactions for client accounts with Schwab.
ShankerValleau Wealth Advisors, Inc.'s receipt of Additional Services does not diminish
our duty to act in the best interests of our clients, including seeking best execution of
trades for client accounts.
Item 13
REVIEW OF ACCOUNTS
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INVESTMENT SUPERVISORY SERVICES
INDIVIDUAL PORTFOLIO MANAGEMENT
REVIEWS: While the underlying securities within Individual Portfolio Management
Services accounts are continually monitored, these accounts are reviewed at least
quarterly. Accounts are reviewed in the context of each client's stated investment
objectives and guidelines. More frequent reviews may be triggered by material changes
in the client's individual circumstances.
REPORTS: In addition to the monthly statements and confirmations of transactions that
clients receive from their custodian, we provide quarterly reports summarizing account
performance, balances and holdings.
Item 14
CLIENT REFERRALS AND OTHER COMPENSATION
ShankerValleau Wealth Advisors, Inc. reserves the right to pay authorized persons a
portion of Client's fee in return for having referred such client to Adviser. In such
instances, Adviser will inform Client of such an agreement prior to the establishment of
an advisory relationship in accordance with the Investment Adviser Act of 1940.
It is ShankerValleau Wealth Advisors, Inc.'s policy not to accept or allow our related
persons to accept any form of compensation, including cash, sales awards or other
prizes, from a non-client in conjunction with the advisory services we provide to our
clients.
Item 15
CUSTODY
ShankerValleau Wealth Advisors, Inc. maintains client assets with a qualified custodian
and does not have physical custody of any client funds or securities. ShankerValleau
Wealth Advisors, Inc. may have other forms of custody as defined by the appropriate rule.
As disclosed in Item 5 of this Brochure, we directly debit our fees from client accounts
as authorized. As part of this billing process, the client's custodian is advised of the
amount of the fee to be deducted from that client's account. On at least a quarterly
basis, the custodian is required to send to the client a statement showing all
transactions within the account during the reporting period. Because the custodian
does not calculate the amount of the fee to be deducted, it is important for clients to
carefully review their custodial statements to verify the accuracy of the calculation,
among other items. Clients should contact us directly if they believe that there may be
an error in their statement.
Additionally, ShankerValleau is deemed to have custody by maintaining Standing Letters
of Authorization (SLOAs) allowing the firm to wire and ACH funds under certain
circumstances from client accounts to third parties. For any accounts with a SLOA in
place, ShankerValleau Wealth Advisors, Inc. will follow the conditions set forth in the
SEC’s No Action Letter dated February 21, 2017, and listed immediately below, so that
no surprise audit will be required for these accounts.
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1. The client will be required to provide a written instruction to the qualified custodian
that includes the client’s signature, the third party’s name, and either the third party’s
address or the third party’s account number at a custodian to which the transfer should
be directed.
2. The client will authorize ShankerValleau Wealth Advisors, Inc. in writing, either on
the qualified custodian’s form or separately, to direct transfers to the third party either
on a specified schedule or from time to time.
3. The client’s qualified custodian will perform appropriate verification of the instruction,
such as a signature review or other method to verify the client’s authorization and will
provide a transfer of funds notice to the client promptly after each transfer.
4. The client will have the ability to terminate or change the instruction to the client’s
qualified custodian.
5. ShankerValleau Wealth Advisors, Inc. will have no authority or ability to designate or
change the identity of the third party, the address, or any other information about the
third party contained in the client’s instruction.
6. ShankerValleau Wealth Advisors, Inc. will maintain records showing that the third
party is not a related party of ShankerValleau Wealth Advisors, Inc. or located at the
same address as ShankerValleau Wealth Advisors, Inc.
7. The client’s qualified custodian will send the client, in writing, an initial notice
confirming the instruction and an annual notice reconfirming the instruction.
Item 16
INVESTMENT DISCRETION
Clients hire us to provide discretionary asset management services, in which case we
place trades in a client's account without contacting the client prior to each trade to
obtain the client's permission.
Our discretionary authority includes the ability to do the following without contacting the
client:
Determine the security to buy or sell; and/or
Determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign a discretionary agreement with
our firm and may limit this authority by giving us written instructions. Clients may also
amend such limitations by once again providing us with written instructions.
Item 17 VOTING CLIENT SECURITIES
We vote proxies on behalf of clients; however, you always have the right to vote proxies
yourself. You may exercise this right by instructing your custodian in writing to not allow
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ShankerValleau Wealth Advisors, Inc. to vote proxies in your account.
We will vote proxies in accordance with our established policies and procedures. Our
firm will retain all proxy voting books and records for the requisite period of time,
including a copy of each proxy statement received, a record of each vote cast, a copy
of any document created by us that was material to making a decision how to vote
proxies, and a copy of each written client request for information on how the adviser
voted proxies.
Clients may obtain a copy of our complete proxy voting policies and procedures by
contacting John D. Valleau, Jr. by telephone, email, or in writing. Clients may request, in
writing, information on how proxies for his/her shares were voted. If any client requests
a copy of our complete proxy policies and procedures or how we voted proxies for
his/her account(s), we will promptly provide such information to the client.
We will neither advise nor act on behalf of the client in legal proceedings involving
companies whose securities are held in the client's account(s), including, but not limited
to, the filing of "Proofs of Claim" in class action settlements. If desired, clients may direct
us to transmit copies of class action notices to the client or a third party. Upon such
direction, we will make commercially reasonable efforts to forward such notices in a
timely manner.
With respect to ERISA accounts, we will vote proxies unless the plan documents
specifically reserve the plan sponsor's right to vote proxies.
We vote proxies for most, but not all of our clients. Clients may, at their election, choose
to receive proxies related to their own accounts, in which case we may consult with
clients as requested.
Item 18
FINANCIAL INFORMATION
ShankerValleau Wealth Advisors, Inc. has no additional financial circumstances to
report.
Under no circumstances do we require or solicit payment of fees in excess of $1,200
per client more than six months in advance of services rendered. Therefore, we are not
required to include a financial statement.
ShankerValleau Wealth Advisors, Inc. has not been the subject of a bankruptcy petition
at any time.
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