Overview
Assets Under Management: $628 million
Headquarters: LEHI, UT
High-Net-Worth Clients: 154
Average Client Assets: $4 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (FORM ADV 2A - APP 1 - WRAP BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $62,500 | 1.25% |
| $10 million | $125,000 | 1.25% |
| $50 million | $625,000 | 1.25% |
| $100 million | $1,250,000 | 1.25% |
Clients
Number of High-Net-Worth Clients: 154
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 97.68
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 748
Discretionary Accounts: 748
Regulatory Filings
CRD Number: 315843
Last Filing Date: 2025-02-12 00:00:00
Website: https://solidaritywealth.com
Form ADV Documents
Primary Brochure: FORM ADV 2A - APP 1 - WRAP BROCHURE (2025-09-22)
View Document Text
Item 1: Cover Page
Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure
September 2025
Solidarity Wealth, LLC Wrap Program
Sponsored by:
Solidarity Wealth, LLC
3600 N Outlet Parkway, Suite 200,
Lehi, Utah 84048
www.solidaritywealth.com
Firm Contact:
Jeffrey McClean
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Solidarity
Wealth, LLC. If clients have any questions about the contents of this brochure, please contact us at
(385) 374-1665 or info@solidaritywealth.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 #315843.
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
Solidarity Wealth, LLC is required to notify clients of any information that has changed since the last
annual update of the Wrap Brochure (“Wrap Brochure”) that may be important to them. Clients can
request a fully copy of our Wrap Brochure or contact us with any questions that they may have about
the changes.
Since our firm’s most recent annual amendment filing, we have the following material changes to
report:
• We have amended our policies for billing on deposits and withdrawals so as to only make
adjustments for individual transactions in excess of $1,000,000
• We have terminated our agreement with SmartAsset to pay compensation for new client
leads.
• We now accept proxy voting authority as described below in Item 6.
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Solidarity Wealth, LLC
Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Services, Fees & Compensation .......................................................................................................................... 4
Item 5: Account Requirements & Types of Clients .................................................................................................... 6
Item 6: Portfolio Manager Selection & Evaluation ..................................................................................................... 6
Item 7: Client Information Provided to Portfolio Manager(s) ............................................................................ 16
Item 8: Client Contact with Portfolio Manager(s) .................................................................................................... 16
Item 9: Additional Information ........................................................................................................................................ 16
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Item 4: Services, Fees & Compensation
Our firm manages assets for many different types of clients to help meet their financial goals while
remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in
the client’s best interest. This is accomplished in part by knowing the client. Our firm has established
a service-oriented advisory practice with open lines of communication. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for
investment advisory services and associated custodial transaction costs. Transaction fees will be paid
by our firm via individual transaction charges. Because our firm absorbs client transaction fees, an
incentive exists to limit trading activities in client accounts. Custodial transaction costs, however, are
not included in the advisory fee charged by our firm for non-wrap services, and are to be paid by the
client to their chosen custodian. Depending on the client’s account or portfolio trading activity, clients
may pay more for using our wrap fee services than they would for using our non-wrap services.
Our firm recommends Pershing Advisor Solutions, LLC (“Pershing”) as a custodian for client accounts.
Other major custodians have recently eliminated transaction fees for all ETFs and U.S. listed equities,
so clients may pay more for investing in the same securities at Pershing.
Our Wrap Advisory Services
Our Wrap services are offered to a select number of clients in which it is deemed to be suitable. We
only offer Wrap services for clients that we expect to incur transaction charges due to our firm’s
options investment strategy. Our Wrap Wealth Management service is offered as a separate,
standalone service.
❖ Wrap Wealth Management:
We begin our relationship by developing a thorough understanding of your financial and non-
financial goals. Our firm reviews each client’s overall financial circumstances, including, among
other items, current tax status, income level, and personal balance sheet; estate planning needs,
insurance coverage, and family tree; and expected liquidity needs in the short and long term. Our
firm seeks to understand a client’s overall investment goals, previous investment experience, and
tolerance for certain types of risk and complexity that can be involved in investing and planning
for a client’s financial future. We periodically ask client’s to provide us with pertinent documents
and information (bank and brokerage account statements, insurance policies, wills, trusts and
other estate planning documents, tax returns, etc.) to further assist us in this information
gathering process, as necessary. Based on what is learned, an investment approach is presented
to the client, consisting of individual stocks, bonds, ETFs, options, mutual funds and other public
and private securities or investments. Once the appropriate portfolio has been determined,
portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the
client’s individual needs, stated goals and objectives. Upon client request, our firm provides a
summary of observations and recommendations for the planning or consulting aspects of this
service.
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Although our firm will provide tax and estate planning advice and coordinate all tax and estate
planning advice with a client’s trusted legal and tax advisors, our firm relies on the client and
their trusted outside advisors to implement any recommendations.
For Clients that sign an agreement for our Wealth Management Service, each Client will be
charged a management fee (the “Wealth Management Fee”) of up to a maximum annual rate of
1.25% (“the Wealth Management Fee Rate”) of the gross market value of assets under
management, including, if applicable, a target notional value of options overlays (together, a
client’s “Gross Assets”), paid quarterly, in advance of each quarter. Certain private securities may
have a lag in valuations, and these assets will be valued based upon the most recently available
data. Additionally, our firm excludes accrued interest and dividends from our advisory fee
calculations. Each Client’s Wealth Management Fee Rate is set forth in a wealth management
agreement, and is determined based on several factors, including: the complexity of the services
to be provided, the level of assets to be managed, and the overall relationship with the Adviser.
The Custodian will independently value all securities held in accounts managed by our firm. Our
firm will not have the authority or responsibility to value portfolio securities.
The Client may make additions or withdrawals from the account[s] at any time, subject to the
Adviser’s right to terminate an account or the overall relationship. Additions may be in cash or
securities provided that the Adviser reserves the right to liquidate any transferred securities or
decline to accept particular securities into a Client’s account[s]. Clients may withdraw account
assets on notice to our firm, subject to the usual and customary securities settlement procedures.
However, the Adviser typically designs its investment portfolios as long-term investments, and
the withdrawal of assets may impair the achievement of a Client’s investment objectives. Our firm
may consult the Client about certain implications such transactions. Clients are advised that when
such securities are liquidated, they may be subject to securities transaction fees, short-term
redemption fees, and/or tax ramifications. Our firm will make a billing adjustment for any
individual deposit or withdrawal in excess of $1,000,000 from the Client’s account[s] such that
our firm’s fee will be applied pro rata based on the average daily balance of the account during
that period.
Wealth Management Fees are charged and paid quarterly, in advance of each calendar quarter,
pursuant to the terms of the Client’s wealth management agreement based on the Client’s Gross
Assets as of the end of the prior calendar quarter. Wealth Management Fees are calculated by the
Adviser or its delegate and deducted from each Client’s account(s) by the Custodian. Each client’s
Wealth Management Fee is calculated by dividing such Client’s then current Wealth Management
Fee Rate by 4 and multiplying the quotient by the Client’s Gross Assets. Clients will be provided
with a statement, at least quarterly, from the Custodian reflecting deduction of the wealth
management fee. Unless otherwise agreed to in writing, our advisory fees shall be assessed on
cash and cash equivalents. 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 our firm to be paid directly from
their account(s) held by the Custodian as part of the wealth management agreement and separate
account forms provided by the Custodian. If our firm sends a copy of our invoice to the client, a
legend urging the comparison of information provided in our statement with those from the
qualified custodian will be included.
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Other Types of Fees & Expenses:
In addition to our advisory fees above, 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.
Furthermore, Pershing Advisor Solutions, LLC (“Pershing”), does not charge our firm transaction fees
for U.S. listed equities and exchange traded funds.
Termination and Refunds:
Clients that sign an agreement for our standalone Wrap Wealth Management service may terminate
the advisory agreement in writing at any time. Upon notice of termination clients will receive a pro-
rata refund of unearned fees charged in advance.
Wrap Fee Program Recommendations:
Our firm does not recommend or offer the wrap program services of other providers.
Item 5: Account Requirements & Types of Clients
Our firm does not have a minimum account balance for opening and maintaining accounts or
otherwise engaging our firm. However, our firm recommends that clients have a minimum account
balance of $5,000,000 for engaging us for our services
Our firm has the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Corporations, Limited Liability Companies and/or Other Business Types
Item 6: Portfolio Manager Selection & Evaluation
Selection of Portfolio Managers:
Our firm’s investment adviser representatives (“IARs”) act as portfolio manager(s) for this wrap fee
program. A conflict arises in that other investment advisory firms may charge the same or lower fees
than our firm for similar services. Our IARs are subject to individual licensing requirements as
imposed by state securities boards. Our firm is required to confirm or update each IAR’s Form U4 on
an annual basis. IAR supervision is conducted by our Chief Compliance Officer or management
personnel.
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Advisory Business:
Information about our wrap fee services can be found in Item 4 of this brochure. Our firm offers
individualized investment advice to our clients that sign a wrap service agreement with our firm.
Restrictions on investments in certain securities or types of securities may not be possible due to the
level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs:
Our firm does not manage wrap fee accounts in a different fashion than non-wrap fee accounts. All
accounts are managed on an individualized basis according to the client’s investment objectives,
financial goals, risk tolerance, etc.
Methods of Analysis:
The following methods of analysis and investment strategies may be utilized in formulating our
investment advice and/or managing client assets, provided that such methods and/or 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.
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in response
to certain events taking place around the world. These include events directly involving the issuers
of securities held as underlying assets in a client’s account, conditions affecting the general economy,
and overall market changes. Other contributing factors include local, regional, or global political,
social, or economic instability and governmental or governmental agency responses to economic
conditions. Currency, interest rate, and commodity price fluctuations may also affect security prices
and income.
The prices of, and the income generated by, most debt securities held by a client’s account may be
affected by changing interest rates and by changes in the effective maturities and credit ratings of
these securities. For example, the prices of debt securities in the client’s account generally will decline
when interest rates rise and increase when interest rates fall. In addition, falling interest rates may
cause an issuer to redeem, “call” or refinance a security before its stated maturity, which may result
in our firm having to reinvest the proceeds in lower yielding securities. Longer maturity debt
securities generally have higher rates of interest and may be subject to greater price fluctuations than
shorter maturity debt securities. Debt securities are also subject to credit risk, which is the possibility
that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make
timely payments of principal or interest and the security will go into default.
The guarantee of a security backed by the U.S. Treasury or the full faith and credit of the U.S.
government only covers the timely payment of interest and principal when held to maturity. This
means that the current market values for these securities will fluctuate with changes in interest rates.
Investments in securities issued by entities based outside the United States may be subject to
increased levels of the risks described above. Currency fluctuations and controls, different
accounting, auditing, financial reporting, disclosure, regulatory and legal standards and practices
could also affect investments in securities of foreign issuers. Additional factors may include
expropriation, changes in tax policy, greater market volatility, different securities market structures,
and higher transaction costs. Various administrative difficulties, such as delays in clearing and
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settling portfolio transactions, or in receiving payment of dividends can increase risk. Finally,
investments in securities issued by entities domiciled in the United States may also be subject to
many of these risks.
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting: In this type of technical analysis, our firm reviews charts of market and security activity in
an attempt to identify when the market is moving up or down and to predict how long the trend may
last and when that trend might reverse.
Cyclical Analysis: Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis.
Duration Constraints: Our firm adhere to a discipline of generally maintaining duration within a
narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio
management team rebalances client portfolios to their current duration targets on a periodic basis.
The risk of constraining duration is that the client may not participate fully in a large rally in bond
prices.
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. 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.
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Technical Analysis: A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The
process usually consists of searching vast databases for patterns, such as correlations among liquid
assets or price-movement patterns (trend following or mean reversion). The resulting strategies may
involve high-frequency trading. The results of the analysis are taken into consideration in the
decision to buy or sell securities and in the management of portfolio characteristics. A risk in using
quantitative analysis is that the methods or models used may be based on assumptions that prove to
be incorrect.
Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable
information, such as management expertise, industry cycles, strength of research and development,
and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on
numbers that can be found on reports such as balance sheets. The two techniques, however, will often
be used together in order to examine a company's operations and evaluate its potential as an
investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to
the social and experiential realm rather than the mathematical one. This approach depends on the
kind of intelligence that machines (currently) lack, since things like positive associations with a
brand, management trustworthiness, customer satisfaction, competitive advantage and cultural
shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative
analysis is that subjective judgment may prove incorrect.
Sector Analysis: Sector analysis involves identification and analysis of various industries or
economic sectors that are likely to exhibit superior performance. Academic studies indicate that the
health of a stock's sector is as important as the performance of the individual stock itself. In other
words, even the best stock located in a weak sector will often perform poorly because that sector is
out of favor. Each industry has differences in terms of its customer base, market share among firms,
industry growth, competition, regulation and business cycles. Learning how the industry operates
provides a deeper understanding of a company's financial health. One method of analyzing a
company's growth potential is examining whether the amount of customers in the overall market is
expected to grow. In some markets, there is zero or negative growth, a factor demanding careful
consideration. Additionally, market analysts recommend that investors should monitor sectors that
are nearing the bottom of performance rankings for possible signs of an impending turnaround.
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Investment Strategies We Use
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:
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic,
foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-
term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these
three provides a starting point. Usually included are hybrid instruments such as convertible bonds
and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be
considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.;
Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps;
insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and
futures; foreign currency; venture capital; private equity; and/or distressed securities.
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.
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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.
Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm makes a decision to sell.
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
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
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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.
Options: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder, or option buyer). The contract offers the buyer the right,
but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the
strike price) during a certain period of time or on a specific date (exercise date). Options are
extremely versatile securities. Traders use options to speculate, which is a relatively risky practice,
while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option
buyers and writers have conflicting views regarding the outlook on the performance of a:
• Call Option: Call options give the option to buy at certain price, so the buyer would want the
stock to go up. Conversely, the option writer needs to provide the underlying shares in the
event that the stock's market price exceeds the strike due to the contractual obligation. An
option writer who sells a call option believes that the underlying stock's price will drop
relative to the option's strike price during the life of the option, as that is how he will reap
maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes
that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock
for a lower price and then sell it for a profit. However, if the underlying stock does not close
above the strike price on the expiration date, the option buyer would lose the premium paid
for the call option.
• Put Option: Put options give the option to sell at a certain price, so the buyer would want the
stock to go down. The opposite is true for put option writers. For example, a put option buyer
is bearish on the underlying stock and believes its market price will fall below the specified
strike price on or before a specified date. On the other hand, an option writer who sells a put
option believes the underlying stock's price will increase about a specified price on or before
the expiration date. If the underlying stock's price closes above the specified strike price on
the expiration date, the put option writer's maximum profit is achieved. Conversely, a put
option holder would only benefit from a fall in the underlying stock's price below the strike
price. If the underlying stock's price falls below the strike price, the put option writer is
obligated to purchase shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock
price to the option’s strike price, small movements in a stock can translate into big movements in the
underlying options.
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Margin Loans: Our firm may allow or recommend that you to pledge securities from your portfolio
as collateral for a loan by using margin in brokerage account. This allows you to own more stock than
you would be able to with your available cash. Margin accounts and transactions are risky and not
necessarily appropriate for every client.
Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). Our firm does this in an
attempt to take advantage of conditions that our firm believes will soon result in a price swing in the
securities our firm purchase.
Private Equity: Private equity is an equity investment into non-public companies. Private equity
funds hold illiquid positions (for which there is no active secondary market) and typically only invest
in the equity and debt of target companies, which are generally taken private and brought under the
private equity manager's control. Risks associated with private equity include:
• Funding Risk: The unpredictable timing of cash flows poses funding risks to investors.
Commitments are contractually binding and defaulting on payments results in the loss of
private equity partnership interests. This risk is also commonly referred to as default risk.
• Liquidity Risk: The illiquidity of private equity partnership interests exposes investors to
asset liquidity risk associated with selling in the secondary market at a discount on the
reported NAV.
• Market Risk: The fluctuation of the market has an impact on the value of the investments held
in the portfolio.
• Capital Risk: The realization value of private equity investments can be affected by numerous
factors, including (but not limited to) the quality of the fund manager, equity market
exposure, interest rates and foreign exchange.
Private Funds: A private fund is an investment vehicle that pools capital from a number of investors
and invests in securities and other instruments. In almost all cases, a private fund is a private
investment vehicle that is typically not registered under federal or state securities laws. So that
private funds do not have to register under these laws, issuers make the funds available only to
certain sophisticated or accredited investors and cannot be offered or sold to the general public.
Private funds are generally smaller than mutual funds because they are often limited to a small
number of investors and have a more limited number of eligible investors. Many but not all private
funds use leverage as part of their investment strategies. Private funds management fees typically
include a base management fee along with a performance component. In many cases, the fund’s
managers may become “partners” with their clients by making personal investments of their own
assets in the fund. Most private funds offer their securities by providing an offering memorandum or
private placement memorandum, known as “PPM” for short.
The PPM covers important information for investors and investors should review this document
carefully and should consider conducting additional due diligence before investing in the private
fund. The primary risks of private funds include the following: (a) Private funds do not sell publicly
and are therefore illiquid. An investor may not be able to exit a private fund or sell its interests in the
fund before the fund closes.; and (b) Private funds are subject to various other risks, including risks
associated with the types of securities that the private fund invests in or the type of business issuing
the private placement.
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Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, and that their assets are appropriately diversified in
investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance.
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.
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
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.
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.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. This can create a substantial delay in the receipt of proceeds from an
investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to
quickly get out of an investment before the price drops significantly) a particular investment and
therefore, can have a negative impact on investment returns.
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Manager Risk: There is always the possibility that poor security selection will cause your
investments to underperform relative to benchmarks or other funds with a similar investment
objective.
Market Risk: The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes in
the market, and you could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade
in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in
general). For fixed-income securities, a period of rising interest rates could erode the value of a bond
since bond values generally fall as bond yields go up. Past performance is not a guarantee of future
returns.
Market Timing Risk: Market timing can include high risk of loss since it looks at an aggregate market
versus a specific security. Timing risk explains the potential for missing out on beneficial movements
in price due to an error in timing. This could cause harm to the value of an investor's portfolio because
of purchasing too high or selling too low.
Operational Risk: Operational risk can be experienced when an issuer of an investment product is
unable to carry out the business it has planned to execute. Operational risk can be experienced as a
result of human failure, operational inefficiencies, system failures, or the failure of other processes
critical to the business operations of the issuer or counter party to the investment.
Options Risk: Options on securities may be subject to greater fluctuations in value than an
investment in the underlying securities. Additionally, options have an expiration date, which makes
them “decay” in value over the amount of time they are held and can expire worthless. Purchasing
and writing put and call options are highly specialized activities and entail greater than ordinary
investment risks.
Past Performance: Charting and technical analysis are often used interchangeably. Technical
analysis generally attempts to forecast an investment’s future potential by analyzing its past
performance and other related statistics. In particular, technical analysis often times involves an
evaluation of historical pricing and volume of a particular security for the purpose of forecasting
where future price and volume figures may go. As with any investment analysis method, technical
analysis runs the risk of not knowing the future and thus, investors should realize that even the most
diligent and thorough technical analysis cannot predict or guarantee the future performance of any
particular investment instrument or issuer thereof.
Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under
all market conditions and each investor should evaluate his/her ability to maintain any investment
he/she is considering in light of his/her own investment time horizon. Investments are subject to
risk, including possible loss of principal.
Please Note: 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
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understand the risks associated with investing in the stock market, are appropriately diversified in
your investments, and ask any questions you may have.
Voting Client Securities:
Our firm votes client proxies when authorized to do so in writing by a client. Our firm understands
our duty to vote client proxies and to do so in the best interests of our clients. Furthermore, it is
understood that any material conflicts between our interests and those of our clients with regard to
proxy voting must be resolved before proxies are voted. Our firm generally abstains on most issues
up for vote. However we will review each issue, and vote when we deem the matter material to our
client’s interest. Documentation shall be retained with regard to each ballot cast.
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, Jeffrey
McClean, at (385) 374-1665 or info@solidaritywealth.com.
Item 7: Client Information Provided to Portfolio Manager(s)
All accounts are managed by our in-house licensed IARs. The IAR selected to manage the client’s
account(s) or portfolio(s) will be privy to the client’s investment goals and objectives, risk tolerance,
restrictions placed on the management of the account(s) or portfolio(s) and relevant client notes
taken by our firm. Please see our firm’s Privacy Policy for more information on how our firm utilizes
client information.
Item 8: Client Contact with Portfolio Manager(s)
Clients are always free to directly contact their portfolio manager(s) with any questions or concerns
about their portfolios or other matters.
Item 9: Additional Information
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.
Financial Industry Activities & Affiliations
Representatives of our firm are registered representatives of M.S. Howells & Co, member
FINRA/SIPC, and licensed insurance agents. As a result of these transactions, they receive normal and
customary commissions. A conflict of interest exists as these commissionable securities sales create
an incentive to recommend products based on the compensation earned. To mitigate this potential
conflict, our firm will act in the client’s best interest.
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Representatives of our firm are licensed or non-practicing attorneys in the State(s) of Texas and Utah.
Legal services are not offered through our firm. Should a client of our firm require legal services, they
will be referred to a separate attorney. Our firm will not receive any additional compensation for
these referrals.
Representatives of our firm are insurance agents/brokers. They offer insurance products and receive
customary fees as a result of insurance sales. A conflict of interest exists as these insurance sales
create an incentive to recommend products based on the compensation adviser and/or our
supervised persons may earn. To mitigate this potential conflict, our firm will act in the client’s best
interest.
Representatives of our firm are owners of a private investment firm. This constitutes a potential
conflict of interest. To mitigate this conflict representatives of our firm will prioritize their
involvement and interests of their clients at Solidarity Wealth, LLC. In addition, Representatives of
our firm are held to a fiduciary standard and will act in the client’s best interest
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 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.
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.
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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 the same securities prior to buying or selling for our clients in the same day. If related persons’
accounts are included in a block trade, our related persons will always trade personal accounts last.
Review of Accounts
For clients that sign an agreement for services offered under our Wrap Wealth Management service
we review accounts on at least an annual basis for our clients. 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. We do not provide written reports to
clients. Verbal reports to clients take place on at least an annual basis when we contact clients who
subscribe to at least one of these services.
Other Compensation
Except for the arrangements outlined in Item 12 of our firm Form ADV 2A Firm Brochure, our firm
has no additional arrangements to disclose.
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).
Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• Our firm has never been the subject of a bankruptcy proceeding.
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