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Firm Brochure- Form ADV Part 2A
This brochure provides information about the qualifications and business practices of
Signify Wealth. If you have any questions about the contents of this brochure, please
contact us at (314) 222-0295 or by email at: info@signifywealth.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 Signify Wealth is also available on the SEC’s
website at www.adviserinfo.sec.gov.Signify Wealth’s CRD number is:
160094
7750 Clayton Road Suite 100
St. Louis, Missouri 63117
(314) 222-0295
info@signifywealth.com
Registration does not imply a certain level of skill or training.
Version Date: 07/25/2025
Item 2: Material Changes
These are the following material changes in this brochure from the last annual amendment
filing of Signify Wealth LLC on March 15, 2024. Material changes relate to Signify Wealth LLC’s
policies, practices or conflicts of interests.
Items 4, 5, 6, and 8: Updated to describe features, fees, and risks of new business line—Special
Purpose Vehicles.
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Item 3: Table of Contents
Item 2: Material Changes ....................................................................................................................1
Item 3: Table of Contents ....................................................................................................................2
Item 4: Advisory Business ...................................................................................................................4
A. Description of the Advisory Firm ...................................................................................................... 4
B. Types of Advisory Services ..........................................................................................................4
C. Client Tailored Services and Client Imposed Restrictions .............................................................8
D. Wrap Fee Programs .......................................................................................................................... 8
E. Amounts Under Management .......................................................................................................8
Item 5: Fees and Compensation .........................................................................................................8
A. Fee Schedule ................................................................................................................................8
B. Payment of Fees ................................................................................................................................ 9
C. Clients Are Responsible For Third Party Fees ................................................................................. 10
D. Prepayment of Fees .......................................................................................................................... 10
E. Outside Compensation For the Sale of Securities to Clients .........................................................10
Item 6: Performance-Based Fees and Side-By-Side Management ........................................................ 10
Item 7: Types of Clients .......................................................................................................................11
Minimum Account Size ............................................................................................................................ 11
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ............................... 11
A. Methods of Analysis and Investment Strategies ...........................................................................11
B. Material Risks Involved ...................................................................................................................... 11
C. Risks of Specific Securities Utilized ................................................................................................... 12
Item 9: Disciplinary Information ...........................................................................................................13
A. Criminal or Civil Actions ................................................................................................................13
B. Administrative Proceedings ..........................................................................................................13
C. Self-regulatory Organization (SRO) Proceedings ................................................................................. 13
Item 10: Other Financial Industry Activities and Affiliations ..................................................................... 13
A. Registration as a Broker/Dealer or Broker/Dealer Representative ................................................13
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity
Trading Advisor ....................................................................................................................... 13
C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests
. 13
D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those
Selections 14
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.............. 15
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A. Code of Ethics ..............................................................................................................................15
B. Recommendations Involving Material Financial Interests ................................................................ 15
C. Investing Personal Money in the Same Securities as Clients ........................................................15
D. Trading Securities At/Around the Same Time as Clients’ Securities ..............................................15
Item 12: Brokerage Practices ................................................................................................................... 16
A. Factors Used to Select Custodians and/or Broker/Dealers ...........................................................16
B. Aggregating (Block) Trading for Multiple Client Accounts .............................................................18
Item 13: Reviews of Accounts ....................................................................................................................... 18
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ..............................18
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts.............................................19
C. Content and Frequency of Regular Reports Provided to Clients ...................................................19
Item 14: Client Referrals and Other Compensation ................................................................................. 19
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales
Awards or Other Prizes) ...............................................................................................................19
B. Compensation to Non –Advisory Personnel for Client Referrals ..................................................19
Item 15: Custody .................................................................................................................................19
Item 16: Investment Discretion ...................................................................................................................... 20
Item 17: Voting Client Securities (Proxy Voting) ...................................................................................... 20
Item 18: Financial Information ........................................................................................................................ 21
A. Balance Sheet ...............................................................................................................................21
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to
Clients
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C. Bankruptcy Petitions in Previous Ten Years .................................................................................21
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Item 4: Advisory Business
A. Description of the Advisory Firm
Signify Wealth is a Limited Liability Company organized in the state of Missouri.
• This firm has been in business since December 2011.
• Signify Wealth LLC ‘s principal owner is Stephen P. Rhodes
B. Types of Advisory Services
Signify Wealth (hereinafter “SW”) offers the following services to advisory clients:
Investment Management Services
SW provides discretionary investment management services for its Clients either directly or
through allocation to unaffiliated Third-Party Managers participating in a Managed Account
Program. For Clients with accounts managed through a Managed Account Program, the Third-
Party manages will also require such authority.
Based on information you provide about your individual and family circumstances, financial
situation, securities portfolio, investment objectives (such as income, balanced growth and
income, or maximum growth, for example), expected investment time horizon, tolerance for
volatility or risk in your portfolio, and liquidity needs, we will work with you to develop an
appropriate investment program.
SW primarily allocates Client assets among various Third-Party managers; we may also manage
all or a portion a Client’s account(s) internally. In addition to Third-party managers, SW may
construct Client portfolios utilizing mutual funds, exchange-traded funds (“ETFs”), individual equity
securities and fixed income securities. SW may employ other types of investments as necessary
to achieve the Client’s objectives. SW may also recommend that certain accredited investors (as
defined by Rule 501 of the Securities Act of 1933) invest in privately placed securities, which may
include debt, equity 6 or interests in pooled investment vehicles (e.g. hedge funds). Where
applicable, SW may also provide advice regarding legacy positions or other investments held in
a Client’s portfolio. Please refer to Item 8 – Methods Of Analysis, Strategies & Risk Of Loss for
information about the investment strategies and types of investments we generally recommend to
Clients.
Managed Accounts Program
Client’s investible assets can be managed by us through a Managed Account Program sponsored
by one of the institutional management firms we recommend (each referred to as a “Sponsor”).
We believe many Clients can benefit from the diverse investment products, strategies, portfolios,
and institutional managers available through Managed Account Programs. We will assist the
Client to select an appropriate Managed Account Program and to designate an initial investment
strategy and model portfolio, and if appropriate, a third-party manager to manage their account.
Currently, we have Clients participating in the Managed Account Programs sponsored by Dynasty
Wealth Management, LLC (“DWM”), a subsidiary of Dynasty Financial Partners, LLC (“DFP”)
(collectively “Dynasty”), Envestnet and other investment platforms. The vast majority of our Clients
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are using Managed Account Programs through Dynasty. Please see Item 10 – Other Financial
Industry Activities & Affiliations for additional disclosures.
Dynasty provides an integrated platform service provider of business resources to Registered
Investment Advisors (“RIA”). Dynasty provides access to trading technology, reporting and
investments through an open architecture system. Dynasty selects, builds and monitors
investment portfolios in order to cater to various levels of investor sophistication. SW uses
Dynasty’s Separately Managed Accounts (“SMA”) and Unified Managed Accounts (“UMA”) to
create custom portfolios for a range of Client needs.
Dynasty’s SMA/UMA solutions include:
• Institutional quality research
• Integrated flexible performance reporting options
• A single technology platform to manage trading, research and reporting
Accounts participating in a Managed Account Program will typically pay a quarterly Program Fee
(calculated as a percentage of assets) that include (i) the Program Sponsor’s services in
researching and adjusting the model portfolios and strategies, screening available investment
options, and performing initial due diligence and on-going monitoring of Third-Party Managers, (ii)
the day-to-day investment management services of Third-Party Managers, if any, selected for the
account, and (iii) the broker-dealer’s brokerage and custody services.
For Clients that we recommend a Managed Account Program, we will explain the objectives of
the Program, the characteristics and risk profiles of the available investment portfolios, the
management styles and strategies of the Third-Party Managers, and the potential benefits, costs,
risks, and requirements of the program.
Clients who choose to participate in a Managed Account Program, we will assist the Client to
identify a suitable model portfolio or strategy, and if applicable to the Managed Account Program,
an appropriate Third-Party Manager to provide day-today management of the Client’s Program
account[s].
Client Directed Investments
For client directed investments/funds, not recommended by the Adviser and possibly held outside
the custodians, the Adviser will provide reporting, administrative and monitoring services for these
investments.
Financial Planning/Consulting Services
SW does not offer stand-alone financial planning services. Clients who enter into investment
management services agreements with SW have the option to request various other financial
planning services from SW, including but not limited to risk management planning, tax planning,
retirement planning, estate planning, and/or debt management planning. These optional other
financial planning services are provided at no additional cost. However, optional other financial
planning services are only provided to investment management services Clients upon request and
only after SW has agreed to the request. SW is under no obligation and bears no responsibility to
provide all investment management services clients with optional financial planning services. The
following is additional detail on the optional financial planning services that SW may provide (upon
request by the client and agreement by SW) to investment management services clients:
• Risk Management Planning - Upon request, SW conducts risk management
planning for a client. After gathering information provided by the client, SW
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insurance,
flood
insurance, health
identifies and analyzes risks relevant to the client. After identification and
examination, SW recommends products, tools, and techniques to mitigate,
reduce, and/or eliminate the identified risks. This usually includes the client
implementing various insurance policies. Examples include, but are not
limited to, automobile insurance, commercial insurance, disability insurance,
errors & omissions
insurance,
homeowners’ or renters’ insurance, life insurance, personal articles
insurance, and umbrella insurance. Other non- insurance products, tools,
and techniques to mitigate, reduce, and/or eliminate the identified risks
associated with each client are also recommended to the client if applicable
to the client’s situation.
• Tax Planning – Upon request, SW assists a client with tax planning. After
gathering information provided by the client, SW seeks to help the client
minimize, reduce, or legally eliminate the various types of taxes imposed
upon the client. Various taxes include, but are not limited to, federal, state,
and local income taxes, estate taxes, excise taxes, foreign taxes, franchise
taxes, payroll taxes, property taxes, real estate taxes, sales taxes, self-
employment taxes, and unemployment taxes. There are many strategies and
techniques to minimize, reduce, or legally eliminate each type of tax, and SW
analyzes each client’s distinct situation in order to properly recommend
effective and efficient strategies and techniques.
• Retirement Planning – Upon request, SW reviews and analyzes a client’s
current and forecasted retirement scenario. After gathering information
provided by the client, SW works with the client to set realistic retirement
goals and outline steps and tools that help the client accomplish those goals.
SW helps the client achieve sustainable balances of spending and saving
during their working years to minimize lifestyle changes between the client’s
working years and retirement years. Retirement planning by SW usually
involves, but is not limited to, calculating annual or monthly retirement
savings needs, reviewing current retirement vehicles the client is presently
using, reviewing potential retirement vehicles available for use by the client,
and presenting to the client simulations and other projections, charts, and
tools to help the client visualize their retirement goals, assess their progress
toward those goals, and increase their likelihood of achieving those goals.
• Estate Planning – Upon request, SW helps clients prepare and arrange for the
tax- efficient and cost-efficient disposition of their assets to their desired
beneficiaries. After gathering information provided by the client, SW reviews
the client’s overall situation, including, but not limited to, the titling and
location of assets and liabilities, the use of wills, trusts, family limited
partnerships, powers of attorney and medical directives, life insurance
policies, and the client’s state of residency. After review, SW works with the
client to determine the client’s specific goals. SW then recommends changes
intended to benefit the client and the beneficiaries. Typical generic goals
include, but are not limited to, helping the client eliminate uncertainties over
the administration of a probate, minimizing the costs of estate management
(including minimizing asset transfer costs, liability payoff costs, court costs,
appraisal costs, accounting and legal costs, as well as estate, gift, and
inheritance taxes), preserving confidentiality, ensuring timely asset transfers,
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confirming and implementing proper beneficiary designations, and helping
the client fulfill any gifting and/or charitable intentions. It should be noted that
SW does not practice law, and, therefore, SW works with licensed attorneys
to execute estate plans.
• Debt Management Planning – Upon request, SW analyzes a client’s
outstanding debts/liabilities in order to help the client maximize wealth. After
gathering information provided by the client, including details on income,
assets, and debts/liabilities, which may include, but are not limited to,
automobile loans, commercial loans, credit cards, home equity lines of
credit, installment loans, lines of credit, margin, medical debts, mortgages,
and student loans, SW works with the client to determine the best actions
the client should take regarding each debt/liability. SW analyzes the overall
impact and risks associated with each individual debt/liability position as well
as the overall impact and risks associated with the aggregate debt/liability
position given the client’s assets, income, age, and other factors. Depending
on the scope of the financial planning services requested and mutually
agreed upon, SW may also analyze and review with the client the effect the
debts/liabilities have on other financial planning areas, such as tax planning
and estate planning.
Cryptocurrency Services
Cryptoassets - Our firm offers Cryptoasset planning, and investment management services included
as part of our ongoing investment management fees. For clients engaging in investment
management service, there is no separate fee for Cryptoassets charged by our firm. Custodians,
exchanges and third parties may include fees for their service.
SW will offer cryptocurrency to clients through the qualified custodian, Gemini
(https://www/gemini.com/).
Selection of Other Advisers
SW can and will direct clients to sub-advisers. The client will not be directly engaged with the sub-
adviser. SW will enter an agreement with each sub-adviser for sub-advisory services to be provided
to SW clients. Each sub-adviser will deduct their management fees directly from the Advisory
Client’s account(s). Accounts enrolled in the Dynasty managed program will have one combined fee
deducted by Dynasty. This combined fee consists of the fee for Dynasty, SW, and SMA (if
applicable). Dynasty will remit SW’s fees (listed in section 5) to SW and SMA fee (if applicable) to
the SMA. SW does not receive any portion of the fees for Dynasty or the SMA (if applicable). Fees
are deducted or billed quarterly or monthly in advance. SW will always act in the best interests of
the client, including when determining which third party manager to recommend to clients. In
addition, SW will determine if the sub-adviser is properly licensed, notice filed or exempt from
registering with the department prior the manager to any SW clients.
Special Purpose Vehicles (“SPVs”)
SW sponsors a special purpose vehicle which is structured as a pooled investment vehicle and sold
under an exemption from registration under Regulation D of the Securities Act of 1933 (i.e., private
placements). The SPV is the Minerva RMC II. As the sponsor of the SPV, SW works with the SPV
administrator in making the various recommendations and decisions with respect to the SPV and its
operations, including, among other things, the approval of any new subscriptions, the sourcing,
acquisition, and disposition of the underlying investments and other fund assets.
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As the investment adviser of the SPV, SW is responsible for the day-to-day management of each
SPV’s invested assets based on their respective investment objectives as outlined in their private
placement memorandum and other governing documents (the “SPV Offering Documents”). The SPV
formed to hold a single investment in a privately held company (referred to herein as a “portfolio
company”). Each potential qualified investor receives a copy of the specific SPV’s Offering
Documents prior to investing in an SPV. It is important that each potential qualified investor fully read
the offering materials prior to investing for a complete understanding of, among other things, the
objectives, risks, fees, and conflicts associated with the SPV.
From time to time, SW recommends an SPV to SW clients that meet the regulatory qualifications and
where SW believes such an investment would be suitable for such clients. This creates a conflict of
interest because SW has an incentive since it is paid a performance fee by the SPV.
Please refer to Items 5, 6, and 10 below for further information, including how SW addresses
associated conflicts.
Please also refer to Form ADV Part 1, Schedule A for Item 7.B for further information specific to the
SPV.
Services Limited to Specific Types of Investments
SW generally limits its investment advice and/or money management to mutual funds, equities,
bonds, fixed income, ETFs, and insurance products including annuities. SW may use other
securities as well to help diversify a portfolio when applicable.
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C. Client Tailored Services and Client Imposed Restrictions
SW
offers the same suite of services to all of its clients. However, specific client financial plans and their
implementation are dependent upon the client Investment Policy Statement which outlines each
client’s current situation and is used to construct a client specific plan to aid in the selection of a
portfolio that matches restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that includes
management fees, transaction costs, fund expenses, and any other administrative fees. SW does
NOT participate in any wrap fee programs.
E. Amounts Under Management
As of December 2024, SW manages approximately $ 283,707,850 in assets on a discretionary
basis and did not manage any assets on a non-discretionary basis.
Item 5: Fees and Compensation
A. Fee Schedule
Investment Management Services Fees
The standard annual fee for investment management services is 1% of total assets under
management.
Investment advisory fees are paid quarterly or monthly, in advance of each calendar quarter,
pursuant to the terms of the investment advisory agreement. Investment advisory fees are based
on the market value of assets under management at the end of the prior calendar quarter.
Investment advisory fees will be adjusted based on in-flows and out-flows that occur in Client
Account during the prior calendar quarter.
The investment advisory fee in the first quarter of service is prorated from the inception date of
the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the
Advisor. The client’s fees will take into consideration the aggregate assets under management
with the Advisor. All securities held in accounts managed by Signify Wealth will be independently
valued by the Custodian. Signify Wealth will not have the authority or responsibility to value
portfolio securities.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and
custody fees, and other related costs and expenses described in Item 5.C below, which may be
incurred by the Client. However, the Advisor shall not receive any portion of these commissions,
fees, and costs.
Currently, if more than $10,000 in Assets are deposited or withdrawn after the beginning of a
quarter, the Fee will be prorated based on the number of days remaining in the quarter and
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adjusted in the following quarter. There may be a time in the future when this amount will increase
from $10,000 to $50,000 in Assets that are deposited or withdrawn after the beginning of the
quarter that an adjustment to the Fee will be made due to the fact of changing operational
platforms. If or when this occurs, the Clients will be notified of this change and given the
opportunity to discuss further with the firm. The firm will always act in its fiduciary capacity and in
the client’s best interests when any changes are made.
Negotiability of Fees & Other Terms
We retain the discretion to negotiate or waive all or a portion of our fee, any minimum account size
requirement, or other terms related to our relationship with any Client, and to negotiate alternative
fees, minimums, or other terms on a Client-by-Client, and service-by-service basis. When
negotiating these matters, we usually consider, among other factors, the size of the account,
anticipated future fees or other compensation, anticipated future additional assets from the Client
or related accounts, and existing or anticipated advisory, referral, or other relationships that may
benefit us. The specific terms of each Client's advisory arrangement will be agreed in writing
between SW and the Client.
Client Direct Investment Services
For client directed investments/funds, not recommended by the Adviser and possibly held outside
the custodians, the Adviser will charge an asset-based charge equal to .50% of the investment
value. New investments and accounts will be automatically enrolled in the fee structure and the
Adviser will provide an updated list periodically.
Selection of Other Advisers Fees
SW may direct clients to sub-advisers. The client will not be directly engaged with the sub- adviser.
SW will enter an agreement with each sub-adviser for sub-advisory services to be provided to SW
clients. Each sub-adviser will deduct their management fees directly from the Advisory Client’s
account(s). Accounts enrolled in the Dynasty managed program will have one combined fee
deducted by Dynasty. Each sub-adviser may charge additional transaction fees as described
under section 5C below. This combined fee consists of the fee for Dynasty, SW, and SMA (if
applicable). Dynasty will remit SW’s fees to SW and SMA fee (if applicable) to the SMA. SW does
not receive any portion of the fees for Dynasty or the SMA (if applicable). Fees are deducted or
billed quarterly or monthly in advance. SW will always act in the best interests of the client, including
when determining which third party manager to recommend to clients. In addition, SW will
determine if the sub-adviser is properly licensed, notice filed or exempt from registering with the
department prior the manager to any SW clients.
Managed Account Programs
The Client accounts under the Managed Account Program offered through Dynasty will be
charged an advisory fee based upon assets in accordance to the Investment Management
Agreement. Dynasty and the Third-Party Manager will charge fees that are separate from this
advisory fee. Dynasty’s fee will be up to 0.30% (30 bps) and the Third-Party Manager fee will be
up to 0.20% (20bps). The Client’s account statement for the Managed Account Program will most
likely reflect a single fee for the program (shared between SW, Dynasty, and/or Third-Party
Manager).
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Cryptoassets
Cryptoassets planning and investment management services are offered at no additional cost to
our clients. Cryptoasset custodians, exchanges and third parties may charge fees for their service.
Our firm has discretionary management without any material limitations.
Special Purpose Vehicles
SW does not charge a management fee to the SPV. However, as the investment adviser, SW is
eligible to receive a performance-based payment, which is outlined in the Offering Documents
relating to the SPV and summarized in Item 6 below.
B. Payment of Fees
Payment of Investment Supervisory Fees
Advisory fees are withdrawn directly from the client’s accounts with client written authorization.
Fees are paid quarterly or monthly in advance. The qualified custodian(s) delivers brokerage
account statements to clients on a monthly basis showing all holdings and activity in the clients’
brokerage accounts, including the quarterly or monthly fees paid to SW. Upon request from client,
SW creates a billing analysis which shows the fee amounts, calculations of the fees, total assets
under management, itemization of the assets under management, the time period covered, and
contact information for the direction of any questions or comments.
C. Clients Are Responsible For Third Party Fees
Clients are responsible for the payment of all third party fees (Third-Party Managers, brokerage
commissions, mark-ups and mark-downs on fixed-income transactions, other transaction costs and
expenses, fees and expenses charged by mutual funds and exchange traded funds (including,
without limitation, transaction costs, 12b-1 fees, and sales charges), fees imposed by variable annuity
providers, account maintenance fees, odd-lot differentials, transfer taxes, and wire transfer,
electronic fund fees etc. Those fees are separate and distinct from the fees and expenses charged
by SW. Please see Item 12 of this brochure regarding broker/custodian.
D. Prepayment of Fees
SW collects fees in advance. Fees that are collected in advance will be refunded based on the
prorated amount of work completed at the point of termination and the total days during the billing
period. Fees will be returned within fourteen days to the client via check or credited to the account
withdrawn.
The fee refunded will be the balance of the fees collected in advance minus the daily rate* times
the number of days in the quarter up to and including the day of termination. (*The daily rate is
calculated by dividing the quarterly AUM fee by the number of days in the termination quarter).
E. Outside Compensation For the Sale of Securities to Clients
Certain Investment Advisor Representatives of SW are licensed Insurance Agents. This
information is further detailed as disclosed in ITEM 10. In these capacities, individuals will collect
additional compensation in the form of commissions for insurance products sold.
The acceptance of additional compensation for products presents a conflict of interest; there is
an incentive to recommend insurance products based on the compensation received, rather than
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on client need.
Clients should note that similar insurance services may (or may not) be available from other
insurance agents for similar or lower fees. Clients have the option to purchase investment
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products that are recommended by your Investment Advisor Representative, through other
brokers or agents that do not affiliate with Signify Wealth LLC.
Item 6: Performance-Based Fees and Side-By-Side Management
SPV Performance Fees
SW does not charge an advisory fee on SPV assets. However, SW receives a “Carry
Percentage”, which is a portion of the “Carried Interest”, which is a portion of the total profits
produced by the SPV. SW will receive 5% (or 20% of the Carry Percentage) for its efforts as co-
manager to the SPV. Before any carry is paid out, the Members of the SPV will receive their initial
investment and performance returns in accordance with the terms of RMC II’s PPM. The overall
carried interest is 25%, which is higher than a typical 20% of the profits. Thus, a conflict of interest
arises in that the co-Managers are incentivized to make riskier investment decisions so that they
may achieve a higher profit. Moreover, clients should note that lower fees for comparable
investments are available from other advisers and sources and Signify clients are not obligated
to invest in the SPV.
Conflicts of Interest Surrounding FCA Performance Based Fees
Charging a performance-based fee creates conflicts of interest because: (i) there is an incentive
for SW to make more speculative/riskier investment recommendations and make different
decisions regarding the timing and manner of the realization of such investments, than would be
made if such performance-based fee was not part of the overall compensation structure, and (ii)
it can cause SW to favor certain investments for clients that are charged performance-based fee
than other clients who are not charged a performance- based fee.
To maintain fair and equitable treatment of all of its clients, SW takes steps to mitigate any potential
and actual conflicts of interest relating to this type of arrangement, which include disclosing the matter
in this Brochure, assessing whether such a speculative investment is consistent with a particular
client’s stated investment objectives, always putting the interests of its clients first, and identifying and
disclosing the performance-based fee investments to prospective and existing clients.
Item 7: Types of Clients
SW generally provides investment advice and/or management supervisory services to the following
types of clients:
❖
Individuals
❖ High-Net-Worth Individuals
❖ Privately held small business entities
Minimum Account Size
There is an account minimum, $250,000, which may be waived by the SW.
Item 8: Methods of Analysis, Investment Strategies, and
Risk of Investment Loss
A. Methods of Analysis and Investment Strategies
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Methods of Analysis
SW’s methods of analysis include fundamental analysis and technical analysis.
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages.
Technical analysis involves the analysis of past market data; primarily price and volume.
Investment Strategies
SW uses both short- and long-term trading.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
B. Material Risks Involved
Methods of Analysis
Fundamental analysis concentrates on factors that determine a company’s value and expected
future earnings. This strategy would normally encourage equity purchases in stocks that are
undervalued or priced below their perceived value. The risk assumed is that the market will fail to
reach expectations of perceived value.
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Technical analysis attempts to predict a future stock price or direction based on market trends. The
assumption is that the market follows discernible patterns and if these patterns can be identified
then a prediction can be made. The risk is that markets do not always follow patterns and relying
solely on this method may not work long term.
Investment Strategies
Short term trading generally holds greater risk and clients should be aware that there is a material
risk of loss using this strategy.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
C. Risks of Specific Securities Utilized
SW generally seeks investment strategies that do not involve significant or unusual risk beyond that
of the general domestic and/or international equity markets.
Mutual Funds: Investing in mutual funds carries the risk of capital loss. Mutual funds are not
guaranteed or insured by the FDIC or any other government agency. You can lose money
investing in mutual funds. All mutual funds have costs that lower investment returns. They can be
of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned above).
Equity investment generally refers to buying shares of stocks by an individual or firms in return for
receiving a future payment of dividends and capital gains if the value of the stock increases. There
is an innate risk involved when purchasing a stock that it may decrease in value and the investment
may incur a loss.
Fixed Income is an investment that guarantees fixed periodic payments in the future that may
involve economic risks such as inflationary risk, interest rate risk, default risk, repayment of
principal risk, etc.
Alternative Investments: Alternative investments, including (but not limited to) investment
partnerships, alternative mutual funds, non-traditional ETFs, managed futures, and/or real estate
(related) investments may also present unique risks, such as decreased liquidity and
transparency and increased complexity. Alternative investments typically use derivative
instruments (such as options, futures, or index-based instruments) and/or leveraging strategies.
The use of derivative instruments involves multiple risks, as discussed in more detail above. In
addition, to the extent that the alternative investment uses commodities (or commodity-based
derivatives) as part of its investment strategy, the investment return may also vary as a result of
fluctuations in the supply and demand of the underlying commodities. Certain alternative
investments may be less tax efficient than others. Additional risks may include style-specific risk,
speculative investment risk, concentration risk, correlation risk, credit risk and lower-quality debt
securities risk, equity securities risk, financial services companies’ risk, interest rate risk, non-
diversification risk, small- and mid-cap company risk, and special risks of mutual funds and/or
ETFs, among others.
Unaffiliated Private Pooled Investment Vehicles: SW recommends that certain clients invest in
privately placed unaffiliated pooled investment vehicles. This may include but is not limited to
hedge funds, private equity funds, venture capital funds, direct lending funds, and real estate
funds. The managers of these vehicles have broad discretion in selecting the investments. There
are few limitations on the types of securities or other financial instruments which may be traded,
and there is no requirement to diversify. The vehicles may trade on margin or otherwise leverage
positions, thereby potentially increasing a vehicle’s risk profile. In addition, because the vehicles
are not registered as investment companies or securities, there is an absence of regulation. There
are numerous other risks in investing in these securities and the specific vehicles that the Firm
may recommend, such as limited liquidity, higher fees, limited transparency, and heightened risk
of loss. When FCA recommends these types of investments, the firm will ensure the clients
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receive a copy of the private placement memorandum and other offering documents for the
recommended fund(s), which outline all the associated risks, among other things, and it is
important for clients to fully review these documents prior to investing.
An investment in the SPV is speculative and involves a high degree of risk. An SPV’s performance
can be volatile and is therefore only suitable for investors that are sophisticated and can afford
fluctuations in the value of their capital investment, in addition to meeting regulatory qualification
requirements. There can be no assurance that the SPV’s investment objectives will be achieved
or that investors will receive a return of their capital investment. An investor could lose all or a
substantial amount of their investment in an SPV. Also, an investment in an SPV has limited
liquidity and there are restrictions on an investor’s ability to withdraw and transfer their interest.
There are additional risks and conflicts associated with an investment in an SPV that potential
investors should be aware of prior to investing. To that end, potential investors are provided with
the Offering Documents of the specific SPV associated with their potential investment, which
contain detailed information on the conflicts and risks associated with an investment in the SPVs
and should be read fully.
Stocks & Exchange Traded Funds (ETF): Investing in stocks & ETF's carries the risk of capital loss
(sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in these
securities are not guaranteed or insured by the FDIC or any other government agency.
Short term trading risks include liquidity, economic stability and inflation.
Cryptocurrency investing refers to trading in digital or virtual currencies, such as Bitcoin, that are
not back by real assets or tangible securities. They are traded between consenting parties with no
broker and tracked on digital ledgers commonly known as blockchains. Due to the nature of
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cryptocurrencies, clients are exposed to the risks normally associated with investing but also
unique risks not typical of investing in traditional securities. These risks include, but are not limited
to the following:
• Unregulated – currently cryptocurrencies are unregulated by both governments
and central banks.
•
Increased Price Volatility – the price of cryptocurrency is constantly fluctuating.
Trade or balance can surge or drop suddenly. Price can drop to zero.
• Trade Execution – there is a risk that cryptocurrency trades may not be executed at
the price and/or time requested due to market volatility, systematic slowdowns, or
unexpected technical issues.
• Susceptible to Error/Hacking – technical glitches, human error and/hacking can
occur, which typically do not affect traditional securities
• Forks – this implies a splitting of the chain on which the cryptocurrency runs, which
makes it go in a different direction, with different rules than the existing blockchain.
o Soft Fork – only a protocol change; the crypto currency still continues to
work on the original blockchain rules.
o Hard Fork – a permanent divergence in the blockchain. This is a radical
change to a network’s protocol that effectively results in two branches, one
that follows the previous protocol and one that follows the new version.
Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss
that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
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Neither SW nor its representatives are registered as, or have pending applications to become, a
broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor
Neither SW nor its representatives are registered as or have pending applications to become a
Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor.
C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
Stephen P. Rhodes is an owner of Promise Properties which he oversees his personal rental
properties.
Stephen P. Rhodes is the owner of Katalysis Ventures LLC, a holding company for his personal
private investments. His responsibilities include analyzing and overseeing private investment. 2
hours and month during and outside of trading hours are spent on this activity. 0 yearly
compensation is expected to be derived from the business.
Stephen P. Rhodes is a licensed insurance agent. This activity creates a conflict of interest since
there is an incentive to recommend insurance products based on commissions or other benefits
received from the insurance company and its representatives, rather than on the client’s needs.
Additionally, the offer and sale of insurance products by supervised persons of SW are not made in
their capacity as a fiduciary, and products are limited to only those offered by certain insurance
providers. SW addresses this conflict of interest by requiring its supervised persons to act in the best
interest of the client at all times, including when acting as an insurance agent. SW periodically
reviews recommendations by its supervised persons to assess whether they are based on an
objective evaluation of each client’s risk profile and investment objectives rather than on the
receipt of any commissions or other benefits. SW will disclose in advance how it or its supervised
persons are compensated and will disclose conflicts of interest involving any advice or service
provided. At no time will there be tying between business practices and/or services (a condition
where a client or prospective client would be required to accept one product or service conditioned
upon the selection of a second, distinctive tied product or service). No client is ever under any
obligation to purchase any insurance product. Insurance products recommended by SW’s
supervised persons may also be available from other providers on more favorable terms, and
clients can purchase insurance products recommended through other unaffiliated insurance
agencies.
Stephen P. Rhodes is an owner of Signify Business Management LLC.
Signify Business Management LLC, an affiliate of Signify Wealth LLC, is a bookkeeping, and
business management firm. From time to time, representatives of Signify Wealth LLC, in their
separate capacity as bookkeeper/business manager, will offer clients products from those
activities. Clients should be aware that these services pay compensation and thus involve a
conflict of interest. Signify Wealth LLC always acts in the best interest of the client. Clients are in
no way required to purchase any product or service through any representative of Signify Wealth
LLC in such individual’s capacities.
Stephen P. Rhodes is the owner of Signify Holdings Corporation. Holding Company for Signify
Wealth LLC
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Stephen P. Rhodes is the co- owner of 12 Enterprises LLC. Business used for buying, repairing and
selling real estate properties.
Stephen P. Rhodes is the owner of Signify University LLC.
Signify Wealth LLC is related through common ownership and control to Signify University LLC
(hereinafter “Signify University”). Though not owned by Signify Wealth LLC, Signify University is
owned by the owner of Signify Wealth LLC and is under common control. This entity provides
financial education and literacy courses to the general public as well as clients of Signify Wealth.
Certain Signify Wealth LLC Managing Member(s), Investment Advisor Representatives and
employees act in a separate capacity for this entity. Because of the affiliated nature, referral to
Signify University LLC presents a conflict of interest as both firms have an economic incentive to
refer clients to each other as opposed to other tax providers.
Stephen P. Rhodes is the owner of Talent Commerce Summit (“TCS”). TCS is separate and
distinct from all Signify entities and provides talent management marketing solutions.
Use of Signify University LLC requires separate engagement with this company. It’s important
that you know that when we recommend the services of Signify University, you are never obligated
or required to use their services. There are other financial education firms that offer similar
services to Signify University, and those services may be available for less expensive rates.
Whenever we recommend Signify University, we encourage you to consider other financial
education firms as well.
D. Selection of Other Advisers or Managers and How This Adviser is
Compensated for Those Selections
SW maintains a business relationship with Dynasty, which provides the Firm access to trading
technology, reporting and investments through an open architecture system. The Firm also
recommends Dynasty's subsidiary, Dynasty Wealth Management, a registered investment
adviser, to clients for its Managed Account Program. While SW believes this open architecture
structure for both operational and investment services best serve the interests of its advisory
clients, this relationship may potentially present certain conflicts of interest due to the fact that
Dynasty retains a portion of the platform or other third-party fees paid by the Firm or clients for the
services referenced above. In light of the foregoing, SW seeks at all times to ensure that any
material conflicts are addressed on a fully disclosed basis and handled in a manner that is aligned
with its clients' best interests. SW does not receive any portion of the fees paid directly to Dynasty,
its affiliates or the service providers made available through Dynasty's platform. In addition, the
Firm reviews all such relationships, including the service providers engaged through Dynasty, on
a periodic basis in an effort to ensure clients are receiving competitive rates in relation to the
quality and scope of the services provided.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
We have a written Code of Ethics that covers the following areas: Prohibited Purchases and
Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited
Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of
Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and
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Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training
and Education, Record keeping, Annual Review, and Sanctions. Our Code of Ethics is available
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free upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
SW does not recommend that clients buy or sell any security in which a related person to SW or
SW has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of SW will buy or sell securities for themselves that are also
recommend to clients. This could provide an opportunity for representatives of SW to buy or sell
the same securities as part of a block trade, as described in Item 12B below, with clients. In some
cases, such transactions create a conflict of interest. SW will always document any transactions
that could be construed as conflicts of interest and will never engage in trading that operates to
the client’s disadvantage when similar securities are being bought or sold.
D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of SW will buy or sell securities for themselves that are also
recommend to clients. This could provide an opportunity for representatives of SW to buy or sell
the same securities as part of a block trade, as described in Item 12B below, with clients. In some
cases, such transactions create a conflict of interest. SW will always document any transactions
that could be construed as conflicts of interest and will never engage in trading that operates to
the client’s disadvantage when similar securities are being bought or sold. To mitigate or remedy
any conflicts of interest or perceived conflicts of interest, SW will monitor its proprietary and
personal trading reports quarterly for adherence to its Code of Ethics. If a conflict arises, SW will
cancel the trade of the representative and credit the difference to the client.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
The Custodian and Brokers We Use
SW (“we/our”) does not maintain custody of your assets that we manage (although we may be
deemed to have custody of your assets if you give us authority to withdraw assets from your
account (see Item 15 Custody, below). Your assets must be maintained in an account at a
“qualified custodian,” generally a broker-dealer or bank. We require that our clients use Charles
Schwab & Co., Inc. (Schwab), a FINRA-registered broker-dealer, member SIPC, as the qualified
custodian. We are independently owned and operated and not affiliated with Schwab. Schwab will
hold your assets in a brokerage account and buy and sell securities when we instruct them to. While
we require that you use Schwab as custodian/broker, you will decide whether to do so and open
your account with Schwab by entering into an account agreement directly with them. We do not
open the account for you. Not all advisors require their clients to use a particular broker-dealer or
other custodian selected by the advisor. Even though your account is maintained at Schwab, we
can still use other brokers to execute trades for your account, as described in the next paragraph.
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How We Select Brokers/Custodians
We seek to require a custodian/broker who will hold your assets and execute transactions on terms
that are overall most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others, these:
• combination of transaction execution services along with asset custody services
(generally without a separate fee for custody)
• capability to execute, clear and settle trades (buy and sell securities for your
account)
• capabilities to facilitate transfers and payments to and from accounts (wire
transfers, check requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds,
exchange traded funds (ETFs), etc.)
• availability of investment research and tools that assist us in making investment
decisions
• quality of services
• competitiveness of the price of those services (commission rates, margin interest
rates, other fees, etc.) and willingness to negotiate them
reputation, financial strength, and stability of the provider
their prior service to us and our other clients
•
•
• availability of other products and services that benefit us, as discussed below
(see “Products and Services Available to Us from Schwab”)
Your Custody and Brokerage Costs
For our clients’ accounts it maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it
executes or that settle into your Schwab account. For some accounts, Schwab may charge you a
percentage of the dollar amount of assets in the account in lieu of commissions. This commitment
benefits you because the overall commission rates or asset-based fees you pay are lower than
they would be if we had not made the commitment. In addition to commissions [or] asset-based
fees Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each
trade that we have executed by a different broker-dealer but where the securities bought or the
funds from the securities sold are deposited (settled) into your Schwab account. These fees are in
addition to the commissions or other compensation you pay the executing broker-dealer. Because
of this, in order to minimize your trading costs, we have Schwab execute most trades for your
account.
Products and Services Available to Us from Schwab
Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like
us. They provide us and our clients with access to its institutional brokerage – trading, custody,
reporting and related services – many of which are not typically available to Schwab retail
customers. Schwab also makes available various support services. Some of those services help
us manage or administer our clients’ accounts while others help us manage and grow our business.
Schwab’s support services are generally available on an unsolicited basis (we don’t have to
request them) and at no charge to us as long as we keep a total of at least
$10 million of our clients’ assets in accounts at Schwab. If we have less than $10 million in client
assets at Schwab, it may charge us quarterly service fees. Here is a more detailed description of
Schwab’s support services:
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Services that Benefit You. Schwab’s institutional brokerage services include access to a broad
range of investment products, execution of securities transactions, and custody of client assets. The
investment products available through Schwab include some to which we might not otherwise
have access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit you and your account.
Services that May Not Directly Benefit You. Schwab also makes available to us other products and
services that benefit us but may not directly benefit you or your account. These products and
services assist us in managing and administering our clients’ accounts. They include investment
research, both Schwab’s own and that of third parties. We may use this research to service all or
some substantial number of our clients’ accounts, including accounts not maintained at Schwab.
In addition to investment research, Schwab also makes available software and other technology
that:
• provide access to client account data (such as duplicate trade confirmations and
•
account statements);
facilitate trade execution and allocate aggregated trade orders for multiple
client accounts;
facilitate payment of our fees from our clients’ accounts; and
• provide pricing and other market data;
•
• assist with back-office functions, record keeping and client reporting.
Services that Generally Benefit Only Us. Schwab also offers other services intended to help us
manage and further develop our business enterprise. These services include:
technology, compliance, legal, and business consulting;
• educational conferences and events
•
• publications and conferences on practice management and business succession;
• and access to employee benefits providers, human capital consultants and
insurance providers. Schwab may provide some of these services itself. In other
cases, it will arrange for third-party vendors to provide the services to us. Schwab
may also discount or waive its fees for some of these services or pay all or a part of
a third party’s fees. Schwab may also provide us with other benefits such as
occasional business entertainment of our personnel.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services so long as we keep a total of at least
$10 million of client assets in accounts at Schwab. Beyond that, these services are not contingent
upon us committing any specific amount of business to Schwab in trading commissions or assets
in custody. The $10 million minimum may give us an incentive to require that you maintain your
account with Schwab based on our interest in receiving Schwab’s services that benefit our
business rather than based on your interest in receiving the best value in custody services and the
most favorable execution of your transactions. This is a potential conflict of interest. We believe,
however, that our selection of Schwab as custodian and broker is in the best interests of our clients.
It is primarily supported by the scope, quality and price of Schwab’s services (based on the factors
discussed above – see “How We Select Brokers/Custodians) and not Schwab’s services that
benefit only us. We have over $10 million in client assets under management, and do not believe
that maintaining at least $10 million of those assets at Schwab in order to avoid paying Schwab
quarterly service fees presents a material conflict of interest.
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We will require clients to use Gemini Trust Company, LLC cryptocurrency accounts. Gemini is a
fiduciary and qualified custodian under New York Banking Law and is licensed by the State of New
York to custody digital assets. Client’s crypto assets are held in Gemini accounts only. We only
have access to make investment decisions and has no authority to withdraw funds. We use third
party research to assess investment opportunities in cryptocurrencies and follows the SEC
guidelines to ensure compliance with applicable laws.
B. Aggregating (Block) Trading for Multiple Client Accounts
If SW buys or sells the same securities on behalf of more than one client (including
representatives of SW), it might, but would be under no obligation to, aggregate or bunch, to the
extent permitted by applicable law and regulations, the securities to be purchased or sold for
multiple Clients in order to seek more favorable prices, lower brokerage commissions or more
efficient execution. In such case, SW would place an aggregate order with the broker on behalf of
all such clients in order to ensure fairness for all clients; provided, however, that trades would be
reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy.
SW would determine the appropriate number of shares to place with brokers and will select the
appropriate brokers consistent with SW’s duty to seek best execution, except for those accounts
with specific brokerage direction (if any).
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
Client accounts are reviewed on a quarterly basis by the Adviser assigned to the client.
All financial planning accounts are reviewed upon financial plan creation and plan delivery by their
designated advisors. There is only one level of review and that is the total review conducted to
create the financial plan.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by material market, economic or political events, or by changes in
client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Clients are advised to notify SWQ promptly if there are any material changes in their financial
situation, or investment objectives, or in the event they wish to place restrictions on their account.
C. Content and Frequency of Regular Reports Provided to Clients
Each client will receive at least quarterly from the custodian, a written report that details the client’s
account including assets held and asset value which will come from the custodian.
Clients are provided a one-time financial plan concerning their financial situation. After the
presentation of the plan, there are no further reports. Clients may request additional plans or
reports for a fee.
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Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients
(Includes Sales Awards or Other Prizes)
SW does not receive any economic benefit by third parties for advice rendered to clients. All
Charles Schwab benefits are listed above in section 12A.
B. Compensation to Non –Advisory Personnel for Client Referrals
SW does directly and indirectly compensate any person who is not advisory personnel for client
referrals.
Item 15: Custody
Custody means holding, directly or indirectly, client funds or securities, or having any authority to
obtain possession of them.
“Qualified Custodians” include types of financial institutions such as banks, broker-dealers,
futures commission merchant or any other entity that maintains client securities and funds that
clients and advisers use for custodial services.
When SW deducts fees directly from client accounts at a selected custodian, SW will be deemed to
have limited custody of client’s assets and must have written authorization from the client to do
so. Clients will receive all account statements and billing invoices that are required in each
jurisdiction, and they should carefully review those statements for accuracy.
SW may also be deemed to have custody over the funds and securities of trust accounts for which
it or its related persons serve in a capacity to assist clients with various financial transactions. SW
will follow custody rules for the accounts and clients for which SW has bill pay authority. As some
arrangements fall outside the scope of a SLOA (standing letter of authorization) SW will follow the
steps set forth in the SEC guidance issued in February 2017.
Based on the regulatory definition of custody, Signify Wealth LLC is deemed to have custody over
client funds due first to SW’s member managers’ affiliation with their business management and
bookkeeping services firm, Signify Business Management LLC. Signify Business Management
LLC usually has authority to initiate transactions from a client’s bank accounts. Such authority is
usually granted by the client when signing an agreement with Signify Business Management LLC.
To protect Signify Wealth clients, SW has established the following procedures:
• Funds of clients are held at independent banks, brokers/dealers, and/or qualified
custodians in separate accounts in the names of the clients.
• Clients receive brokerage account statements monthly directly
from
the
brokers/dealers and/or qualified custodians.
• Clients receive bank account statements monthly directly from the independent
banks.
• SW does not authorize or allow any bank account besides the client’s primary
checking account to be linked to the client’s brokerage accounts. Therefore, the
only distributions allowed from the client’s brokerage accounts are transfers to the
client’s primary checking account, which is enforced by the qualified custodian.
• SW arranges annual surprise examinations with an Independent Public Accountant
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Item 16: Investment Discretion
For those client accounts where SW provides ongoing supervision, the client has given SW written
discretionary authority over the client’s accounts with respect to securities to be bought or sold
and the amount of securities to be bought or sold. Details of this relationship are fully disclosed to
the client before any advisory relationship has commenced. The client provides SW discretionary
authority via a limited power of attorney in the Investment Advisory Contract and in the contract
between the client and the custodian.
Item 17: Voting Client Securities (Proxy Voting)
Signify Wealth will not vote proxies which are solicited for securities held in client accounts. For
accounts that do not participate in a Managed Account Program, we require the Client to retain responsibility for
voting all account securities. We will not vote, exercise rights, make elections, or take other such actions with
respect to securities held for accounts we manage. If desired, a Client may instruct us in writing to
forward to the Client or a third-party materials we receive pertaining to proxy solicitations or similar matters.
Upon our receipt of such written instructions, we will use commercially reasonable efforts to forward such
materials in a timely manner. In the absence of the Client's written request, we will discard account
proxy and related materials.
Clients may obtain proxy materials by written request to the account's custodian. For information
about how to obtain proxy materials from a custodian, Clients may contact us by telephone at 314-
222-0295 or by mail sent to the attention of our Chief Compliance Officer at the street address
shown on the front of this Disclosure Brochure. However, we will not provide advice about the
issues raised by any proxy solicitation or other request for action.
For accounts that participate in a Managed Account Program, authority to vote account securities
is usually delegated to the Third-Party Manager or the Sponsor; however, the Client must refer to
the terms of his or her specific agreement to determine whether the Client is permitted or required
to delegate proxy voting authority to the Sponsor or a Third-Party Manager. These terms will vary
by Program and Third-Party Manager.
Similarly, we will not advise or exercise rights, make elections, or take other actions with respect
to legal proceedings involving companies whose securities are or were held in the Client's
account, including asserting any claims or voting in bankruptcy or reorganization proceedings, or
filing "proofs of claim" in class action litigation. If desired, a Client may instruct us in writing to
forward to the Client or a third party any materials we receive pertaining to such matters. Upon
our receipt of such written instructions, we will use commercially reasonable efforts to forward such
materials in a timely manner. In the absence of the Client's written request, we will discard such
materials.
Item 18: Financial Information
A. Balance Sheet
SW does not require nor solicit prepayment of more than $1,200 in fees per client, six months or
more in advance and therefore does not need to include a balance sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
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SW does not have any financial impairment that would preclude the Firm from meeting contractual
commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
Neither SW nor one associated has file bankruptcy petitions in the previous 10 years.
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Privacy Policy
Privacy Policy
An important part of the relationship we have with our clients is the information they share with
us. We want each client to know how we treat their private information. We keep personal
information such as Social Security Numbers and account balances confidential. We take steps
to safeguard this data from anyone who should not have access to it. We do not sell this
information to anyone.
In dealing with Signify Wealth, LLC clients can expect that we will take the steps outlined below
to keep all their information confidential and secure.
Our Privacy Policy
In providing financial services and products (“Service”) to our clients, we collect certain non-public
information about them. Our policy is to keep this information confidential and strictly safeguarded,
and to use or disclose it only as needed to provide services to our clients, or as permitted by law.
Protecting your privacy is important to us.
Information We Collect
The non-public personal information we have about clients includes the information they give us
when opening an account or communicating with us. This could include:
•
•
•
•
•
•
Name and address
Social Security Number
Investment objectives and experience
Financial circumstances
Employment history
Account balances and transactions
How We Share Your Personal Information
We do not sell personal client information to anyone.
Affiliates. We may share personal information about you with our affiliated companies for
everyday business purposes, however, our affiliated companies are not permitted to use this
information to market their products or services to you.
We do not disclose personal information about our clients to non-affiliated third parties, without
expressed written consent. We may disclose anonymous information that cannot be linked to an
individual client on occasion, but only to companies that we hire to help us provide products and
services to our clients, or as required by law, or as authorized by the client personally, or as
otherwise described in this Privacy Policy.
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Service Providers. Companies and individuals that provide services on our behalf or help us
operate our services and business (such as IT, hosting, investment trading, customer relationship
management and support, print and mail fulfillment, data management, email delivery, etc.).
Service-Related Third Parties. Brokers, custodians, administrators, transfer agents, investment
funds and their respective managed and other non-affiliated third parties as necessary to provide
our services to you.
How Information Is Used
We use your personal information for the following purposes:
Service Delivery. We use your personal information to provide, operate, and improve the Service;
execute your transactions; provide support for the service; and respond to you inquires, questions
and feedback.
Compliance and Operations. We may use your personal information to: comply with applicable
laws, lawful requests, and legal process, such as to respond to subpoenas or requests from
government authorities; protect our, your or others’ rights, privacy, safety or property (including
by making and defending legal claims); audit our internal processes for compliance with legal and
contractual requirements and internal policies; and prevent, identify, investigate and deter
fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity
theft.
How Information Is Safeguarded
We have procedures in place that we believe are reasonably designed to protect the security and
confidentiality of client information. These include confidentiality agreements with companies we
hire to help us provide services to clients, password-protected user access to our computer files,
and strict confidentiality policies that apply to all Signify personnel, vendors and contractors.
You have the following choices with respect to your personal information:
Your Data Choices
Decline to provide information. We need to collect personal information to provide certain
services. If you do not provide the information requested, we may not be able to provide those
services.
How to contact us. You can reach us in the following ways:
•
•
•
Mail: 7750 Clayton Road Suite 100, St. Louis, Missouri, 63117
Email: info@signifywealth.com
Phone: (314) 222-0295
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