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SilverLake Wealth Management, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: June 30, 2025
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of SilverLake Wealth Management, LLC (“SilverLake” or the “Advisor”). If you have any questions about the
contents of this Disclosure Brochure, please contact the Advisor at (802) 857-5083 or by email at
info@silverlakewealth.com.
SilverLake is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about SilverLake to assist you in determining whether to retain the
Advisor.
Additional information about SilverLake and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor firm name or CRD# 165525.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone: (802) 857-5083 | Fax: (802) 857-5082
www.silverlakewealth.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about Advisory
Persons of SilverLake. For convenience, the Advisor has combined these documents into a single disclosure
document.
SilverLake believes that communication and transparency are the foundation of its relationship and continually
strives to provide you with complete and accurate information at all times. SilverLake encourages all current and
prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment filing on
February 23rd, 2024.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations, or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs in the business practices of SilverLake.
At any time, you may view the current Disclosure Brochure online at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 165525.
You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (802) 857-
5083 or by email at info@silverlakewealth.com.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ...................................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................ 2
Item 3 – Table of Contents ........................................................................................................................... 3
Item 4 – Advisory Services .......................................................................................................................... 5
A. Firm Information ................................................................................................................................................... 5
B. Advisory Services Offered ................................................................................................................................... 5
C. Client Account Management ................................................................................................................................ 7
D. Wrap Fee Programs ............................................................................................................................................ 8
E. Assets Under Management ................................................................................................................................. 8
Item 5 – Fees and Compensation ................................................................................................................ 8
A. Fees for Advisory Services .................................................................................................................................. 8
B. Fee Billing ............................................................................................................................................................ 9
C. Other Fees and Expenses ................................................................................................................................... 9
D. Advance Payment of Fees and Termination ...................................................................................................... 10
E. Compensation for Sales of Securities ................................................................................................................ 10
Item 6 – Performance-Based Fees and Side-By-Side Management ....................................................... 11
Item 7 – Types of Clients ............................................................................................................................ 11
Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss .............................................. 11
A. Methods of Analysis ........................................................................................................................................... 11
B. Risk of Loss ....................................................................................................................................................... 12
Item 9 – Disciplinary Information .............................................................................................................. 13
Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 13
Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .... 14
A. Code of Ethics .................................................................................................................................................... 14
B. Personal Trading with Material Interest ............................................................................................................. 14
C. Personal Trading in Same Securities as Clients ................................................................................................ 14
D. Personal Trading at Same Time as Client ......................................................................................................... 14
Item 12 – Brokerage Practices ................................................................................................................... 14
A. Recommendation of Custodian[s] ...................................................................................................................... 14
B. Aggregating and Allocating Trades .................................................................................................................... 15
Item 13 – Review of Accounts ................................................................................................................... 16
A. Frequency of Reviews ....................................................................................................................................... 16
B. Causes for Reviews ........................................................................................................................................... 16
C. Review Reports ................................................................................................................................................. 16
Item 14 – Client Referrals and Other Compensation ............................................................................... 16
A. Compensation Received by SilverLake ............................................................................................................. 16
B. Compensation for Client Referrals ..................................................................................................................... 17
Item 15 – Custody ....................................................................................................................................... 17
Item 16 – Investment Discretion ................................................................................................................ 17
Item 17 – Voting Client Securities ............................................................................................................. 18
Item 18 – Financial Information ................................................................................................................. 18
Form ADV Part 2B – Brochure Supplement: Briand, Richard ................................................................ 19
Form ADV Part 2B – Brochure Supplement: Eddy, Robert .................................................................... 22
Form ADV Part 2B – Brochure Supplement: Golonka, Thomas ............................................................. 25
Form ADV Part 2B – Brochure Supplement: Steele, Jeffrey .................................................................. 29
Form ADV Part 2B – Brochure Supplement: Riehle, Theodore .............................................................. 32
Form ADV Part 2B – Brochure Supplement: Eddy, Derek ...................................................................... 35
Form ADV Part 2B – Brochure Supplement: Bergmann, Ryan…………………………………………….39
Form ADV Part 2B – Brochure Supplement: Steele, Gregory……………………………………………...42
Form ADV Part 2B – Brochure Supplement: Thorton, Patrick...…………………………………………...44
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 3
Form ADV Part 2B – Brochure Supplement: Hubert, John Henry……………………………………….. 45
Form ADV Part 2B – Brochure Supplement: Smith, Hans Frederick……………………………...…….. 48
Privacy Policy ............................................................................................................................................. 50
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 4
Item 4 – Advisory Services
A. Firm Information
SilverLake Wealth Management, LLC (“SilverLake” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). SilverLake was organized as a Limited Liability Company
(“LLC”) under the laws of the State of Vermont in March 2002. SilverLake became a registered investment
advisor in December 2012. SilverLake is owned and operated by Managing Partners Richard J. Briand, Robert
Eddy, Thomas Golonka, Theodore Riehle, and Jeffrey Steele. This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by SilverLake.
B. Advisory Services Offered
SilverLake offers investment advisory services to individuals, high net worth individuals, trusts, estates,
retirement plans, charitable organizations, and corporations (each referred to as a “Client”), and unaffiliated
registered investment advisors.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to
mitigate potential conflicts of interest. SilverLake’s fiduciary commitment is further described in the Advisor’s
Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics,
Participation or Interest in Client Transactions and Personal Trading.
Investment Management Services
SilverLake’s investment philosophy is customized to the needs of each Client based on a deep understanding of
the Client’s long-term goals. SilverLake provides continuous personal Client contact and interaction while
providing investment management and consulting services. SilverLake primarily offers discretionary and non-
discretionary investment management services, but Clients may request such services to be provided on a non-
discretionary basis. SilverLake works with each Client to identify their investment goals and objectives as well as
risk tolerance and financial situation in order to create an investment strategy. The Advisor may retain other
types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related
reasons, or other reasons as identified between the Advisor and the Client.
SilverLake will then construct a portfolio consisting of individual equity securities, individual fixed income
securities, diversified mutual funds, exchange-traded funds (“ETFs”), and/or stocks to achieve the Client’s
investment goals. The Advisor may also utilize other investment types, as appropriate, to meet the needs of its
Clients. Diversification is sought to reduce overall portfolio risk, which can include using different asset classes
as well as different sectors/industries.
Depending on the needs of each Client, SilverLake may create a customized portfolio or invest all or a portion of
Client assets in its model portfolios. Each Client’s portfolio construction strategy is developed based on the
Client’s need, including such factors as other investments, tax sensitivity, and/or the alignment of a SilverLake
portfolio with a Client’s particular needs.
SilverLake will select, recommend and/or retain mutual funds on a fund by fund basis. Due to specific custodial
and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans,
SilverLake will select, recommend, and/or retain a mutual fund share class that does not have trading costs but
do have higher internal expense ratios than institutional share classes. SilverLake will seek to select the lowest
cost share class available that is in the best interest of each Client and will ensure the selection aligns with the
Client’s financial objectives and stated investment guidelines.
SilverLake’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. SilverLake will construct, implement, and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 5
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to the
acceptance by the Advisor.
SilverLake evaluates and selects investments for inclusion in Client portfolios only after applying their internal
due diligence process. SilverLake may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. SilverLake may recommend specific positions to increase sector or asset class
weightings. The Advisor may recommend employing cash positions as a possible hedge against market
movement. SilverLake may recommend selling positions for reasons that include but are not limited to
harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities,
overvaluation or overweighting of the position[s] in the portfolio, changes in risk tolerance of the Client,
generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Non-Purpose Loans – The Advisor may introduce certain Clients to non-purpose loan programs made available
through certain Custodians’ banking partner affiliates (“Lending Program”). In such instances, the Client’s assets
in their account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of
a Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory
fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the
Advisor for the Lending Program. For additional information related to the risks involved in non-purpose loans
and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new
(or increases its current) advisory fee as a result of the transaction. No client is under any obligation to roll over
a retirement account to an account managed by the Advisor.
At no time will SilverLake accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at
the Custodian, pursuant to the terms of the agreement. Please see Item 12 – Brokerage Practices for additional
information.
Financial Planning Services
SilverLake will typically provide a variety of financial planning services to individuals and families pursuant to a
written financial planning agreement. Services are offered in several areas of a Client’s financial situation,
depending on their goals, objectives, and financial situation. Generally, such financial planning services will
involve preparing a financial plan or rendering a financial consultation for clients based on the Client’s financial
goals and objectives. This planning or consulting may encompass one or more areas of need, including but not
limited to investment planning, retirement planning, personal savings, education savings, insurance needs, and
other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
SilverLake may also refer Clients to an accountant, attorney, or another specialist, as appropriate for their
unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the
Client’s financial situation, observations, and recommendations. For planning engagements that encompass an
ad-hoc analysis, the Advisor may not provide a written summary. Plans or consultations are typically completed
within six months of the contract date, assuming all information and documents requested are provided
promptly.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 6
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the
amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement any transaction through
the Advisor.
Retirement Plan Advisory Services
SilverLake provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Oversight Services (ERISA 3(21))
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
•
•
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
SilverLake may also provide communication and education services to the Plan and its Participants, pursuant to
the terms of the Advisor’s agreement with each Plan Sponsor:
Investment education
• Plan Participant contact by phone, email, or letter upon eligibility to promote enrollment
•
• Regular on-site advisor visits with staff for account updates and reviews
• Periodic company-wide employee survey of retirement plan understanding
• Periodic Plan Participant group education
These services are provided by SilverLake serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of SilverLake’s fiduciary status, the specific services to be rendered,
and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Use of Independent Managers
SilverLake will recommend that Clients utilize one or more unaffiliated investment managers or investment
platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the
Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an
investment management agreement with the Independent Manager[s] that defines the terms in which the
Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due
diligence over each Independent Manager to ensure the strategy remains aligned with the Client’s investment
objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy
recommendations and managing the ongoing Client relationship. Prior to entering an agreement with an
Independent Manager, the Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure
Brochure (or a brochure that makes the appropriate disclosures).
C. Client Account Management
Prior to engaging SilverLake to provide investment advisory services, each Client is required to enter into one or
more agreements with the Advisor that defines the terms, conditions, authority, and responsibilities of the
Advisor and the Client. These services may include:
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 7
• Establishing an Investment Strategy – SilverLake, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – SilverLake will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – SilverLake will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
•
Investment Management and Supervision – SilverLake will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
SilverLake does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by SilverLake.
E. Assets Under Management
As of December 31, 2024, SilverLake manages $572,662,800 in Client assets, of which $514,818,319 are
managed on a discretionary basis and $57,844,481 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more
written agreements with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, 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 range from 0.50% to 1.50%,
depending on the size and complexity of the Client relationship. Relationships with multiple objectives, specific
reporting requirements, portfolio restrictions, and other complexities may be charged a higher fee.
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. Investment advisory fees are negotiable upon the sole discretion of the Advisor, and the
agreed-upon fee will be included in the investment advisory agreement. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed
by SilverLake will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing.
Financial Planning Services
SilverLake offers financial planning services on an hourly basis at a rate of up to $300 per hour or on a fixed fee
basis, which may be negotiable depending on the nature and complexity of each Client’s circumstances. An
estimate for total hours and/or total costs will be determined prior to engaging for these services. The Advisor’s fee
is exclusive of and in addition to brokerage fees, transaction fees, and other related costs and expenses, which
may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and
costs.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.50% and are billed
in advance, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are
based on the market value of assets under management at the end of the prior calendar quarter Fees may be
negotiable depending on the size and complexity of the Plan.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 8
Use of Independent Managers
As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more
Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent
Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee
with an increased level of assets placed under management with an Independent Manager. The terms of such fee
arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the
Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will
not exceed 2.00% annually.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or the Custodian (on behalf of the Advisor) and deducted
from the Client account[s] at the Custodian. Clients authorize the calculation and deduction of the investment
advisory fee through the investment advisory agreement and the contractual arrangement[s] between the
Custodian and the Client. The amount due is calculated by applying the quarterly rate (annual rate divided by four
(4)) to the total assets under management with SilverLake at the end of each quarter. Clients will be provided with
a statement, at least quarterly, from the Custodian reflecting the deduction of the investment advisory fee. It is the
responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as
the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to
be deducted by SilverLake from their account[s] held by the Custodian as part of the investment advisory
agreement and separate account forms provided by the Custodian.
Financial Planning Services
Financial planning fees are invoiced by the Advisor upon completion of the engagement deliverable[s] and are due
upon receipt.
Retirement Plan Advisory Services
Retirement plan advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
retirement plan advisory agreement. Fees are negotiated with the Plan Sponsor on a case-by-case basis and may
be billed as a fixed quarterly fee or as a percentage of the market value of assets in the Plan at the end of the prior
calendar quarter.
Use of Independent Managers
For Client accounts implemented through an Independent Manager, the Client’s overall fees may include
SilverLake’s investment advisory fee (as noted above) plus investment management fees and/or platform fees
charged by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the
Advisor may assume responsibility for calculating the Client’s fees and deducting all fees from the Client’s
account[s].
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf
of the Client’s account[s]. SilverLake includes securities transactions costs as part of its overall investment
advisory fee through the SilverLake Wrap Fee Program. Securities transaction fees for Client-directed trades may
be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure.
The inclusion of securities transaction fees into a single bundled fee may cost the Client more or less than if paid
separately.
As mentioned in Item 4.B. above, the Client may be invested into share classes of a mutual fund that have a
higher expense ratio than a different share class. This may result in Clients paying higher expense ratio[s]. For a
complete discussion of expenses related to each mutual fund, please read a copy of the prospectus issued by
that particular fund.
In addition, all fees paid to SilverLake for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 9
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for
the funds, other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of
SilverLake, but would not receive the services provided by SilverLake, which are designed, among other things, to
assist the Client in determining which products or services are most appropriate to each Client’s financial situation
and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by
SilverLake to fully understand the total fees to be paid. Additionally, as noted above, the Advisor will select share
classes that do not have trading costs but do have higher internal expense ratios than institutional share classes.
Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Investment Management and Retirement Plan Advisory Services
SilverLake is compensated for its advisory services in advance of the quarter in which services are rendered.
Either party may terminate the agreement with SilverLake, at any time, by providing advance written notice to the
other party. The Client may also terminate the investment advisory agreement within five (5) business days of
signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for
bona fide advisory services rendered to the point of termination, and such fees will be due and payable by the
Client. The Advisor will then refund any unearned, prepaid advisory fees from the effective date of termination to
the end of the quarter. The Client’s advisory agreement with the Advisor is non-transferable without the Client’s
prior consent.
Financial Planning Services
SilverLake is compensated for its financial planning services upon completion of the engagement deliverable[s].
Either party may terminate the financial planning agreement with SilverLake, at any time, by providing advance
written notice to the other party. The Client may also terminate the agreement within five (5) business days of
signing the Advisor’s financial planning agreement at no cost to the Client. After the five-day period, the Client will
incur charges for bona fide advisory services rendered to the point of termination, and such fees will be due and
payable by the Client. The Client’s financial planning agreement with the Advisor is non-transferable without the
Client’s prior consent.
Retirement Plan Advisory Services
SilverLake is compensated for its services at the beginning of the quarter before advisory services are rendered.
Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written
notice to the other party. The Client shall be responsible for retirement plan advisory fees up to and including the
effective date of termination. The Advisor will refund any unearned, prepaid retirement plan advisory fees from the
effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the
Advisor is non-transferable without the Client’s prior consent.
Use of Independent Managers
In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest,
or a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination
will be set forth in the respective agreements between the Client or the Advisor and the Independent Manager.
SilverLake will assist the Client with the termination and transition as appropriate.
E. Compensation for Sales of Securities
SilverLake does not buy or sell securities and does not receive any compensation for securities transactions in any
Client account other than the investment advisory fees noted above.
Broker-Dealer Affiliations
Advisory Persons are also registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is
a registered broker-dealer (CRD# 35747), member FINRA, SIPC. In one’s separate capacity as a registered
representative of PKS, the Advisory Person will implement securities transactions under PKS and not through
SilverLake. In such instances, the Advisory Person will receive commission-based compensation in connection
with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products.
Compensation earned by the Advisory Person in one’s capacity as a registered representative is separate and
in addition to the Advisor’s fees. This practice presents a conflict of interest because the Advisory Person, who
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 10
is a registered representative, has an incentive to effect securities transactions for the purpose of generating
commissions rather than solely based on the Client. Clients are not obligated to implement any recommendation
provided by the Advisor or Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing
investment advisory fees in connection with any products or services implemented in the Advisory Person’s
separate capacity as a registered representative. Please see Item 10 – Other Financial Industry Activities and
Affiliations.
Insurance Agency Affiliations
Certain Advisory Persons are also licensed as independent insurance professionals. These persons will earn
commission-based compensation for selling insurance products, including insurance products they sell to
Clients. Insurance commissions earned by these persons are separate and in addition to advisory fees. This
practice presents a conflict of interest because Advisory Persons providing investment advice on behalf of the
Advisor, who are insurance agents, have an incentive to recommend insurance products to Clients for the
purpose of generating commissions rather than solely based on Client needs. However, Clients are under no
obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the
Advisor. Please see Item 10 – Other Financial Industry Activities and Affiliations.
Item 6 – Performance-Based Fees and Side-By-Side Management
SilverLake does not charge performance-based fees for its investment advisory services. The fees charged by
SilverLake are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client. SilverLake does not manage any proprietary investment funds or limited
partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any
particular investment options to its Clients.
Item 7 – Types of Clients
SilverLake offers investment advisory services to individuals, high net worth individuals, trusts, estates,
retirement plans, charitable organizations, corporations, and unaffiliated registered investment advisors. The
amount of each type of Client is available on the Advisor’s Form ADV Part 1A. These amounts may change over
time and are updated at least annually by the Advisor. SilverLake generally does not impose a minimum size for
establishing a relationship.
Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss
A. Methods of Analysis
SilverLake employs fundamental and technical analysis methods in developing investment strategies for its
Clients. Research data and analysis from SilverLake are derived from numerous sources, including financial
media companies, third-party research materials, Internet sources, and review of company activities, including
annual reports, prospectuses, press releases, and research prepared by others.
As noted above, SilverLake generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. SilverLake will typically hold all or a portion of a security for more than a year but may hold
for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times,
SilverLake may also buy and sell positions that are more short-term in nature, depending on the goals of the
Client and/or the fundamentals of the security, sector, or asset class.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria
consist generally of ratios and trends that may indicate the overall strength and financial viability of the entity
being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong
investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a
potential investment, it does not guarantee that the investment will increase in value. Assets meeting the
investment criteria utilized in the fundamental analysis may lose value and may have negative investment
performance. The Advisor monitors these economic indicators to determine if adjustments to strategic
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 11
allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 –
Review of Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in determining
the recommendations made to clients. Technical analysis may involve the use of charts to identify market
patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company.
The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends
in the future. Even if the trend will eventually reoccur, there is no guarantee that AA will be able to accurately
predict such a reoccurrence.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. SilverLake will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of
analysis may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon,
tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the
provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial
condition, goals, or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risk
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well
as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the
overall financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a
large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements
and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a
short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond prices
will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the
coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a lower
rate than was previously being earned, (3) inflation risk, i.e., the risk that the cost of living and inflation increase
at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default
risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the company
defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating agency’s
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 12
downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its
debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily available
market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have
the same price as a mutual fund purchased later that same day.
Non-Purpose Loans and Lines of Credit
Non-purpose loans and lines of credit carry a number of risks, including but not limited to the risk of a market
downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline
in the market value of collateralized securities held in the account[s] at the Custodian may result in a reduction
in the draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit
additional funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s
collateral account[s].
Past performance is not a guarantee of future returns. Investing in securities and other investments
involves a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the Advisor or its Advisory Persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices.
You may independently view the backgrounds of the Advisor and its Advisory Persons on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or
CRD# 165525.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
As noted in Item 5, certain Advisory Persons of SilverLake are also registered representatives of PKS, a
registered broker-dealer (CRD# 35747), member FINRA, SIPC. In their separate capacities as registered
representatives of PKS, Advisory Persons will receive compensation for the implementation of
recommendations for commissionable transactions. Clients are not obligated to implement any recommendation
provided by Advisory Persons of SilverLake. Neither SilverLake nor its Advisory Persons will earn ongoing
investment advisory fees in connection with any services implemented in an Advisory Person’s separate
capacity as a registered representative.
Insurance Agency Affiliations
As noted in Item 5, certain Advisory Persons of SilverLake are also licensed insurance professionals.
Implementations of insurance recommendations are separate and apart from the Advisory Person’s role with the
SilverLake. As insurance professionals, Advisory Persons will receive customary commissions and other related
revenues from the various insurance companies whose products are sold. Advisory Persons are not required to
offer the products of any particular insurance company. Commissions generated by insurance sales do not
offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the
insurance companies. Clients are under no obligation to implement any recommendations made by Advisory
Persons or the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 13
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more
Independent Managers. The Advisor does not receive any compensation, nor does this present a material
conflict of interest. The Advisor will only earn its investment advisory fee as described in Item 5.A.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading
A. Code of Ethics
SilverLake has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client.
This Code of Ethics applies to all persons associated with SilverLake (“Supervised Persons”). The Code of
Ethics was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s
duties to the Client. SilverLake and its Supervised Persons owe a duty of loyalty, fairness, and good faith
towards each Client. It is the obligation of SilverLake associates to adhere not only to the specific provisions of
the Code but also to the general principles that guide the Code. The Code of Ethics covers a range of topics that
may address employee ethics and conflicts of interest. To request a copy of the Code of Ethics, please contact
the Advisor at (802) 857-5083 or via email at info@silverlakewealth.com.
B. Personal Trading with Material Interest
SilverLake allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. SilverLake does not act as principal in any transactions. In addition, the Advisor
does not act as the general partner of a fund or advise an investment company. SilverLake does not have a
material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
SilverLake allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted, consistent with Section 204A of the Investment Advisers
Act of 1940, a Code of Ethics, which addresses insider trading (material non-public information controls) and
personal securities reporting procedures. When trading for personal accounts, Supervised Persons of
SilverLake have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best
interest of its Clients can be violated if personal trades are made with more advantageous terms than Client
trades or by trading based on material non-public information. This risk is mitigated by SilverLake requiring
reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer
(“CCO”) or delegate. The Advisor also adopted written policies and procedures to detect the misuse of material,
non-public information.
In addition, the Code of Ethics governs Gifts and Entertainment given by and provided to the Advisor, outside
employment activities of Supervised Persons, Employee reporting, sanctions for violations of the Code of Ethics,
and records retention requirements for various aspects of the Code of Ethics.
D. Personal Trading at Same Time as Client
While SilverLake allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded
afterward. At no time will SilverLake or any Supervised Person of SilverLake transact in any security to
the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
SilverLake does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize SilverLake to direct trades to the Custodian as agreed upon in the investment advisory
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 14
agreement. Further, SilverLake does not have the discretionary authority to negotiate commissions on behalf of
Clients on a trade-by-trade basis.
Where SilverLake does not exercise discretion over the selection of the Custodian, the Advisor will typically
recommend the Custodians to Clients. SilverLake will typically recommend Clients establish accounts at Charles
Schwab, Inc. (“Schwab”) or Fidelity Clearing & Custody Solutions and related divisions and entities of Fidelity
Investments, Inc., including National Financial Services, LLC, and Fidelity Brokerage Services, LLC (collectively
“Fidelity”). Schwab and Fidelity (each a “Custodian” and collectively the “Custodians”) are FINRA-registered
broker-dealers and members of SIPC and serve as the Client’s “qualified custodian.” SilverLake maintains
institutional relationships with the Custodians, whereby the Advisor receives economic benefits from these
Custodians.
Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the
Advisor associated with using a custodian not recommended by SilverLake. However, because of SilverLake’s
affiliation with PKS, the Advisor may be limited in the services it can offer if a Custodian is selected that is not
approved by PKS.
SilverLake has established an institutional relationship with Fidelity to assist the Advisor in managing Client
account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity platform includes
brokerage, custody, administrative support, record keeping, technology, and related services designed to support
registered investment advisors like SilverLake in serving Clients. These services are intended to serve the best
interests of the Advisor’s Clients.
Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain securities
transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction fees
and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered
discounted from customary retail commission rates. However, the commissions and transaction fees charged by
Fidelity may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14
below for additional information.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an
advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for
research and other services. SilverLake does not participate in soft dollar programs sponsored or
offered by any broker-dealer/custodian. However, the Advisor receives certain economic
benefits from the Custodian. Please see Item 14 below.
2. Brokerage Referrals – SilverLake does not receive any compensation from any third party in
connection with the recommendation for establishing an account.
3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis,” where SilverLake will
place trades within the established account[s] at the Custodian designated by the Client. Further, all
Client accounts are traded within their respective account[s] at the designated Custodian. The Advisor
will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own
account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client
account from another Client’s account[s]). SilverLake will not be obligated to select competitive bids on
securities transactions and does not have an obligation to seek the lowest available transaction costs.
These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain
the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. SilverLake will execute its transactions
through the Custodian as authorized by the Client.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 15
SilverLake may aggregate orders in a block trade or trades when securities are purchased or sold through the
Custodian for multiple (discretionary) accounts. If a block trade 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 in a manner
that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does
not consistently advantage or disadvantage particular Client accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by the Principals of SilverLake,
which may periodically include the CCO. Formal reviews are generally conducted at least annually or more
frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A. above, each Client account shall be reviewed at
least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed
as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or
large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify SilverLake if changes
occur in his/her personal financial situation that might adversely affect his/her investment plan. Additional
reviews may be triggered by material market, economic, or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may
also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by SilverLake
Participation in Institutional Advisor Platforms (Fidelity)
As noted in item 12, SilverLake has established an institutional relationship with Fidelity to assist the Advisor in
managing Client account[s].
As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor,
certain research and brokerage services, including research services obtained by Fidelity directly from
independent research companies. The Advisor may also receive additional services and support from Fidelity. As
a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or
expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter
into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s
Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above.
The Advisor receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Fidelity. The software and related systems support may
benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times
to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from
a Custodian creates a conflict of interest since these benefits may influence the Advisor’s recommendation of this
Custodian over one that does not furnish similar software, systems support, or services.
Participation in Institutional Advisor Platforms (Schwab)
SilverLake has also established an institutional relationship with Schwab through its “Schwab Advisor Services”
unit, a division of Schwab dedicated to serving independent advisory firms like SilverLake. As a registered
investment advisor participating on the Schwab Advisor Services platform, SilverLake receives access to
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 16
software and related support without cost because the Advisor renders investment management services to
Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and
many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor
endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt
of economic benefits from a custodian creates a conflict of interest since these benefits may influence the
Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or
services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual
funds and other investments without having to adhere to investment minimums that might be required if the
Client were to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts, and other services. In addition, the Advisor receives duplicate statements for
Client accounts the ability to deduct advisory fees, trading tools, and back-office support services as part of its
relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for
its Clients but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and support to SilverLake that
may not benefit the Client, including educational conferences and events, consulting services, and discounts for
various service providers. Access to these services creates a financial incentive for the Advisor to recommend
Schwab, which results in a conflict of interest. SilverLake believes, however, that the selection of Schwab as
Custodian is in the best interests of its Clients.
B. Compensation for Client Referrals
SilverLake does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Item 15 – Custody
SilverLake does not accept or maintain custody of Client accounts, except for the limited circumstances outlined
below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction
of advisory fees, all Clients for whom SilverLake exercises discretionary authority must hold their assets with a
"qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and
securities and must instruct SilverLake to utilize that Custodian for securities transactions on their behalf. Clients
are encouraged to review statements provided by the Custodian and compare to any reports provided by
SilverLake to ensure accuracy, as the Custodian does not perform this review.
[IF APPLICABLE] Money Movement Authorization - For instances where Clients authorize SilverLake to move
funds between their accounts, SilverLake and the Custodian have implemented safeguards to ensure that all
money movement activities are conducted strictly in accordance with the Client’s documented instructions.
Item 16 – Investment Discretion
SilverLake offers its investment advisory services on either a discretionary or non-discretionary basis. For
discretionary accounts, SilverLake will have the authority over the selection and amount of securities to be
bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these
purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth
by the Client and agreed to by SilverLake. Discretionary authority will only be authorized upon full disclosure to the
Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 17
agreement containing all applicable limitations to such authority. All discretionary trades made by SilverLake will
be in accordance with each Client's investment objectives and goals.
Item 17 – Voting Client Securities
SilverLake does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly
from the Custodian. The Advisor will assist in answering questions relating to proxies; however, the Client retains
the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither SilverLake nor its management has any adverse financial situations that would reasonably impair the
ability of SilverLake to meet all obligations to its Clients. Neither SilverLake nor any of its Advisory Persons have
been subject to a bankruptcy or financial compromise. SilverLake is not required to deliver a balance sheet
along with this Disclosure Brochure as the firm does not collect fees of $1,200 or more for services to be
performed six months or more in advance.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 18
Form ADV Part 2B – Brochure Supplement
for
Richard J. Briand
Managing Partner
Effective: June 30, 2025
This Form ADV Part 2B (“Brochure Supplement”) provides information about the background and qualifications
of Richard J. Briand (CRD# 1045809) in addition to the information contained in the SilverLake Wealth
Management, LLC (“SilverLake” or the “Advisor,” CRD# 165525) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure
Brochure or this Brochure Supplement, please contact the Advisor at (802) 857-5083 or by email at
info@silverlakewealth.com.
Additional information about Mr. Briand is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 1045809.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 19
Item 2 – Educational Background and Business Experience
The Managing Partner of SilverLake is Richard J. Briand. Mr. Briand, born in 1955, is a dedicated Portfolio
Manager for Clients of SilverLake. Mr. Briand earned a Bachelor of Science degree in Accounting from Bentley
University in 1978. Additional information regarding Mr. Briand’s employment history is included below.
Employment History:
Managing Partner and Portfolio Manager, SilverLake Wealth Management, LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Registered Representative, LPL Financial, LLC
Managing Partner, Wells Fargo Financial Network, LLC
Managing Partner, Wachovia Securities Financial Network, LLC
Financial Advisor, Wachovia Securities, LLC
Financial Advisor, Wachovia Securities, Inc.
Financial Advisor, First Union Securities, Inc.
10/2012 to Present
04/2020 to Present
10/2012 to 04/2020
05/2009 to 10/2012
10/2005 to 05/2009
05/2003 to 10/2005
06/2002 to 05/2003
08/2000 to 06/2002
Item 3 – Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Mr. Briand. Mr. Briand has never
been involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits,
arbitration claims, or administrative proceedings against Mr. Briand.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there
are no legal, civil, or disciplinary events to disclose regarding Mr. Briand.
However, the Advisor encourages Clients to independently view the background of Mr. Briand on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching by his full name or individual CRD#
1045809.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Briand is also a registered representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a
registered broker-dealer (CRD# 6413), member FINRA, SIPC. In his separate capacity as a registered
representative, Mr. Briand will receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr.
Briand. Neither the Advisor nor Mr. Briand will earn ongoing investment advisory fees in connection with any
services implemented in Mr. Briand’s separate capacity as a registered representative. In no circumstances will
SilverLake earn an advisory fee and a commission on the same investment. In the event that Mr. Briand earns a
commission on an investment, the advisory fee will be waived by SilverLake.
Insurance Agency Affiliations
Mr. Briand is also a licensed insurance professional. This activity is done separate and apart from his role with
SilverLake. As an insurance professional, Mr. Briand will receive customary commissions and other related
revenues from the various insurance companies whose products are sold. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Briand or the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 20
Item 5 – Additional Compensation
Mr. Briand has additional business activities where compensation is received. These business activities are
detailed in Item 4 above.
Item 6 – Supervision
Mr. Briand serves as a Managing Partner and Portfolio Manager of SilverLake and is supervised by Jeffrey
Steele, the Chief Compliance Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics and internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons.
As a registered entity, SilverLake is subject to examinations by regulators, which may be announced or
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 21
Form ADV Part 2B – Brochure Supplement
for
Robert W. Eddy
Managing Partner
Effective: June 30, 2025
This Form ADV Part 2B (“Brochure Supplement”) provides information about the background and qualifications
of Robert W. Eddy (CRD# 75378) in addition to the information contained in the SilverLake Wealth Management,
LLC (“SilverLake” or the “Advisor,” CRD# 165525) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure or this Brochure
Supplement, please contact the Advisor at (802) 857-5083 or by email at info@silverlakewealth.com.
Additional information about Robert W. Eddy is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 75378.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 22
Item 2 – Educational Background and Business Experience
Robert W. Eddy is a Managing Partner of SilverLake. Mr. Eddy, born in 1945, is dedicated to serving the Clients
of SilverLake. Mr. Eddy earned a Bachelor of Science degree from Ithaca College in 1967. Additional
information regarding Mr. Eddy’s employment history is included below.
Employment History:
Managing Partner, SilverLake Wealth Management, LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Registered Representative, LPL Financial, LLC
Managing Partner, Wells Fargo Financial Network, LLC
Managing Partner, Wachovia Securities Financial Network, Inc.
Managing Partner, Wachovia Securities Financial Network, LLC
Financial Advisor, Morgan Stanley & Co., Inc.
10/2012 to Present
04/2020 to Present
10/2012 to 04/2020
05/2009 to 10/2012
06/2003 to 05/2009
06/2002 to 05/2003
02/1978 to 04/2002
Item 3 – Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Mr. Eddy. Mr. Eddy has never been
involved in any regulatory, civil, or criminal action. There have been no Client complaints, lawsuits, arbitration
claims, or administrative proceedings against Mr. Eddy.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there
are no legal, civil, or disciplinary events to disclose regarding Mr. Eddy.
However, the Advisor encourages Clients to independently view the background of Mr. Eddy on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching by his full name or individual CRD#
75378.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Eddy is also a registered representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a
registered broker-dealer (CRD# 6413), member FINRA, SIPC. In his separate capacity as a registered
representative, Mr. Eddy will receive commissions for the implementation of recommendations of
commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr.
Eddy. Neither the Advisor nor Mr. Eddy will earn ongoing investment advisory fees in connection with any
services implemented in Mr. Eddy’s separate capacity as a registered representative. In no circumstances will
SilverLake earn an advisory fee and a commission on the same investment. In the event that Mr. Eddy earns a
commission on an investment, the advisory fee will be waived by SilverLake.
Insurance Agency Affiliations
Mr. Eddy is also a licensed insurance professional. This activity is done separate and apart from his role with
SilverLake. As an insurance professional, Mr. Eddy will receive customary commissions and other related
revenues from the various insurance companies whose products are sold. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Eddy or the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 23
Item 5 – Additional Compensation
Mr. Eddy has additional business activities where compensation is received. These business activities are
detailed in Item 4 above.
Item 6 – Supervision
Mr. Eddy serves as a Managing Partner of SilverLake and is supervised by Jeffrey Steel, the Chief Compliance
Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics and internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons.
As a registered entity, SilverLake is subject to examinations by regulators, which may be announced or
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 24
Form ADV Part 2B – Brochure Supplement
for
Thomas Golonka, CFA®, CFP®
Managing Partner
Effective: June 30, 2025
This Form ADV Part 2B (“Brochure Supplement”) provides information about the background and qualifications
of Thomas Golonka, CFA®, CFP®, (CRD# 2209094) in addition to the information contained in the SilverLake
Wealth Management, LLC (“SilverLake” or the “Advisor,” CRD# 165525) Disclosure Brochure. If you have not
received a copy of the Disclosure Brochure or if you have any questions about the contents of the SilverLake
Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (802) 857-5083 or by email at
info@silverlakewealth.com.
Additional information about Thomas Golonka is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 2209094.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 25
Item 2 – Educational Background and Business Experience
Thomas Golonka, CFA®, CFP®, is a Managing Partner of SilverLake. Mr. Golonka, born in 1967, is dedicated to
serving the Clients of SilverLake. Mr. Golonka earned a Master’s of Business Administration degree from Union
College in 1991 and a Bachelor of Arts degree from the University of Notre Dame in 1989. Additional information
regarding Mr. Golonka’s employment history is included below.
Employment History:
Managing Partner, SilverLake Wealth Management. LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Registered Representatives, LPL Financial, LLC
Managing Partner, Wells Fargo Advisors Financial Network, LLC
Managing Partner, Wachovia Securities Financial Network, LLC
Financial Advisor, Wachovia Securities, LLC
Financial Advisor, Wachovia Securities, Inc.
10/2012 to Present
04/2020 to Present
10/2012 to 04/2020
05/2009 to 10/2012
10/2005 to 5/2009
06/2003 to 10/2005
08/2000 to 05/2003
Chartered Financial Analyst™ (“CFA®”)
The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and
awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour
examinations over two to four years. The three levels of the CFA® Program test a wide range of investment
topics, including ethical and professional standards, fixed-income analysis, alternative and derivative
investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four
years of acceptable professional experience in the investment decision-making process and must commit to
abide by and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of
Professional Conduct. CFA® is a trademark owned by CFA® Institute.
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by the
CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold the CFP® certification. It is recognized in the United States and a number of other countries for its (1)
high standard of professional education, (2) stringent code of conduct and standards of practice, and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 92,000 individuals have
obtained the CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that the CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). The CFP
Board’s financial planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real-world circumstances;
• Experience – Complete at least three (3) years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by the CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 26
• Continuing Education – Complete thirty (30) hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to
maintain competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of
their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to the CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®.
Item 3 – Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Mr. Golonka. Mr. Golonka has never
been involved in any regulatory, civil, or criminal action. There have been no Client complaints, lawsuits,
arbitration claims, or administrative proceedings against Mr. Golonka.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there
are no legal, civil, or disciplinary events to disclose regarding Mr. Golonka.
However, the Advisor encourages Clients to independently view the background of Mr. Golonka on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching by his full name or
individual CRD# 2209094.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Golonka is also a registered representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a
registered broker-dealer (CRD# 6413), member FINRA, SIPC. In his separate capacity as a registered
representative, Mr. Golonka will receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr.
Golonka. Neither the Advisor nor Mr. Golonka will earn ongoing investment advisory fees in connection with any
services implemented in Mr. Golonka’s separate capacity as a registered representative. In no circumstances
will SilverLake earn an advisory fee and a commission on the same investment. In the event that Mr. Golonka
earns a commission on an investment, the advisory fee will be waived by SilverLake.
Insurance Agency Affiliations
Mr. Golonka is also a licensed insurance professional. This activity is done separate and apart from his role with
SilverLake. As an insurance professional, Mr. Golonka will receive customary commissions and other related
revenues from the various insurance companies whose products are sold. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Golonka or the Advisor.
Item 5 – Additional Compensation
Mr. Golonka has additional business activities where compensation is received. These business activities are
detailed in Item 4 above.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 27
Item 6 – Supervision
Mr. Golonka serves as a Managing Partner of SilverLake and is supervised by Jeffrey Steele, the Chief
Compliance Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics and internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons.
As a registered entity, SilverLake is subject to examinations by regulators, which may be announced or
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 28
Form ADV Part 2B – Brochure Supplement
for
Jeffrey D. Steele
Managing Partner and Chief Compliance Officer
Effective: June 30, 2025
This Form ADV Part 2B (“Brochure Supplement”) provides information about the background and qualifications
of Jeffrey D. Steele (CRD# 2111373) in addition to the information contained in the SilverLake Wealth
Management, LLC (“SilverLake” or the “Advisor,” CRD# 165525) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure
Brochure or this Brochure Supplement, please contact the Advisor at (802) 857-5083 or by email at
info@silverlakewealth.com.
Additional information about Jeffrey D. Steele is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 2111373.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 29
Item 2 – Educational Background and Business Experience
Jeffrey D. Steele is a Managing Partner and the Chief Compliance Officer of SilverLake. Mr. Steele, born in
1967, is dedicated to serving the Clients of SilverLake. Mr. Steele earned a Bachelor of Arts degree in
Economics from the State University of New York College at Cortland (“SUNY”) in 1989. Additional information
regarding Mr. Steele’s employment history is included below.
Employment History:
Managing Partner & Chief Compliance Officer, SilverLake Wealth Management, LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Financial Advisor, LPL Financial, LLC
Managing Partner, Wells Fargo Advisors Financial Network, LLC
Managing Partner, Wachovia Securities Financial Network, LLC
Financial Advisor, Wachovia Securities, LLC
Financial Advisor, Wachovia Securities, Inc.
Financial Advisor, First Union Securities, Inc.
Financial Advisor, Morgan Stanley & Co., Inc.
10/2012 to Present
04/2020 to Present
10/2012 to 04/2020
05/2009 to 10/2012
10/2005 to 05/2009
06/2003 to 10/2005
06/2002 to 05/2003
04/2002 to 06/2002
10/1990 to 04/2002
Item 3 – Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Mr. Steele. Mr. Steele has never been
involved in any regulatory, civil, or criminal action. There have been no Client complaints, lawsuits, arbitration
claims, or administrative proceedings against Mr. Steele.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there
are no legal, civil, or disciplinary events to disclose regarding Mr. Steele.
However, the Advisor encourages Clients to independently view the background of Mr. Steele on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching by his full name or individual CRD#
2111373.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Steele is also a registered representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a
registered broker-dealer (CRD# 6413), member FINRA, SIPC. In his separate capacity as a registered
representative, Mr. Steele will receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr.
Steele. Neither the Advisor nor Mr. Steele will earn ongoing investment advisory fees in connection with any
services implemented in Mr. Steele’s separate capacity as a registered representative. In no circumstances will
SilverLake earn an advisory fee and a commission on the same investment. In the event that Mr. Steele earns a
commission on an investment, the advisory fee will be waived by SilverLake.
Insurance Agency Affiliations
Mr. Steele is also a licensed insurance professional. This activity is done separate and apart from his role with
SilverLake. As an insurance professional, Mr. Steele will receive customary commissions and other related
revenues from the various insurance companies whose products are sold. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Steele or the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 30
Item 5 – Additional Compensation
Mr. Steele has additional business activities where compensation is received. These business activities are
detailed in Item 4 above.
Item 6 – Supervision
Mr. Steele serves as the Managing Partner and the Chief Compliance of SilverLake. Mr. Steele can be reached
at (802) 857-5083.
SilverLake has implemented a Code of Ethics and internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons.
As a registered entity, SilverLake is subject to examinations by regulators, which may be announced or
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 31
Form ADV Part 2B – Brochure Supplement
for
Theodore M. Riehle
Managing Partner
Effective: June 30, 2025
This Form ADV Part 2B (“Brochure Supplement”) provides information about the background and qualifications
of Theodore M. Riehle (CRD# 1053690) in addition to the information contained in the SilverLake Wealth
Management, LLC (“SilverLake” or the “Advisor,” CRD# 165525) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure
Brochure or this Brochure Supplement, please contact the Advisor at (802) 857-5083 or by email at
info@silverlakewealth.com.
Additional information about Theodore M. Riehle is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or individual CRD# 1053690.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 32
Item 2 – Educational Background and Business Experience
Theodore M. Riehle is a Managing Partner of SilverLake. Mr. Riehle, born in 1947, is dedicated to serving the
Clients of SilverLake. Mr. Riehle earned a Bachelor of Science degree from the University of Vermont in 1970.
Additional information regarding Mr. Riehle’s employment history is included below.
Employment History:
Managing Partner, SilverLake Wealth Management, LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Registered Representative, LPL Financial, LLC
Managing Partner, Wells Fargo Advisors Financial Network, LLC
Managing Partner, Wachovia Securities Financial Network, LLC
Managing Partner, Wachovia Securites Financial Network, Inc.
Financial Advisor, First Union Securites Financial Network, Inc.
Financial Advisor, Morgan Stanley & Co., Inc.
10/2012 to Present
04/2020 to Present
10/2012 to 11/2019
05/2009 to 10/2012
06/2003 to 05/2009
06/2002 to 05/2003
03/2002 to 06/2002
01/1995 to 03/2002
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. There are no legal, civil, or
disciplinary events requiring disclosure regarding Mr. Riehle.
However, the Advisor encourages Clients to independently view the background of Mr. Riehle on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching by his full name or individual CRD#
1053690.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Riehle is also a licensed insurance professional. This activity is done separate and apart from his role with
SilverLake. As an insurance professional, Mr. Riehle will receive customary commissions and other related
revenues from the various insurance companies whose products are sold. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Riehle or the Advisor.
Item 5 – Additional Compensation
Mr. Riehle has additional business activities where compensation is received. These business activities are
detailed in Item 4 above.
Item 6 – Supervision
Mr. Riehle serves as the Managing Partner of SilverLake and is supervised by Jeffrey Steele, the Chief
Compliance Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics and internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons.
As a registered entity, SilverLake is subject to examinations by regulators, which may be announced or
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 33
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 34
Form ADV Part 2B – Brochure Supplement
for
Derek G. Eddy, CEPA®
Investment Advisor Representative
Effective: June 30, 2025
This Form ADV Part 2B (“Brochure Supplement”) provides information about the background and qualifications
of Derek G. Eddy (CRD# 5648908) in addition to the information contained in the SilverLake Wealth
Management LLC (“SilverLake” or the “Advisor,” CRD# 165525) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure
Brochure or this Brochure Supplement, please contact the Advisor at (802) 857-5083 or by email at
info@silverlakewealth.com.
Additional information about Mr. Eddy is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or individual CRD# 5648908.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 35
Item 2 – Educational Background and Business Experience
Derek G. Eddy is an Investment Advisor Representative with SilverLake. Mr. Eddy, born in 1984, is dedicated to
advising Clients of SilverLake. Mr. Eddy earned a Bachelor’s degree in Business and Economics from Bishop
University in 2008. Additional information regarding Mr. Eddy’s employment history is included below.
Employment History:
Investment Advisor Representative, SilverLake Wealth Management, LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Registered Representative, LPL Financial, LLC
Registered Representative, Wells Fargo Advisor Financial Network, LLC
Sales Assistant, Wachovia Securities Financial Network, LLC
03/2009 to Present
04/2020 to Present
12/2012 to 04/2020
05/2009 to 12/2012
05/2008 to 05/2009
Certified Exit Planning Advisor™ (“CEPA®”)
The Certified Exit Planning Advisor™ and CEPA® are professional certification marks granted by The Exit
Planning Institute®. It is recognized as the designation that business owners look for when looking for a trusted
advisor. CEPA® applicants must meet strict requirements, including: a minimum of a bachelor’s degree from an
accredited U.S. college or university (or the equivalent from a foreign university); completion of the 5-day
CEPA® program taught by a faculty of experts; and passing the CEPA® exam consisting of 150 multiple choice
questions. Applicants must also have 5 years of experience dealing with the owners of privately-held businesses
in some advisory capacity. All applicants for the CEPA® program must sign an attestation agreeing to abide by
the Code of Ethics and Professional Standards™ of the Exit Planning Institute.
CEFA® advisors must complete ongoing continuing professional education and ethics requirements to maintain
their certification, with recertification every three years and completing 40 hours of continuing education. More
information on the CEPA® designation can be found on the Exit Planning website: www.exit-planning-
institute.org
Item 3 – Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Mr. Eddy. Mr. Eddy has never been
involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration
claims, or administrative proceedings against Mr. Eddy.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there
are no legal, civil, or disciplinary events to disclose regarding Mr. Eddy.
However, the Advisor encourages Clients to independently view the background of Mr. Eddy on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching by his full name or individual CRD#
5648908.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Eddy is also a registered representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a
registered broker-dealer (CRD# 6413), member FINRA, SIPC. In his separate capacity as a registered
representative, Mr. Eddy will receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr.
Eddy. Neither the Advisor nor Mr. Eddy will earn ongoing investment advisory fees in connection with any
services implemented in Mr. Eddy’s separate capacity as a registered representative. In no circumstances will
SilverLake earn an advisory fee and a commission on the same investment. In the event that Mr. Eddy earns a
commission on an investment, the advisory fee will be waived by SilverLake.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 36
Item 5 – Additional Compensation
Mr. Eddy has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Eddy serves as an Investment Advisor Representative with SilverLake and is supervised by Jeffrey Steele,
the Chief Compliance Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics and internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its employees. As a
registered entity, SilverLake is subject to examinations by regulators, which may be announced or
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 37
Form ADV Part 2B – Brochure Supplement
for
Ryan J. Bergmann, CFP®
Investment Advisor Representative
Effective: June 30, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Ryan J. Bergmann, CFP® (CRD# 7127547) in addition to the information contained in the SilverLake Wealth
Management LLC (“SilverLake” or the “Advisor”, CRD# 165525) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure
Brochure or this Brochure Supplement, please contact us at (802) 857-5083 or by email at
info@silverlakewealth.com.
Additional information about Mr. Bergmann is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7127547.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 38
Item 2 – Educational Background and Business Experience
Ryan J. Bergmann, CFP® , born in 1985, is dedicated to advising Clients of SilverLake as an Investment Advisor
Representative. Mr. Bergmann earned a Bachelors in Psychology and Sociology from University of Vermont in
2008. Additional information regarding Mr. Bergmann’s employment history is included below.
Employment History:
Investment Advisor Representative, SilverLake Wealth Management LLC
Client Service Associate, Morgan Stanley
Financial Advisor, Morgan Stanley Private Bank, N.A
Senior Financial Analyst, Gap Inc.
Senior Vendor Management Analyst, Dr Pepper Snapple Group
12/2022 to Present
07/2019 to 12/2022
05/2021 to 12/2022
07/2012 to 06/2019
02/2009 to 06/2012
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by the
CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold the CFP® certification. It is recognized in the United States and a number of other countries for its (1)
high standard of professional education, (2) stringent code of conduct and standards of practice, and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 92,000 individuals have
obtained the CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that the CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). The CFP
Board’s financial planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real-world circumstances;
• Experience – Complete at least three (3) years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by the CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete thirty (30) hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to
maintain competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of
their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to the CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 39
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Bergmann. Mr. Bergmann has
never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Bergmann.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there
are no legal, civil or disciplinary events to disclose regarding Mr. Bergmann.
However, we do encourage you to independently view the background of Mr. Bergmann on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 7127547.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Bergmann is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mr. Bergmann’s role with SilverLake. As an insurance professional, Mr. Bergmann will
receive customary commissions and other related revenues from the various insurance companies whose
products are sold. Mr. Bergmann is not required to offer the products of any particular insurance company.
Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict
of interest in recommending certain products of the insurance companies. Clients are under no obligation to
implement any recommendations made by Mr. Bergmann or the Advisor. Mr. Bergmann spends approximately
10% of his time per month in this capacity.
Item 5 – Additional Compensation
Mr. Bergmann has additional business activities where compensation is received that are detailed in Item 4
above.
Item 6 – Supervision
Mr. Bergmann serves as an Investment Advisor Representative of SilverLake and is supervised by Jeffrey
Steele, the Chief Compliance Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons.
As a registered entity, SilverLake is subject to examinations by regulators, which may be announced or
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 40
Form ADV Part 2B – Brochure Supplement
for
Gregory J. Steele
Investment Advisor Representative
Effective: June 30, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Gregory J. Steele (CRD# 2571053) in addition to the information contained in the SilverLake Wealth
Management LLC (“SilverLake” or the “Advisor”, CRD# 165525) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure
Brochure or this Brochure Supplement, please contact us at (802) 857-5083 or by email at
info@silverlakewealth.com.
Additional information about Mr. Steele is available on the SEC’s Investment Adviser Public Disclosure website
at Investment Advisor Representative.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
2571053.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 41
Item 2 – Educational Background and Business Experience
Gregory J. Steele, born in 1971, is dedicated to advising Clients of SilverLake as an Investment Advisor
Representative. Mr. Steele earned a Bachelor of Arts from Union College in 1993. Additional information
regarding Mr. Steele’s employment history is included below.
Employment History:
Investment Advisor Representative, SilverLake Wealth Management LLC
Managing Director, JVB Financial Group
High Yield Sales, Mizuho Securities USA, LLC
High Yield Trading, RBC Capital Markets
04/2024 to Present
04/2023 to 04/2024
07/2018 to 10/2022
05/2012 to 01/2018
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Steele. Mr. Steele has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Steele.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there
are no legal, civil or disciplinary events to disclose regarding Mr. Steele.
However, we do encourage you to independently view the background of Mr. Steele on the Investment Adviser
Public Disclosure website at Investment Advisor Representative.adviserinfo.sec.gov by searching with his full
name or his Individual CRD# 2571053.
Item 4 – Other Business Activities
Mr. Steele is dedicated to the investment advisory activities of SilverLake’s Clients. Mr. Steele does not have
any other business activities.
Item 5 – Additional Compensation
Mr. Steele is dedicated to the investment advisory activities of SilverLake’s Clients. Mr. Steele does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Steele serves as an Investment Advisor Representative of SilverLake and is supervised by Jeffrey Steele,
the Chief Compliance Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons.
As a registered entity, SilverLake is subject to examinations by regulators, which may be announced or
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 42
Form ADV Part 2B – Brochure Supplement
for
Patrick J. Thornton
Senior VP, Financial Advisor
Effective: June 30, 2025
this Brochure Supplement, please contact us at
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Patrick J. Thornton (CRD# 1303844) in addition to the information contained in the SilverLake Wealth
Management LLC (“SilverLake” or the “Advisor”, CRD# 165525) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure
(802) 857-5083 or by email at
Brochure or
info@silverlakewealth.com.
Additional information about Mr. Thornton is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1303844.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 43
Item 2 – Educational Background and Business Experience
Patrick J. Thornton, born in 1951, is dedicated to advising Clients of SilverLake as a Senior VP, Financial Advisor.
Mr. Thornton earned a Master of Arts degree from Columbia University in 1976. Mr. Thornton also earned a
Bachelor of Arts degree from College of the Holy Cross in 1974. Additional information regarding Mr. Thornton’s
employment history is included below.
Employment History:
Senior VP, Financial Advisor, SilverLake Wealth Management LLC
Investment Advisor Representative, Belpointe Asset Management LLC
President, Thornton Investment Management PLLC
05/2024 to Present
01/2020 to 06/2024
08/2011 to 05/2024
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Thornton. Mr. Thornton has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Thornton.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Thornton.
However, we do encourage you to independently view the background of Mr. Thornton on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
1303844.
Item 4 – Other Business Activities
Mr. Thornton is dedicated to the investment advisory activities of SilverLake’s Clients. Mr. Thornton does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Thornton is dedicated to the investment advisory activities of SilverLake’s Clients. Mr. Thornton does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Thornton serves as a Senior VP, Financial Advisor of SilverLake and is supervised by Jeffrey Steele, the Chief
Compliance Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons. As
a registered entity, SilverLake is subject to examinations by regulators, which may be announced or unannounced.
SilverLake is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 44
Form ADV Part 2B – Brochure Supplement
for
John Henry B. Hubert
Sr. Vice President
Effective: June 30, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
John Henry B. Hubert (CRD# 3049563) in addition to the information contained in the SilverLake Wealth
Management LLC (“SilverLake” or the “Advisor”, CRD# 165525) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure
Brochure or this Brochure Supplement, please contact us at (802) 857-5083 or by email at
info@silverlakewealth.com.
Additional information about Mr. Hubert is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 3049563.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 45
Item 2 – Educational Background and Business Experience
John Henry B. Hubert, born in 1970, is dedicated to advising Clients of SilverLake as Sr. Vice President Mr.
Hubert earned a BA in Psychology and Education from MIddlebury College in 1992. Additional information
regarding Mr. Hubert’s employment history is included below.
Employment History:
Sr. Vice President, SilverLake Wealth Management LLC
Investment Advisor, Catamount Asset Management LLC
Registered Representative, Cadaret, Grant & CO., Inc.
05/2025 to Present
01/2011 to 06/2025
05/2009 to12/2011
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Hubert. Mr. Hubert has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Hubert.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there
are no legal, civil or disciplinary events to disclose regarding Mr. Hubert.
However, we do encourage you to independently view the background of Mr. Hubert on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
3049563.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Hubert is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mr. Hubert’s role with SilverLake. As an insurance professional, Mr. Hubert will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Hubert is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Hubert or the Advisor. Mr. Hubert spends approximately 5% of his time per
month in this capacity.
Item 5 – Additional Compensation
Mr. Hubert has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Hubert serves as a Sr. Vice President of SilverLake and is supervised by Jeffrey Steele, the Chief
Compliance Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons.
As a registered entity, SilverLake is subject to examinations by regulators, which may be announced or
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 46
Form ADV Part 2B – Brochure Supplement
for
Hans F. Smith
Investment Advisor Representative
Effective: June 30, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Hans F. Smith (CRD# 6322329) in addition to the information contained in the SilverLake Wealth Management
LLC (“SilverLake” or the “Advisor”, CRD# 165525) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the SilverLake Disclosure Brochure or
this Brochure Supplement, please contact us at (802) 857-5083 or by email at info@silverlakewealth.com.
Additional information about Mr. Smith is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6322329.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 47
Item 2 – Educational Background and Business Experience
Hans F. Smith, born in 1981, is dedicated to advising Clients of SilverLake as an Investment Advisor
Representative. Mr. Smith earned a BA in Economics from the University of Vermont in 2003. Additional
information regarding Mr. Smith’s employment history is included below.
Employment History:
Investment Advisor Representative, SilverLake Wealth Management LLC
Investment Advisor Representative, One Day In July LLC
Pilot, Taughannock Aviation
Investment Advisor Representative, Thornton Investment Management PLLC
Pilot, PC Construction
06/2025 to Present
01/2017 to 06/2025
08/2015 to 03/2019
04/2014 to 12/2016
09/2014 to 08/2015
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Smith. Mr. Smith has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Smith.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there
are no legal, civil or disciplinary events to disclose regarding Mr. Smith.
However, we do encourage you to independently view the background of Mr. Smith on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
6322329.
Item 4 – Other Business Activities
Mr. Smith is dedicated to the investment advisory activities of SilverLake’s Clients. Mr. Smith does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Smith is dedicated to the investment advisory activities of SilverLake’s Clients. Mr. Smith does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Smith serves as an Investment Advisor Representative of SilverLake and is supervised by Jeffrey Steele,
the Chief Compliance Officer. Mr. Steele can be reached at (802) 857-5083.
SilverLake has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of SilverLake. Further, SilverLake is subject to regulatory
oversight by various agencies. These agencies require registration by SilverLake and its Supervised Persons.
As a registered entity, SilverLake is subject to examinations by regulators, which may be announced or
unannounced. SilverLake is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 48
Privacy Policy
Effective: June 30, 2025
Our Commitment to You
SilverLake Wealth Management, LLC (“SilverLake” or the “Advisor”) is committed to safeguarding the use of
your personal information that we have as your Investment Advisor. SilverLake (also referred to as "we," "our,"
and "us" throughout this notice) protects the security and confidentiality of the personal information we have and
implements controls to ensure that such information is used for proper business purposes in connection with the
management or servicing of our relationship with you. Our relationship with you is our most important asset. We
understand that you have entrusted us with your private information, and we do everything we can to maintain
that trust.
SilverLake does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and proper business purposes in connection with the servicing and management of
our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Privacy Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) share some of your personal information. Federal and State laws
give you the right to limit some of this sharing. Federal and State laws require RIAs to disclose how we
collect, share, and protect your personal information.
What information do we collect from you?
Social security or taxpayer identification number
Assets and liabilities
Name, address, and phone number[s]
Income and expenses
Email address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What sources do we collect information from in addition to you?
Custody, brokerage, and advisory agreements
Account applications and forms
Other advisory agreements and legal documents
Investment questionnaires and suitability documents
Transactional information with us or others
Other information needed to service account
How we share your information?
RIAs do need to share personal information regarding their clients to effectively implement the RIA’s services.
In the section below, we list some reasons we may share your personal information.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 49
Basis for sharing
Sharing
Limitations
Servicing our Clients
We may share non-public personal information with non-
affiliated third parties (such as brokers, custodians,
regulators, credit agencies, other financial institutions) as
necessary for us to provide agreed services to you consistent
with applicable law, including but not limited to:
SilverLake may
share this
information.
Clients cannot limit
the Advisor’s ability
to share.
• Processing transactions;
• General account maintenance;
• Responding to regulators or legal investigations; and
• Credit reporting, etc.
We are required to share your information with Purshe
Kaplan Sterling Investments, Inc. due to the affiliation of our
advisory persons as registered representatives of PKS.
SilverLake may
share this
information.
Clients cannot limit
the Advisor’s ability
to share.
Administrators
We may disclose your non-public personal information to
companies we hire to help administrate our business.
Companies we hire to provide services of this kind are not
allowed to use your personal information for their own
purposes and are contractually obligated to maintain strict
confidentiality. We limit their use of your personal information
to the performance of the specific service we have
requested.
SilverLake does not
share personal
information.
Clients cannot limit
the Advisor’s ability
to share.
Marketing Purposes
SilverLake does not disclose and does not intend to disclose
personal information with non-affiliated third parties to offer
you services. Certain laws may give us the right to share
your personal information with financial institutions where you
are a customer and where SilverLake or the client has a
formal agreement with the financial institution. We will only
share information for purposes of servicing your
accounts, not for marketing purposes.
SilverLake does
share personal
information.
Clients can limit the
Advisor’s ability to
share.
Authorized Users
In addition, your non-public personal information may also be
disclosed to you and persons we believe to be your
authorized agent[s] or representative[s].
Clients can limit the
Advisor’s ability to
share.
Information About Former Clients
SilverLake does not disclose and does not intend to disclose
non-public personal information to non-affiliated third parties
with respect to persons who are no longer our clients.
SilverLake does not
share personal
information regarding
former clients
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
Page 50
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural,
and electronic safeguards. These include computer safeguards such as passwords, secured files, and
buildings.
Our employees are advised about SilverLake's need to respect the confidentiality of each client’s non-public
personal information. We train our employees on their responsibilities.
We require third parties that assist in providing our services to you to protect the personal information they
receive. This includes contractual language in our third-party agreements.
Changes to our Privacy Policy.
We will send you notice of our Privacy Policy annually for as long as you maintain an ongoing relationship
with us.
Periodically we may revise our Privacy Policy and will provide you with a revised policy if the changes
materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the
sharing of non-public personal information other than as described in this notice unless we first notify you and
provide you with an opportunity to prevent the information sharing.
State-Specific Regulations
Vermont
In response to a Vermont regulation, if we disclose personal information about
you to non-affiliated third parties, we will only disclose your name, address, other
contact information, and general information about our experience with you.
Questions: You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy
Policy by contacting us at (802) 857-5083 or by email at info@silverlakewealth.com.
SilverLake Wealth Management, LLC
33 Blair Park Road, Suite 100, Williston, VT 05495
Phone : (802) 857-5083 | Fax : (802) 857-5082
www.silverlakewealth.com
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