View Document Text
Item 1: Cover Page
Part 2A of Form ADV
February 2026
1300 Oliver Road, Suite 210
Fairfield, CA 94534
www.SolanoWealth.com
Firm Contact:
Carlos Mendoza
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Solano Wealth
Investment Advisors, LLC dba Solano Wealth Advisors. If clients have any questions about the
contents of this brochure, please contact us at (707) 435-8400 or carlos@solanowealth.com. The
information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any State Securities Authority. Additional information about our firm is
also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #322037.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Solano Wealth Investment Advisors, LLC dba Solano Wealth Advisors is required to notify clients of
any information that has changed since the last annual update of the Firm Brochure (“Brochure”) that
may be important to them. Clients can request a full copy of our Brochure or contact us with any
questions that they may have about the changes.
Since our last annual amendment filing filed on March 6th, 2025, we have the following material
changes to report:
• Our firm has changed our DBA name to Solano Wealth Advisors.
• Our firm now maintains Standing Letters of Authorization granting third-party money
movement authority. Please see Item 16 of this brochure for more information.
• Our firm has amended Item 8 of this brochure to expand on the different types of securities
we may recommend in client accounts. Please see Item 8 for more information.
ADV Part 2A – Firm Brochure
Page 2
Solano Wealth Advisors
Item 3: Table of Contents
Item 1: Cover Page ................................................................................................................................................................... 1
Part 2A of Form ADV ............................................................................................................................................................... 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ...................................................................................................................................................... 3
Item 4: Advisory Business .................................................................................................................................................... 4
Item 5: Fees & Compensation .............................................................................................................................................. 5
Item 6: Performance-Based Fees & Side-By-Side Management ............................................................................ 6
Item 7: Types of Clients & Account Requirements ..................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .................................................................... 7
Item 9: Disciplinary Information .................................................................................................................................... 12
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 12
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............ 12
Item 12: Brokerage Practices ........................................................................................................................................... 13
Item 13: Review of Accounts or Financial Plans....................................................................................................... 18
Item 14: Client Referrals & Other Compensation ..................................................................................................... 18
Item 15: Custody .................................................................................................................................................................... 19
Item 16: Investment Discretion ....................................................................................................................................... 20
Item 17: Voting Client Securities ..................................................................................................................................... 20
Item 18: Financial Information ........................................................................................................................................ 20
ADV Part 2A – Firm Brochure
Page 3
Solano Wealth Advisors
Item 4: Advisory Business
We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a limited liability company formed under the laws of the State of
California in 2024 and has been in business as an investment adviser since that time. Our firm is
wholly owned by Carlos Mendoza.
Types of Advisory Services Offered
Wrap Asset Management Services:
For more information regarding our Wrap Fee Based Asset Management services, please see Item 4
of our Wrap Fee Brochure.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically 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 Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Assuming that all the information and documents requested from the client are
provided promptly, plans or consultations are typically completed within 6 months of the client
signing a contract with our firm.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Wrap Asset Management services.
General investment advice will be offered to our Financial Planning & Consulting clients.
ADV Part 2A – Firm Brochure
Page 4
Solano Wealth Advisors
Participation in Wrap Fee Programs
Our firm only offers wrap fee accounts to our clients, which are managed on an individualized basis
according to the client’s investment objectives, financial goals, risk tolerance, etc. Please see our Part
2A, Appendix 1 (the “Wrap Fee Program Brochure”) for more information.
Regulatory Assets Under Management
Our firm manages $331,919,831 on a discretionary basis and $0 on a non-discretionary basis as of
December 31st, 2025.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Wrap Asset Management:
For more information regarding pricing, please see Item 4 of the Wrap Fee Brochure.
Financial Planning & Consulting:
Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. The maximum hourly fee to be charged will not exceed $350. Flat fees
range from $1,500 to $10,000 Our firm requires a retainer of 50% of the ultimate financial planning
or consulting fee at the time of signing. The fee-paying arrangements will be determined on a case-
by-case basis and will be detailed in the signed consulting agreement. Our firm will not require a
retainer exceeding $1,200 when services cannot be rendered within 6 months.
Other Types of Fees & Expenses
Wrap clients will not incur transaction costs for trades by their chosen custodian. More information
about this can be found in our separate Wrap Fee Program Brochure.
LPL Financial offers a trading platform with select exchange traded funds (“ETFs”) that do not charge
transaction fees. The no-transaction-fee ETF trading platform is available to clients participating in
LPL Financial’s Strategic Wealth Management (“SWM”) programs. Clients will be subject to
transaction fees charged by LPL Financial for ETFs not included in LPL Financial’s platform and for
other types of securities. The limited number of ETFs available on LPL Financial’s no-transaction fee
platform may have higher overall expenses than other types of securities and ETFs not included in
ADV Part 2A – Firm Brochure
Page 5
Solano Wealth Advisors
the platform. Other major custodians have eliminated transaction fees for all ETFs and U.S. listed
equities, so clients may pay more for investing in the same securities at LPL Financial.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), distribution
fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and
mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire
transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm
does not receive a portion of these fees.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Wrap Asset Management
and services in writing at any time. Either party may terminate the signed advisory agreement at any
time. Upon receipt of your notice of termination, LPL will process a pro-rata refund of the unearned
portion of the advisory fees charged in advance at the beginning of the quarter.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Commissionable Securities Sales
In order to sell securities for a commission, our supervised persons are registered representatives of
LPL Financial, LLC (“LPL”), member FINRA/SIPC. Our supervised persons may accept compensation
for the sale of securities or other investment products, including distribution or service (“trail”) fees
from the sale of mutual funds. You should be aware that the practice of accepting commissions for the
sale of securities presents a conflict of interest and gives our firm and/or our supervised persons an
incentive to recommend investment products based on the compensation received, rather than on
your needs. We generally address commissionable sales conflicts that arise:
a) by explaining to clients that commissionable securities sales create an incentive to
recommend products based on the compensation we and/or our supervised persons may
earn and may not necessarily be in the best interests of the client; and
b) when recommending commissionable mutual funds, explaining that “no-load” funds are also
available.
Item 6: Performance-Based Fees & Side-By-Side Management
We do not accept performance-based fees.
ADV Part 2A – Firm Brochure
Page 6
Solano Wealth Advisors
Item 7: Types of Clients & Account Requirements
We have the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations; and
• Corporations, Limited Liability Companies and/or Other Business Types.
Our requirements for opening and maintaining accounts or otherwise engaging us:
• We generally charge a minimum fee of $1,500 for written financial plans. We require a
minimum household balance of $250,000 for our Wrap Asset Management services.
is negotiable depending on the client’s extenuating
The minimum account requirement
circumstances.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an
appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and
risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a
particular security, industry or market sector. Another risk is that the ratio of securities, fixed income,
and cash will change over time due to stock and market movements and, if not corrected, will no
longer be appropriate for the client’s goals.
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the financial
condition and management of the company itself) to determine if the company is underpriced
(indicating it may be a good time to buy) or overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk, as the price of a security can move up or down along with the overall market regardless of the
economic and financial factors considered in evaluating the stock.
Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis: Analysis of the experience and
track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has
demonstrated an ability to invest over a period of time and in different economic conditions. The
underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is
significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The
funds or ETFs are monitored in an attempt to determine if they are continuing to follow their stated
investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments,
ADV Part 2A – Firm Brochure
Page 7
Solano Wealth Advisors
past performance does not guarantee future results. A manager who has been successful may not be
able to replicate that success in the future. In addition, as our firm does not control the underlying
investments in a fund or ETF, managers of different funds held by the Client may purchase the same
security, increasing the risk to the Client if that security were to fall in value. There is also a risk that
a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which
could make the holding(s) less suitable for the Client’s portfolio.
Investment Strategies We Use & Preferred Securities
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Cash & Cash Equivalents: Cash and cash equivalents generally refer to either United States dollars
or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank CD’s and
commercial papers. Generally, these assets are considered nonproductive and will be exposed to
inflation risk and considerable opportunity cost risk. Investments in cash and cash equivalents will
generally return less than the advisory fee charged by our firm. Our firm may recommend cash and
cash equivalents as part of our clients’ asset allocation when deemed appropriate and in their best
interest. Our firm considers cash and cash equivalents to be an asset class. Therefore, our firm assess
an advisory fee on cash and cash equivalents unless indicated otherwise in writing.
Exchange Traded Funds (“ETFs”): An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
between the returns of a fund and the returns of the index, can arise due to differences in composition,
management fees, expenses, and handling of dividends. ETFs benefit from continuous pricing; they
can be bought and sold on a stock exchange throughout the trading day. Because ETFs trade like
stocks, you can place orders just like with individual stocks - such as limit orders, good-until-canceled
orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are bought and
redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought and sold at
the market prices on the exchanges, which resemble the underlying NAV but are independent of it.
However, arbitrageurs will ensure that ETF prices are kept very close to the NAV of the underlying
securities. Although an investor can buy as few as one share of an ETF, most buy in board lots.
Anything bought in less than a board lot will increase the cost to the investor. Anyone can buy any
ETF no matter where in the world it trades. This provides a benefit over mutual funds, which
generally can only be bought in the country in which they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently, this
can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
ADV Part 2A – Firm Brochure
Page 8
Solano Wealth Advisors
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk
associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
Individual Stocks: A common stock is a security that represents ownership in a corporation. Holders
of common stock exercise control by electing a board of directors and voting on corporate policy.
Investing in individual common stocks provides us with more control of what you are invested in and
when that investment is made. Having the ability to decide when to buy or sell helps us time the
taking of gains or losses. Common stocks, however, bear a greater amount of risk when compared to
certificate of deposits, preferred stock and bonds. It is typically more difficult to achieve
diversification when investing in individual common stocks. Additionally, common stockholders are
on the bottom of the priority ladder for ownership structure; if a company goes bankrupt, the
common stockholders do not receive their money until the creditors and preferred shareholders have
received their respective share of the leftover assets.
Long-Term Purchases. When utilizing this strategy, we may purchase securities with the idea of
holding them for a relatively long time (typically held for at least a year). A risk in a long-term
purchase strategy is that by holding the security for this length of time, we may not take advantage of
short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a
security may decline sharply in value before we make the decision to sell. Typically, we employ this
sub-strategy when we believe the securities to be well valued and/or we want exposure to a particular
asset class over time, regardless of the current projection for this class.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests that
money in a variety of differing security types based on the objectives of the fund. The portfolio of the
fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors
ADV Part 2A – Firm Brochure
Page 9
Solano Wealth Advisors
pay for mutual fund shares are the fund’s per share net asset value (“NAV”) plus any shareholder fees
that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot
ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence
which securities the fund manager buys and sells or the timing of those trades. With an individual
stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by
checking financial websites or by calling a broker or your investment adviser. Investors can also
monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with
a mutual fund, the price at which an investor purchases or redeems shares will typically depend on
the fund’s NAV, which is calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains
distributions they receive. This includes instances where the fund performed poorly after purchasing
shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given
time, nor can they directly influence which securities the fund manager buys and sells or the timing
of those trades.; and (c) With an individual stock, investors can obtain real-time (or close to real-time)
pricing information with relative ease by checking financial websites or by calling a broker or your
investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—or
even second to second. By contrast, with a mutual fund, the price at which an investor purchases or
redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until
many hours after the investor placed the order. In general, mutual funds must calculate their NAV at
least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor actually sells and makes a profit. Mutual funds, however, are
different. When an investor buys and holds mutual fund shares, the investor will owe income tax on
any ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to
owing taxes on any personal capital gains when the investor sells shares, the investor may have to
pay taxes each year on the fund’s capital gains. That is because the law requires mutual funds to
distribute capital gains to shareholders if they sell securities for a profit, and cannot use losses to
offset these gains.
Short-Term Purchases. When utilizing this strategy, we may also purchase securities with the idea
of selling them within a relatively short time (typically a year or less). We do this in an attempt to take
advantage of conditions that we believe will soon result in a price swing in the securities we purchase.
ADV Part 2A – Firm Brochure
Page 10
Solano Wealth Advisors
Structured Products. Structured products are designed to facilitate highly customized risk-return
objectives. While structured products come in many different forms, they typically consist of a debt
security that is structured to make interest and principal payments based upon various assets, rates
or formulas. Many structured products include an embedded derivative component. Structured
products may be structured in the form of a security, in which case these products may receive
benefits provided under federal securities law, or they may be cast as derivatives, in which case they
are offered in the over-the-counter market and are subject to no regulation.
Investing in structured products includes significant risks, including valuation, lack of liquidity, price,
credit and market risks. The relative lack of liquidity due to the highly customized nature of the
investment. Moreover, the full extent of returns from the complex performance features is often not
realized until maturity. As such, structured products tend to be more of a buy-and-hold investment
decision rather than a means of getting in and out of a position with speed and efficiency.
Another risk with structured products is the credit quality of the issuer. Although the cash flows are
derived from other sources, the products themselves are legally considered to be the issuing financial
institution's liabilities. The vast majority of structured products are from high-investment-grade
issuers only. Also, there is a lack of pricing transparency. There is no uniform standard for pricing,
making it harder to compare the net-of-pricing attractiveness of alternative structured product
offerings than it is, for instance, to compare the net expense ratios of different mutual funds or
commissions among broker-dealers.
Risk of Loss
Securities investments are not guaranteed and you may lose money on your investments. We ask that
you work with us to help us understand your tolerance for risk. Investing in securities involves risk
of loss that clients should be prepared to bear. While the stock market may increase and your
account(s) could enjoy a gain, it is also possible that the stock market may decrease and your
account(s) could suffer a loss. It is important that you understand the risks associated with investing
in the stock market, are appropriately diversified in your investments, and ask us any questions you
may have.
Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may
cause your account value to likewise decrease, and vice versa. How specific fixed income securities
may react to changes in interest rates will depend on the specific characteristics of each security.
ADV Part 2A – Firm Brochure
Page 11
Solano Wealth Advisors
Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity
risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely
manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price
of a bond to decline.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are registered representatives of LPL, member FINRA/SIPC. They may
offer securities and receive commissions as a result of securities transactions. A conflict of interest
may arise as these commissionable securities sales may create an incentive to recommend products
based on the compensation they may earn. In any event, as a fiduciary, we always put our Client’s
interest above our own.
Representatives of our firm are insurance agents/brokers. They may offer insurance products and
receive fees as a result of insurance sales. A conflict of interest may arise as these insurance sales may
create an incentive to recommend products based on the compensation adviser and/or our
supervised persons may earn. In any event, as a fiduciary, we always put our Client’s interest above
our own.
Item 11: Code of Ethics, Participation or Interest
in Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all
material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty
is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal
securities transaction and insider trading. Our firm requires all representatives to conduct business
with the highest level of ethical standards and to comply with all federal and state securities laws at
all times. Upon employment with our firm, and at least annually thereafter, all representatives of our
firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm
and representatives must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all
clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a
potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly
upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried
out in a way that does not endanger the interest of any client. At the same time, our firm also believes
ADV Part 2A – Firm Brochure
Page 12
Solano Wealth Advisors
that if investment goals are similar for clients and for our representatives, it is logical, and even
desirable, that there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected
by our representatives for their personal accounts1. In order to monitor compliance with our personal
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction
reporting system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time
they buy or sell the same securities for client accounts. In order to minimize this conflict of interest,
our related persons will place client interests ahead of their own interests and adhere to our firm’s
Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain
from buying or selling securities that will be bought or sold in client accounts unless done so after the
client execution or concurrently as a part of a block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
We seek to recommend a custodian/broker who will hold your assets and execute transactions on
terms that are overall most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others, these:
• Ability to maintain the confidentiality of trading intentions
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Liquidity of the securities traded
• Willingness to commit capital
• Ability to place trades in difficult market environments
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c)
which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct
or indirect beneficial interest in.
ADV Part 2A – Firm Brochure
Page 13
Solano Wealth Advisors
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
Our firm recommends that Clients establish accounts with LPL Financial (“LPL”), member
FINRA/SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. LPL provides
brokerage and custodial services to independent investment advisory firms, including our firm. For
accounts custodied at LPL, LPL is generally compensated by clients through commissions, trails, or
other transaction-based fees for trades that are executed through LPL or that settle into LPL accounts.
For IRA accounts, LPL generally charges account maintenance fees. In addition, LPL also charges
clients miscellaneous fees and charges, such as account transfer fees. LPL charges our firm an asset-
based administration fee for administrative services provided by LPL. Such administration fees are
not directly borne by Clients but may be taken into account when our firm negotiates its advisory fee
with clients.
While LPL does not participate in, or influence the formulation of, the investment advice our firm
provides, certain supervised persons of our firm are Dually Registered Persons. Dually Registered
Persons are restricted by certain Financial Industry Regulatory Authority (“FINRA”) rules and policies
from maintaining accounts at another custodian or executing transactions in such accounts through
any broker-dealer or custodian that is not approved by LPL. As a result, the use of other trading
platforms must be approved by our firm and LPL.
Clients should also be aware that for accounts where LPL serves as the custodian, our firm is limited
to offering services and investment vehicles that are approved by LPL and may be prohibited from
offering services and investment vehicles that may be available through other broker-dealers and
custodians, some of which may be more suitable for a client’s portfolio than the services and
investment vehicles offered through LPL. Clients should understand that not all investment advisers
require that Clients custody their accounts and trade through specific broker-dealers.
Benefits Received by Our Personnel
LPL makes available to our firm various products and services designed to assist our firm in managing
and administering client accounts. Many of these products and services may be used to service all or
a substantial number of accounts, including accounts not held with LPL. These include software and
other technology that provide access to client account data (such as trade confirmation and account
statements); facilitate trade execution (and aggregation and allocation of trade orders for multiple
client accounts); provide research, pricing information and other market data; facilitate payment of
our firm’s fees from its clients’ accounts; and assist with back-office functions; recordkeeping and
client reporting.
LPL also makes available to our firm other services intended to help manage and further develop our
business. Some of these services assist our firm to better monitor and service program accounts
maintained at LPL. Many of these services, however, benefit only our firm. These support services
and/or products may be provided without cost, at a discount, and/or at a negotiated rate, and include
ADV Part 2A – Firm Brochure
Page 14
Solano Wealth Advisors
practice management-related publications; consulting services; attendance at conferences and
seminars, meetings, and other educational and/or social events; marketing support; and other
products and services used by our firm in furtherance of the operation and development of its
investment advisory business.
Where such services are provided by a third-party vendor, LPL will either make a payment to our firm
to cover the cost of such services, reimburse our firm for the cost associated with the services, or pay
the third party vendor directly on behalf of our firm.
The products and services described above are provided to our firm as part of its overall relationship
with LPL. While as a fiduciary, our firm endeavors to act in its clients’ best interests, the receipt of
these benefits creates a conflict of interest because our firm’s requirement that Clients custody their
assets at LPL is based in part on the benefit to our firm of the availability of the foregoing products
and services and not solely on the nature, cost or quality of custody or brokerage services provided
by LPL. Our firm’s receipt of some of these benefits may be based on the amount of advisory assets
custodied on the LPL platform.
Transition Assistance Benefits
LPL Financial provides various benefits and payments to Dually Registered Persons that are new to
the LPL Financial platform to assist the representative with the costs (including foregone revenues
during account transition) associated with transitioning his or her business to the LPL Financial
platform (collectively referred to as “Transition Assistance”). The proceeds of such Transition
Assistance payments are intended to be used for a variety of purposes, including but not necessarily
limited to, providing working capital to assist in funding the Dually Registered Person’s business,
satisfying any outstanding debt owed to the Dually Registered Person’s prior firm, offsetting account
transfer fees (ACATs) payable to LPL Financial as a result of the Dually Registered Person’s clients
transitioning to LPL Financial’s custodial platform, technology set-up fees, marketing and mailing
costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support
and termination fees associated with moving accounts.
The amount of the Transition Assistance payments are often significant in relation to the overall
revenue earned or compensation received by the Dually Registered Person at [his/her] prior firm.
Such payments are generally based on the size of the Dually Registered Person’s business established
at [his/her] prior firm and/or assets under custody on the LPL Financial. Please refer to the relevant
Part 2B brochure supplement for more information about the specific Transition Payments your
representative receives.
Transition Assistance payments and other benefits are provided to associated persons of Solano
Wealth Advisors in their capacity as registered representatives of LPL Financial. However, the receipt
of Transition Assistance by such Dually Registered Persons creates conflicts of interest relating to
Solano Wealth Advisors’ advisory business because it creates a financial incentive for Solano Wealth
Advisors’ representatives to recommend that its clients maintain their accounts with LPL Financial.
In certain instances, the receipt of such benefits is dependent on a Dually Registered Person
maintaining its clients’ assets with LPL Financial and therefore Solano Wealth Advisors has an
incentive to recommend that clients maintain their account with LPL Financial in order to generate
such benefits.
ADV Part 2A – Firm Brochure
Page 15
Solano Wealth Advisors
Solano Wealth Advisors attempts to mitigate these conflicts of interest by evaluating and
recommending that clients use LPL Financial’ s services based on the benefits that such services
provide to our clients, rather than the Transition Assistance earned by any particular Dually
Registered Person. Solano Wealth Advisors considers LPL Financial’ s ability to maintain the
confidentiality of trading intentions, timeliness of execution, execution facilitation services provided,
accuracy and timeliness of trade confirmations, correction of trading errors, liquidity of securities
traded, ability to place trades in difficult market environments and the ability to access a variety of
market venues, expertise as it relates to specific securities and the ability to provide investment ideas,
research services, record keeping services, and custody services, financial condition, and overall
business reputation when recommending or requiring that clients maintain accounts with LPL
Financial. However, clients should be aware of this conflict and take it into consideration in making a
decision whether to custody their assets in a brokerage account at LPL Financial.
Client Brokerage Commissions
In addition to the benefits described above, LPL also makes available to our firm other products and
services that benefit our firm. These benefits may include national, regional or investment adviser
specific educational events organized and/or sponsored by LPL. Other potential benefits may include
occasional business entertainment of personnel of our firm by LPL personnel, including meals,
invitations to sporting events, including golf tournaments, and other forms of entertainment, some of
which may accompany educational opportunities. Some of these products and services assist our firm
in managing and administering clients’ accounts. These include software and other technology (and
related technological training) that provide access to client account data (such as trade confirmations
and account statements), facilitate trade execution (and allocation of aggregated trade orders for
multiple client accounts), provide research, pricing information and other market data, facilitate
payment of our fees from clients’ accounts, and assist with back-office training and support functions,
recordkeeping and client reporting. Many of these services may be used to service all or some
substantial number of our accounts, including accounts not maintained at LPL. LPL also makes
available to our firm other services intended to help our firm manage and further develop our
business enterprise. These services may include professional compliance, legal and business
consulting, publications and conferences on practice management, information technology, business
succession, regulatory compliance, employee benefits providers, human capital consultants,
insurance, and marketing. LPL may also make available, arrange and/or pay vendors for these types
of services rendered to our firm by independent third parties. LPL may discount or waive fees it would
otherwise charge for some of these services or pay all or a part of the fees of a third-party providing
these services to our firm. While, as a fiduciary, our firm endeavors to act in our clients’ best interests,
our recommendation/requirement that clients maintain their assets in accounts at LPL may be based
in part on the benefit to our firm of the availability of some of the foregoing products and services
and other arrangements and not solely on the nature, cost, or quality of custody and brokerage
services provided by LPL, which creates a potential conflict of interest.
As a result of receiving such products and services for no cost, our firm may have an incentive to
continue to place client trades through broker-dealers that offer soft dollar arrangements/the
aforementioned services and products. This interest conflicts with the clients' interest of obtaining
the lowest commission rate available. Therefore, our firm must determine in good faith, based on the
best execution policy stated above that such commissions are reasonable in relation to the value of
the services provided by such executing broker-dealers.
ADV Part 2A – Firm Brochure
Page 16
Solano Wealth Advisors
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
of securities are placed for execution, and the commission rates at which such securities transactions
are effected. Our firm routinely recommends that clients direct us to execute through a specified
broker-dealer. Our firm recommends the use of LPL.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Client-Directed Brokerage
We allow clients to direct brokerage outside our recommendation. However, we may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost clients
more money. For example, in a directed brokerage account, you may pay higher brokerage
commissions because we may not be able to aggregate orders to reduce transaction costs, or you may
receive less favorable prices.
Aggregation of Purchase or Sale
We perform investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the
ADV Part 2A – Firm Brochure
Page 17
Solano Wealth Advisors
same security for numerous accounts served by our firm, which involve accounts with similar
investment objectives. Although such concurrent authorizations potentially could be either
advantageous or disadvantageous to any one or more particular accounts, they are affected only when
we believe that to do so will be in the best interest of the effected accounts. When such concurrent
authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable
to the accounts involved. In any given situation, we attempt to allocate trade executions in the most
equitable manner possible, taking into consideration client objectives, current asset allocation and
availability of funds using price averaging, proration and consistently non-arbitrary methods of
allocation.
Item 13: Review of Accounts or Financial Plans
We review accounts on at least an annual basis for our clients subscribing to our Wrap Asset
Management services. The nature of these reviews is to learn whether clients’ accounts are in line
with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable. Investment Adviser Representatives of our firm, Carlos R. Mendoza,
and Francisco Guerra, will conduct reviews of accounts, as is applicable to them. We do not provide
written reports to clients, unless asked to do so, while verbal reports to clients take place on at least
an annual basis when we contact clients who subscribe to our Wrap Asset Management services.
We may review client accounts more frequently than described above for Wrap Asset Management
services. Among the factors which may trigger an off-cycle review are major market or economic
events, the client’s life events, requests by the client, etc.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Item 14: Client Referrals & Other Compensation
LPL Financial LLC
Our firm may receive from LPL or a mutual fund company, without cost and/or at a discount nonsoft-
dollar support services and/or products, to assist us to better monitor and service client accounts
maintained at such institutions. Included within the support services our firm may receive
investment-related research, pricing information and market data, software and other technology
that provide access to client account data, compliance and/or practice management-related
publications, discounted or gratis consulting services, discounted and/or gratis attendance at
conferences, meetings, and other educational and/or social events, marketing support, computer
hardware and/or software and/or other products used by us to assist us in our investment advisory
ADV Part 2A – Firm Brochure
Page 18
Solano Wealth Advisors
business operations. Our clients do not pay more for investment transactions effected and/or assets
maintained at LPL as a result of this arrangement. There is no commitment made by us to LPL or any
other institution as a result of the above arrangement.
Product Sponsors
Representatives of our firm will occasionally accept travel expense reimbursement provided by
product sponsors in order to attend their educational events. The reimbursement is not directly
dependent upon the recommendation of any specific product. Although we may be incentivized to
recommend products from product sponsors that reimburse our travel, our representatives will
always adhere to their fiduciary duty in recommending appropriate investments for our clients.
Client Referrals
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third
Party Money Movement.” All of our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
statements will include a legend that recommends the client compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4)-2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As
such, our firm has adopted the following safeguards in conjunction with our custodian:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
ADV Part 2A – Firm Brochure
Page 19
Solano Wealth Advisors
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a transfer
of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction
Item 16: Investment Discretion
Our firm only manages accounts where we have discretionary authority. Such authority shall be
granted through the executed investment advisory client agreement. By granting investment
discretion, we are authorized to execute securities transactions, which securities are bought and sold,
the total amount to be bought and sold, and the costs at which the transactions will be effected.
Item 17: Voting Client Securities
SEC Rule 206(4)-6 requires investment advisers who have voting authority with respect to securities
held in their clients’ accounts to monitor corporate actions and vote proxies in their clients’ interests.
Our firm is required by the SEC to adopt written policies and procedures, make those policies and
procedures available to clients, and retain certain records with respect to proxy votes cast.
Our firm considers proxy voting an important right of our clients as shareholders and believe that
reasonable care and diligence must be taken to ensure that such rights are properly and timely
exercised or abstain if we determine the issue to be non-material to our clients’ interests. When our
firm has discretion to vote the proxies of our clients, our firm will vote those proxies in the client’s
best interests and in accordance with these policies and procedures. Clients may request a copy of
our written policies and procedures regarding proxy voting and/or information on how particular
proxies were voted by contacting our Chief Compliance Officer, Carlos Mendoza, by phone at 707435-
8400 or email at carlos@solanowealth.com.
Item 18: Financial Information
We are not required to provide financial information in this Brochure because:
ADV Part 2A – Firm Brochure
Page 20
Solano Wealth Advisors
• We do not require the prepayment of more than $1,200 in fees and when services cannot be
rendered within 6 months.
• We do not take custody of client funds or securities.
• We do not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• We have never been the subject of a bankruptcy proceeding.
ADV Part 2A – Firm Brochure
Page 21
Solano Wealth Advisors