Overview
- Headquarters
- Houston, TX
- Average Client Assets
- $6.9 million
- SEC CRD Number
- 328185
Fee Structure
Primary Fee Schedule (STAVIS WEALTH ADV-PART 2 BROCHURE (3.2026))
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $2,000,000 | 1.00% |
| $2,000,001 | $4,000,000 | 0.75% |
| $4,000,001 | $6,000,000 | 0.65% |
| $6,000,001 | $10,000,000 | 0.55% |
| $10,000,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $41,500 | 0.83% |
| $10 million | $70,000 | 0.70% |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- HNW Share of Firm Assets
- 97.88%
- Total Client Accounts
- 39
- Discretionary Accounts
- 35
- Non-Discretionary Accounts
- 4
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection
Regulatory Filings
Additional Brochure: STAVIS WEALTH ADV-PART 2 BROCHURE (3.2026) (2026-03-23)
View Document Text
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Item 1 – Cover Page
STAVIS WEALTH TRANSFER SOLUTIONS, LLC
1330 POST OAK BLVD, SUITE 2050
HOUSTON, TX 77056
(713) 391-8200
ADV-PART 2 BROCHURE (2A & 2B)
March 15, 2026
This Brochure provides information about the qualifications and business practices of
Stavis Wealth Transfer Solutions, LLC. If you have any questions about the contents of this
Brochure, please contact us at (713) 391-8200. 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.
Stavis Wealth Transfer Solutions, LLC or Stavis Wealth is a registered investment adviser.
Registration of an Investment Adviser does not imply any level of skill or training. The oral
and written communications of an Adviser provide you with information about which you
determine to hire or retain an Adviser.
Additional information about Stavis Wealth also is available on the SEC’s website at
www.adviserinfo.sec.gov.
~ i ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Item 2 – Material Changes
This Firm Brochure provides you with a summary of Stavis Wealth Transfer Solutions, LLC
or Stavis Wealth’s advisory services and fees, professionals, certain business practices and
policies, as well as actual or potential conflicts of interest, among other things. This Item is
used to provide our clients with a summary of new and/or updated information; we will
inform of the revision(s) based on the nature of the information as follows.
This Item of the Firm Brochure will note only specific material updates or changes that are
made to the Brochure and provide clients with a summary of such updates or changes. This
st
Brochure is an update of the Firm’s Annual Updated ADV-Part 2 Brochure for March 2025 (1
Quarter of 2025).
MATERIAL UPDATE(S)/CHANGE(S)
Items 4 & 8: Firm Advisory Business & Advisory Services/Programs were updated.
We have added disclosures in Item 4 – Advisory Business and Item 8 – Investment
Strategies regarding certain third-party private equity and venture capital investment
platforms and managers through which we may offer certain third party-managed
private fund investment vehicles and that we may recommend to advisory clients.
And Firm Assets Under Management or AUM was updated.
Item 5: Advisory Fees-Compensation disclosures were updated generally and also to
reflect an update in the Firm Principal’s affiliated broker-dealer as a registered
representative.
Item 10: Investment-Financial Industry Affiliation/Arrangement disclosures were
updated to reflect strategic relationship arrangements with third-party private equity
and venture capital managers.
Item 12: Brokerage Execution and Trading disclosures were updated.
Item 14: Client Referral and Other Compensation disclosures were updated to disclose
strategic relationship arrangements and related compensation involving certain third-
party private equity and venture capital managers.
The Firm will provide you with a new updated Brochure as necessary based on changes or
new information, at any time, without charge. Currently, our Brochure may be requested
by contacting Deborah Stavis, Firm Managing Principal/CEO, at dstavis@staviswealth.com.
~ ii ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Item 3 -Table of Contents
Item 1 – Cover Page ............................................................................................................................................... i
Item 2 – Material Changes.................................................................................................................................. ii
Item 3 – Table of Contents.................................................................................................................................iii
Item 4 – Advisory Business................................................................................................................................ 4
Item 5 – Fees and Compensation...................................................................................................................14
Item 6 – Performance-Based Fees and Side-By-Side Management.................................................. 18
Item 7 – Types of Clients.................................................................................................................................. 19
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 19
Item 9 – Disciplinary Information ................................................................................................................ 21
Item 10 – Other Financial Industry Activities and Affiliations........................................................... 21
Item 11 – Code of Ethics................................................................................................................................... 24
Item 12 – Brokerage Practices....................................................................................................................... 25
Item 13 – Review of Accounts........................................................................................................................ 29
Item 14 – Client Referrals and Other Compensation............................................................................. 30
Item 15 – Custody............................................................................................................................................... 30
Item 16 – Investment Discretion .................................................................................................................. 30
Item 17 – Voting Client Securities ................................................................................................................ 31
Item 18 – Financial Information ................................................................................................................... 31
Part 2B Brochure Supplement(s)
– Pgs. 32-35
~ iii ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Item 4 – Firm Advisory Business & Advisory Services/Programs
Stavis Wealth Transfer Solutions, LLC (Stavis Wealth or Firm) is a wealth and estate advisory
and asset management-advisory firm that provides financial and estate advisory and
planning services as well as asset management and related wealth transfer solutions to
clients, for a fee. The Firm offers and provides integrated wealth planning management and
wealth transfer services to high-net-worth (HNW) individuals and their families. Included is
the coordination with attorneys
regarding estate planning trusts and related vehicles,
charitable organizations, private and family foundations, family offices, and other corporate
and business entities. These services are designed to assist our clients in identifying and
realizing their personal and family financial and wealth planning objectives in coordination
with their other professional advisors. Stavis Wealth was founded and is majority-owned
and managed by its Managing Principal Deborah Stavis.
Stavis Wealth, in offering financial/estate planning services and certain investment advisory
supervisory services related to the client’s insurance policy, may also provide advice with
respect to both discretionary and non-discretionary sub-accounts (fully dependent upon
each individual carrier’s procedure). For such clients, we may provide other types of
advisory services to the client from time to time, which can include investment policy advice
and assistance, developing asset allocation strategies, manager selection and evaluation,
and/or review of outside accounts to assist with adherence to investment policy guidelines.
The types of service will be tailored to the needs of such clients and the availability of
investment choices within each insurance policy. Services include an analysis based on client
age, risk tolerance, and the availability and type of subaccounts (mutual-fund-like options)
within each policy. When discussing investment options within a life insurance policy, both
terms subaccount and Insurance Dedicated Funds (IDFs) may be used interchangeably.
Stavis Wealth also renders investment management and asset advisory services for assets
under management ("AUM") client accounts where the Firm provides such clients with on-
going, continuous investment and asset management advisory services. We analyze existing
portfolios, establish or assess financial and investment goals and objectives, and make
recommendations. In accordance with the clients' risk profile and investment goals, we
recommend securities, buy and sell them, and monitor their performance through the
investing cycle. Each client has a unique portfolio guided by his or her individual investment
objectives and goals and any related investment policy statement or other written
investment parameters. We consider all client assets that are disclosed to us to provide a
holistic investment approach for clients AUM and investment accounts. We offer non-
discretionary and discretionary portfolio and asset management services. Our investment
advice is tailored to meet our clients' needs and investment objectives while also observing
any investment restrictions. Such advisory clients should also receive an independent
statement of the portfolio directly from the independent qualified custodian.
For the Firm’s financial-wealth and estate advisory services involving client planning
objectives and the client's financial and investment position, Stavis Wealth will prepare a
~ 4 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
financial, wealth and estate plan designed to meet such client objectives. We offer financial
and wealth planning to clients as an independent service or as part of additional advisory,
planning and/or consulting services. Certain aspects of financial-wealth planning include
furnishing of investment advice as defined by the Investment Advisers Act of 1940, as
amended (“Advisers Act”), in which the Firm acts as a fiduciary under the Advisers Act.
Financial planning services are provided to advisory clients through a variety of means,
including through in-person meetings, video conferences, telephone calls, digital platforms,
e-mail, reporting, or a combination thereof. We also have available to us and use a variety of
proprietary and/or third-party tools to aid in delivering financial planning services to our
clients. Implementation of financial and wealth planning strategies and recommendations is
entirely at the client’s discretion.
Also, Stavis Wealth is not required to verify any information received from the client or from
the client’s other professionals and is expressly authorized to rely thereon. Moreover, each
client is advised that it remains the client’s responsibility to promptly notify the Firm if there
is ever any change in the client’s financial situation or investment objectives for the purpose
of reviewing, evaluating, and/or revising the Firm’s previous recommendations and/or
services. Managing Principal, Deborah Stavis, and Firm Staff are available for consultations
at the Firm’s contact number and to discuss any changes or updates to a client's financial
situation.
For financial planning, a conflict may exist between the interests of the Firm and the interest
of the client to the extent the Firm recommends itself to support and assist with the
implementation of its financial and wealth planning recommendations. The client is under
no obligation to act upon our recommendations, and, if the client elects to act on any of our
recommendations, the client is under no obligation to effect any transactions through us.
Also, neither we nor anyone associated with us are attorneys, and therefore no advice that
we confer should be construed as legal advice.
Financial-Wealth Planning, Consulting, and Analysis Services
for the clients’
Stavis Wealth also offers stand-alone financial, estate, and/or insurance planning services
that typically encompass preparation of dynamic, easily understood and actionable
recommendations, based on a thorough evaluation of clients’ personal financial situation and
objectives (“Financial Planning” or “Holistic Financial and Wealth Planning”). The
immediate
customized action plan specifies strategic measures
implementation and execution into an existing financial, wealth transfer and estate plan.
The Firm works with HNW individuals and families on their planning needs, including:
Estate/Legacy Planning
Wealth Planning & Multi-Generational Planning (Stewardship of family wealth)
Wealth Transfer Planning and Solutions
Trust Planning & Trust Policy Management
Strategic Planning and Family Governance
~ 5 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Asset Protection
Insurance Analysis & Risk Management
Philanthropic/Charitable Planning & Giving
The Firm also works with business owners to develop plans for:
Ownership transitions
Key employee retention
Discovers
Planning is a dynamic and continuous process. The following is brief summary of the process
we follow in estate and financial planning.
to understand what the client is most committed to accomplish, fix or
Analysis
avoid, and collects financial information
Quantifies
of client’s current situation, with special emphasis on uncovering gaps,
inefficiencies and opportunities. “What if” scenarios are modeled to determine the
short and long-term impact of planning options
the impact of recommended solutions, using flowcharts, graphs and state
Collaborates
of the art planning software
with the client’s multi-disciplinary team in order to provide a balanced
viewpoint and help the client make informed decisions.
Implements
observations and recommendations.
Provides
Monitors
the clients’ desired estate planning decisions.
the clients’ progress. Repeat/Update the process as circumstances warrant.
Financial-Estate & Wealth Planning Advisory Services
Stavis Wealth offers Holistic Financial and Wealth Planning to clients as an independent
service or as part of another service offering. Certain aspects of Holistic Financial and Wealth
Planning also include delivery of investment advice as defined by the Investment Advisers
Act of 1940, as amended (“Advisers Act”). Financial planning varies among wealth advisors,
clients, and the tools utilized by wealth advisors, as explained in more detail in Item 4 – Tools
for Financial Planning; Tailoring Financial Planning below. Not all clients will receive Financial
Planning services.
Holistic Financial and Wealth Planning generally focuses on planning related to
compensation and employment benefits, cash-flow, retirement, estate,
insurance,
investment, philanthropic, and tax, as may be appropriate. Depending on the level of service,
such Financial Planning is provided to the client either through meetings or digitally whereby
the wealth advisor and the client will work together to develop a written or verbal financial
plan and, with client cooperation, will endeavor to review risk profiles and objectives with
clients no less than annually and update the financial plan to account for changes in the
client’s situation. Stavis Wealth clients are not required to implement their financial plans
through products and services offered by Stavis Wealth or its affiliates (each in their
capacities as asset managers, broker-dealers, or insurance agencies, as applicable).
~ 6 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Clients deciding to implement any portion of their financial plans through Stavis Wealth, or
its affiliates generally do so by entering into separate agreements with Stavis Wealth or an
affiliate. Stavis Wealth does not have discretion over specified client assets as part of such
Financial Planning, but may have discretion from time to time as part of assets under
management-supervision advisory services. Corporate partner groups or affiliates often
have other relationships with Stavis Wealth as vendors, partners, or clients and they, their
employees, or participants may receive benefits or preferential fees or rates as a result of
such other relationships. See Item 5- Negotiated Fees.
In addition to the above services, Holistic Financial and Wealth Planning is also offered to
supplement advisory services made available to certain current or prospective clients
serviced by other RIAs, private wealth advisors, advisory personnel with other RIAs, and
family offices. When Stavis Wealth provides such Financial Planning only to current or
prospective clients they undertake no responsibility for, and provide no investment or
brokerage services related to, such clients’ investment accounts unless otherwise agreed to
in writing.
Stavis Wealth offers Financial-Wealth Planning through the various programs
described below:
Executive Wealth
Executive Wealth programs and services offered by Wealth Advisors are made available to
executives and high-net-worth clients directly or through an RIA or family office.
Comprehensive estate and financial plans intended to maximize compensation and benefit
programs, preserve and/or grow assets, manage income on a long-term basis, and integrate
tax, retirement, and estate plans and goals. In order to deliver comprehensive financial
planning services, Wealth Advisors analyze a number of factors, including, as applicable, the
client’s financial status, sources of income, assets, personal obligations and debts, objectives,
commitments, cash flow, family responsibilities and the effect of the existing income and
estate tax structure on the client’s sources of income and accumulation of wealth.
Family Office
Family Office services are designed to help individuals and families with significant wealth
manage their complex financial affairs. Family Office services can be provided to clients
directly or through an RIA and often includes work with several generations within one client
family and coordination with the individual’s or family’s other advisers (as directed). In many
cases, Family Office services offer high-net-worth individuals and families an alternative to
creating their own family office. Services include estate and trust planning and insurance
policy trust management, review and evaluation of subaccounts within life insurance,
portfolio monitoring, philanthropic and foundation planning, cash flow planning, tax
planning and insurance audits.
~ 7 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Tools for Financial Planning
As referenced above, Holistic Financial and Wealth Planning services are provided to clients
through a variety of means, including through in-person meetings, video conferences,
telephone calls, digital platforms, e-mail, reporting, or a combination thereof. Stavis Wealth
staff have available to them a variety of proprietary and third-party tools to aid in delivering
such planning services to clients.
Tailoring Financial Planning
Holistic Financial and Wealth Planning is typically designed to be personalized to the client,
including such client’s unique circumstances and needs, personal financial goals, net worth,
and/or complexity. Accordingly, the scope, duration, advisory personnel, deliverables, and
channels through which such planning is provided will vary among clients and services based
on a variety of factors. Such Financial Planning will also vary among clients as a result of
agreements with Stavis Wealth. Stavis Wealth will develop programs with certain corporate
partners and community-based organizations and associations. Financial and Estate
Planning programs will vary among organizations and groups participating. Certain
programs may be tailored to address certain corporate partner or community organization
needs or client events.
Financial and estate planning does not always address every aspect of a client’s financial life.
Omission of one or more financial planning topics from discussions with Stavis Wealth
advisors may be the result of differences and/or insufficient information provided by or on
behalf of a client. Such omissions do not indicate that the Financial Planning topic is not
relevant or applicable to the client’s financial situation, and clients are encouraged to consult
with their other advisors regarding such topics (e.g., tax and legal counsel). In some
situations, clients may also be eligible for reduced or waived fees due to certain
arrangements, such as legacy relationships with Stavis Wealth principals.
Reliance on Information in Financial/Wealth Planning
In providing financial/wealth planning, Stavis Wealth relies on the accuracy and
completeness of information provided by or on behalf of clients and does not assume
responsibility to independently verify the accuracy or completeness of such information.
Stavis Wealth does not assume responsibility to review, respond to, or incorporate into its
services any materials uploaded by or on behalf of the client to any electronic storage system
made available to clients. Clients must consult with and inform their designated Firm Staff
regarding any specific materials they would like to include in the services.
Certain Insurance Services &Trust Related Services
Individuals affiliated with the Firm provide insurance and design recommendations to
clients, as appropriate. We represent a wide range of life insurance, annuities, disability and
long-term care products.
~ 8 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Periodic monitoring of sub- accounts within variable life insurance and annuity
policies.
Annual trust policy management, including policies held within an irrevocable trust
Establish Trust related accounts to facilitate premium payment.
With the exception of ongoing asset monitoring and investment supervisory services,
assuming prompt provision of all information from the client, our financial planning services
are typically completed within 30-60 days of our engagement. Unless specifically requested
by the client and agreed in writing, our performance of these services is typically
accompanied by a formal written financial plan. On occasion, planning may be done on a
project basis which may take the form of an informal written summary or checklist of action
items and recommendations. Our final set of recommendations will be updated at least
annually or upon a client’s specific request and upon re-engagement of our firm for such
update(s) and the payment of a new advisory fee. Implementation of our recommendations
will be at the exclusive discretion of the client and may be completed by our firm for an
additional cost as agreed in writing. The client is under no obligation to use our firm to
implement any recommendations provided.
Tailored/Customized Advisory Services – Financial/Wealth & Estate Planning
Stavis Wealth also offers personalized financial/wealth and estate planning advisory
services, developed as a hybrid of any of the foregoing service offerings that are tailored to
the unique needs of the client’s situation and financial reality. During the first information
share meeting we will determine an appropriate mix of services based on the needs and
circumstances of the client. The advice we provide is driven by each client’s individual,
liquidity needs, generational
financial objectives, goals, personal risk assessment,
requirements, charitable desires, coordination of estate and trust planning documents with
their attorney, and accountant for tax considerations. According to these needs, we develop
and recommend an appropriate strategic plan.
-Examples of the products we might recommend include: life insurance, both fixed and
variable, (including private placement life insurance), annuities, variable annuities, long-
term care, and disability.
Ancillary Services
Upon request, we may review a client’s existing estate plan and make recommendations in
conjunction, with legal and accounting advisors, to provide guidance regarding the probate
process, coordination, control, and distribution of assets to several various entities. These
services offered in collaboration with legal counsel are provided to address certain issues
with estate taxes, post-mortem control of assets, and other key details of a client’s post-
mortem plan.
~ 9 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Trust Policy Management
Supervising/Oversight Advisor to Insurance Dedicated Funds within PPLI/PPVA
Notices regarding the timing of the gift to the Trust checking account
Notification to beneficiary regarding withdrawal rights (Crummey Powers);
continuous updating to the number of beneficiaries for utilizing the annual gift tax
exclusion(s)
Notification to Trustee regarding timing of premium payment
Handle administrative policy details such as resignation and appointment of
Trustees, change of address, etc.
Stavis Wealth may recommend that certain clients invest in private placement life insurance
(“PPLI”) and private placement variable annuities (“PPVA”). When recommending PPLI,
Stavis Wealth refers the client to appropriate insurance carriers in order to evaluate the
individual Client’s specific needs and, when appropriate, may recommend a PPLI policy.
After the PPLI policy is created, Stavis Wealth may be hired by the Client insured under the
PPLI policy as a supervising or oversight advisor to help supervise the assets of the policy.
The PPLI policy is a sponsored insurance dedicated fund ("IDF"). An IDF may also operate as
one or more private investment funds each being organized as a designated series (each a
"Fund") that is housed within an investment sub- account. Such IDFs are offered solely to
segregated asset accounts of insurance companies established for the owners of private
placement variable life insurance contracts or private placement variable annuity contracts.
Each Fund typically has the ability to invest globally in speculative investments utilizing a
variety of financial vehicles, including without limitation, funds, private investment vehicles,
hedge funds, stocks, bonds, pools, warrants, options, preferred and convert debt and equity,
real estate and any other investments which may be legally invested in by the Fund under
applicable law. The investment strategy applicable to investments in all Funds varies from
seeking capital preservation to capital appreciation. Investors in the Funds may not impose
Private Placement Insurance Programs & Investment Sub-Accounts
restrictions on the types of securities purchased.
Through insurance sponsors or insurance broker/agents, accredited investors may choose
to invest in PPLI or PPVA with the segregated investment account managed under the
insurance sponsor’s PPLI or PPVA investment sub-account program. PPLI is a variable
universal life insurance policy that provides a segregated investment account and a life
insurance benefit. PPVA enables investors to defer income tax on investment gains without
the traditional retail variable annuity features such as income guarantees or principal
protection, thus reducing the internal fees. The life insurance portion of these products is
Financial-Estate Planning and Ad v i so r y - Consulting Services
provided through the insurance sponsor company.
Stavis Wealth can provide financial planning and/or consulting services (including estate
planning, insurance planning, divorce planning, etc.) to the extent specifically requested by
a client. Financial and estate advisory planning or consulting fees are negotiable as described
in Item-5 Fees and Compensation.
~ 10 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Stavis Wealth provides certain clients with access to an online platform hosted by eMoney
Advisor Advisors, LLC (“eMoney”). The eMoney platform allows a client to view their
complete asset allocation, including those assets that Stavis Wealth does not manage. The
Firm does not provide investment management, monitoring, or implementation services for
any assets.
should not
The eMoney platform also provides access to other types of information and/or reports,
including financial planning concepts. The generated information and/or reports are
rely on it as the primary
provided for educational purposes only and the client
basis for insurance, investment, financial, and/or tax planning decisions. The generated
report is not a recommendation of any investment strategy or transaction, rather it is a tool
for Stavis Wealth and the client to collaboratively: (i) confirm the accuracy of the
information on the client’s risk tolerance and other personal and financial information, and
(ii) solicit the client’s input and feedback to refine the approach for the client’s financial
future. Stavis Wealth shall not be held responsible for any adverse results a client may
experience if the client engages in financial planning or other functions available on the
eMoney platform without Stavis Wealth assistance or oversight.
Multi-Generational Strategic Planning & Family Retreats
Stavis Wealth offers Family Retreats, typically a full day with the entire family in a non- office
setting (including multi-generational family members). Each family participant completes a
behavioral assessment that explores “how” they behave in various financial situations and
their “why”, which reflects their values.
Stavis Wealth combines financial information with the family dynamics utilizing the profile
of each family member. A meeting typically includes a review of family assets, estate and
income tax forecasts, along with ways to minimize estate tax. Ways to reduce estate tax,
ranging from design ideas such as Family Limited Partnerships, Trusts and charitable gifts,
whether in a Donor Advised Fund or a Private Foundation, provide ways to reduce the estate
tax, along with a discussion of the most economic ways to pay the estate tax and examine
ways to overcome misalignment among family members. Critically, we examine and help
develop ways to align family members regarding an optimum estate and philanthropic
strategy.
Investment Advisory & Investment Supervisory-Oversight/Allocation Services
Stavis Wealth currently provides discretionary and non-discretionary investment
management or asset management services on a fee basis. The Firm also provides certain
non-discretionary investment advisory services regarding family/estate and high-net-worth
wealth advisory clients and investment supervisory-oversight and related investment
allocation oversight services, including such services associated with the investment sub-
accounts that exist in variable insurance products.
Options for investing the cash value within life insurance contracts are expanding at a
significant rate, which creates:
~ 11 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Analysis of clients’ risk tolerance
At least a quarterly review of both asset allocation within the subaccounts
and the need for more active investment within the cash value of the policy to
properly assess client risk tolerance, offer significant optionality and
Active management within sub-accounts may require additional monitoring at least
quarterly
Provide an annual update and performance report on each insurance policy
The Firm provides discretionary and non-discretionary services to allocate and reallocate
insurance-related investment subaccounts as part of its advisor supervisory and oversight
services for such clients. In certain instances, advisory clients may grant us, respectively,
discretion to: (a) select variable subaccounts for clients’ existing variable annuities and (b)
allocate and reallocate any premiums among the variable subaccounts available from the
specific annuity sponsor. In performing variable subaccount allocation services, the Firm
will only consider the variable subaccount investment options available within the specific
insurance or annuity purchased by the client. The Firm does not determine which variable
subaccount options are made available by insurance companies or product sponsors, and
variable subaccounts are not custodied at the Firm. If a client has not granted discretion
regarding variable subaccounts as described above, the Firm will provide investment
allocation and supervisory-oversight support services in coordination with the advisory
client’s approval, along with providing certain clients with educational support regarding
asset allocation principles or examples of model portfolios.
Selection of Other Advisers
From time to time, the Firm may recommend that you use the services of a third-party money
manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering
information about your financial situation and objectives, we may recommend that you
engage a specific TPMM or investment program. Factors that we take into consideration
when making our recommendation(s) include, but are not limited to, the following: the
TPMM's performance, methods of analysis, fees, and client financial needs, investment goals,
risk tolerance, and investment objectives. The TPMM(s) will actively manage your portfolio
and will typically assume discretionary investment authority over your account. We will
monitor the TPMMs' performance to ensure its management and investment style remains
aligned with client investment goals and objectives.
Investment Advisory Services & Types of Investments
The Firm offers advice on equity securities, mutual funds, ETFs, and certain index options,
as well as other various types of investments based on your stated goals and objectives. We
may also provide advice on any type of investment held in your portfolio at the inception of
our advisory relationship. Since our investment strategies and advice are based on each
client's specific financial situation, the investment advice we provide to you may be different
or conflicting with the advice we give to other clients regarding the same security or
investment.
~ 12 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Private/Alternative Funds & Third-Party Investment Platforms
rd
rd
Stavis Wealth also offers alternative investment strategies through third-party managers.
These investments carry risk and are designed for investors that meet the qualified
purchaser, qualified client, or accredited investor definitions.
Stavis Wealth has a
party unaffiliated private equity and venture capital
relationship with GLASfunds, a 3
party-managed private fund
investment platform through which we may offer certain 3
investment vehicles and that we may recommend to advisory clients.
From time to time, Stavis Wealth recommends private equity funds offered through the
GLASfunds (“GLAS”) platform. GLAS provides discretionary investment advisory services to
GLASfunds, LP and GLASfunds, SPC (each, a “Fund”, and together, the “Funds”). Each investor
in a Fund, with assistance from GLAS, will allocate its investment in each Fund to one or more
investment strategies (each an “Investment Strategy”). Each Investment Strategy constitutes
a separate series of interests or shares of the relevant Fund. Private funds are typically only
available to high-net-worth individuals who qualify as accredited investors or qualified
purchasers and who meet minimum investment thresholds. We recommend GLAS to
investors who meet the relevant investment qualifications and for whom a private fund is
appropriate based on investing goals and objectives. At the time of investment, you will
receive fund-related offering documents, questionnaires, and disclosures outlining the risks,
costs, and other pertinent information. Additionally, to the extent Stavis Wealth receives
non-cash compensation from GLAS, this would create a conflict of interest (see also Item 14
– Client Referrals and Other Compensation for additional related disclosures). Regardless of
how the client engages our firm, Stavis Wealth focuses on delivering investment advisory
services tailored to their unique circumstances, goals, and objectives. We manage the client’s
account based on their financial situation and investment objectives and in accordance with
any reasonable restrictions imposed by them in terms of the advisory management of the
client’s account. (For additional related information, please also see GLAS/GLASfunds ADV-
Part 2 Brochure.)
Also in maintaining and engaging in business relationships or arrangements with certain
third-party vendors, including GLAS-GLASfunds, Stavis Wealth or its staff may receive non-
cash compensation from such vendors from time to time, which can include reimbursement
or payment for travel, lodging, meals, entertainment, or participation in conferences and
other events. To the extent this may occur, this creates a conflict of interest as these benefits
create an incentive for Stavis Wealth or its personnel to promote the vendor providing the
incentive or recommend investments on the GLASfunds platform over other platform
options in order to continue receiving such non-cash compensation benefits. To mitigate
this conflict, we make all investment recommendations based on our independent analysis
consistent with each client’s best interests and related financial and investment objectives
and risk tolerance parameters.
In addition, Stavis Wealth has formed a strategic alliance or partnership arrangement with
one or more third-party private equity and venture capital fund managers as described
~ 13 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
below. Curate Capital LLC and Stavis Wealth have entered into a strategic relationship
whereby Stavis Wealth is a cornerstone fund investor and strategic partner. Stavis Wealth
clients are able to access Curate Capital Private Funds on terms which are generally more
favorable than those that are generally available to private alternative fund investors. Stavis
Wealth also has received an economic-financial interest in the carried interest fees that may
be earned by Curate with respect to the funds where Stavis Wealth is a strategic partner,
which gives rise to conflicts of interest as Stavis Wealth has an incentive to recommend
clients invest in such Curate Funds.
Carnrite Ventures LLC and Stavis Wealth have also entered into a strategic relationship
whereby Stavis Wealth clients will have access to Carnrite Ventures funds. Stavis Wealth
also has received an economic-financial interest in the carried interest fees that may be
earned by Carnrite Ventures with respect to the funds where Stavis Wealth is a strategic
partner, which gives rise to conflicts of interest as Stavis Wealth has an incentive to
recommend clients invest in such Carnrite Ventures Funds.
focuses on delivering
Regardless of how the client engages our firm or to the extent a conflict of interest exists or
arises, Stavis Wealth
investment advisory services and
recommendations tailored to each client’s unique circumstances, goals, and objectives. We
manage the client’s account based on their financial situation and investment objectives and
in accordance with any reasonable restrictions imposed by them in terms of the advisory
management of the client’s account. And to mitigate any conflicts, the Firm makes all
investment recommendations based on our independent analysis consistent with each
client’s best interests and related financial and investment objectives and risk tolerance
Wrap-Fee Investment Programs
parameters.
Stavis Wealth is not a portfolio manager of, nor a sponsor of, wrap-fee investment programs.
Certain of our clients may participate in wrap-fee programs through the use of certain third-
party money managers. (See disclosure above regarding Selection of Other Advisers).
Assets Under Management/Supervision
As of February 28, 2026, the Firm has total advisory assets under management and
supervision (AUM) of approximately $148.1 million, consisting of approximately $83.2
million of AUM on a discretionary basis and approximately $64.9 million of AUM on a non-
discretionary basis.
Item 5 – Fees and Compensation
The specific manner in which fees are charged by Stavis Wealth is established in an advisory
client’s written advisory services agreement with the Firm. Our advisory agreement does
not include any assets under management or AUM fees on the subaccounts within a life
insurance policy for which the Firm is providing supervisory services. These services are
~ 14 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
provided for clients who either have, or plan to purchase, life insurance policies through
Stavis Wealth.
We receive the following advisory and financial/wealth planning fees in connection with our
services to clients. All client fee arrangements are set forth in written advisory agreement.
Fees are generally calculated on an annual project basis, payable at the time of engagement,
and are due upon receipt of invoice. Either party may terminate the financial/wealth
planning and/or estate planning agreement within 30 days.
Financial/Estate & Wealth Transfer Planning Advisory Fees
Our Firm charges advisory fixed-fees for financial/wealth, estate, and philanthropic planning
services, on a case by case basis. Total fees charged are generally based on the scope and
complexity of the engagement and the time, research, and other resources that will be
devoted to complete the services.
FINANCIAL/ESTATE PLANNING & WEALTH ADVISORY FEE SCHEDULE
NET WORTH
($ in Millions)
FEE
STRUCTURE
$0 - $25
Next $25
Next $50
Next $100
Over $200
$25,000
(Maximum)
$50,000
(Maximum)
$100,000
(Maximum)
$150,000
(Maximum)
$250,000
(Minimum)
Fixed-Fees generally range from $2,500 to $100,000 depending on the mix of assets, scope
and complexity of the engagement. The above fees exclude charges from other professionals
during the course of the engagement such as Attorneys, CPAs, Business Valuation Experts,
Estate-Financial/Wealth Planning Project Services
and Trustee fees.
A flat or fixed project fee may be paid to our Firm for standalone estate-financial
planning/consulting services as agreed by the parties in writing based on the scope and
complexity of such services, which is evaluated case by case and determined in the proposal
meeting. The financial planning fee and scope of services is generally reviewed annually.
~ 15 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Also Stavis Wealth reserves the right to extend estate-financial planning and related wealth
advisory services to legacy clients per a different fee schedule, including up to a waiver of the
fee.Assets Under Management Fee Schedule
ASSETS UNDER MANAGEMENT FEE SCHEDULE
Under 2MM
100 BPS
2MM-4MM
75 BPS
4MM-6MM
65 BPS
6MM-10MM
55 BPS
10MM and Over
Negotiable flat fee
from $10MM invested
Where mutually agreed, the Firm will offset planning-consulting fees with the asset under
management fees in providing both types of advisory services. Where the Firm is not engaged
for financial-estate planning services, the Firm will provide asset management advisory
services only.
Also Stavis Wealth reserves the right to extend assets under management services and
related advisory services to legacy clients per a different fee schedule, including up to a
Trust Policy Management Services
waiver of the fee.
The Firm will charge a $3,500-$5,500 annual fee, payable at time of engagement, in order to
maintain the integrity of the estate plan and specific trusts, as they relate to the estate and
estate tax protection plan. The processes and multi-step services are listed above, and such
annual fee range is based on complexity and scope of work.
In any year where a financial and estate planning fee is paid by the client, the cost of trust
policy management servicing and the related trust policy management fee will be included
in the annual financial planning retainer, rather than charged as a separate fee.
Stavis Wealth reserves the right to extend Trust Policy Management Services to legacy clients
per a different fee schedule, including up to a waiver of the fee.
Life Insurance Policy Audits
The Firm’s fee for a life insurance policy audit is $2,500. This includes an assessment of the
current valuation, planned premium payment, and in-force ledger examination to determine
~ 16 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
policy performance as it relates to client objectives. This fee may be waived for advisory
clients who engage the Firm under a Financial-Estate Planning Contract
Family Retreats
Full-day family meetings generally have an associated $10,000 fee, excluding airfare and
hotel expenses. Stavis Wealth retains the right to modify this fee based on complexity and
content, agreed upon by client.
Brokerage Products & Related Commissions
Firm’s Managing Principal earns additional compensation if a client purchases investment
products through Benefit Funding Services (BFS) where the Managing Principal is also
affiliated as a registered representative. This compensation is in the form of fee
commissions. Because of receipt of this economic benefit, the Firm has a potential conflict of
interest if it recommends to its advisory clients that they purchase investment products
through BFS. This gives us an incentive to recommend investment products based on the
compensation that the Managing Principal will receive. Nonetheless, we believe that we have
addressed this conflict of interest because clients are under no obligation to purchase
investment products through BFS or the Firm’s staff. Further, advisory clients have the
option to purchase investment products that we recommend through other brokers or
agents not affiliated with the Firm. Any commission/fee that individual Firm staff receives
from the sale of investment products is in addition to the advisory fee the Firm charges,
which advisory fee will not be reduced to offset the commission/fee that is received.
Private Investment Funds/Vehicles Management Fee Compensation/Sharing
Stavis Wealth may recommend affiliated or unaffiliated private funds, and the Firm may from
time to time receive revenue fee sharing from or related to investments by non-Stavis Wealth
clients in certain private investment vehicles that Stavis Wealth sponsors up to a one percent
(1.0%) management fee. When investing in a private fund offered by Stavis Wealth, the client
will not pay a fund level management fee. Clients should review the offering documents and
applicable ADV’s of the fund and its fund investment manager prior to investing to
understand all the fees and expenses associated with the investment. There is a conflict of
interest when the Firm recommends an advisory client invest in certain private funds and/or
in a strategic or alliance partner fund because Stavis Wealth earns additional fee and/or non-
fee compensation.
Regardless how the client engages our firm, Stavis Wealth focuses on providing investment
advisory services that are tailored to their unique circumstances, goals, and objectives. We
manage the client’s account based on the client’s financial situation, investment objectives,
and risk parameters and in accordance with any reasonable restrictions imposed by the
client in terms of the advisory management of the client’s account.
In addition, see the
disclosure above under “Private/Alternative Funds & Third-Party Investment Platforms”
with respect to certain additional incentive fee allocations that Stavis Wealth may earn from
its strategic partnerships.
~ 17 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Insurance Products & Related Commissions
Commissions are also received for insurance policies placed, which are dependent on
product type, rating, premium, and any specific client objectives. The Firm’s Managing
Principal also earns additional compensation from insurance companies in the form of fee
compensation for all insurance in force and will receive compensation for the sale of
insurance products from advisory and non-advisory clients. Please see further information
in Item 10 below relating to the additional registrations and affiliations disclosed in this Item
5, including information pertaining to conflicts of interest arising out of these other
registrations and affiliations of certain Firm staff.
Sharing of Financial and Estate Planning Fees
In certain instances from time to time, Stavis Wealth may pay certain fees to private wealth
managers that obtain financial data and client objectives in coordination with the governing
estate plan. Such fees will be disclosed to the client in a separate form, and the amount will
vary based upon the time and effort expended by the private wealth manager.
Additional Information
As indicated above, Stavis Wealth may price its advisory services based upon various
objective and subjective factors. As a result, Stavis Wealth’s clients could pay diverse fees
based upon the complexity of the engagement, and the level and scope of the overall financial
advisory/estate planning services to be rendered. As a result of these factors, the services to
be provided by Stavis Wealth to any particular client could be available from other advisers
Related/Associated Person Employee Accounts
at lower fees.
: As an employee and/or other related
persons or affiliates, such persons or entities may be allowed to invest in the Firm’s
strategies as a client at no cost or a reduced cost. Firm managed employee or other related
party accounts are managed in a manner consistent with Firm’s fiduciary duty to all Clients.
Item 6 – Performance-Based Fees and Side-By-Side Management
Stavis Wealth does not currently charge any performance-based fees (fees based on a share
of capital gains on or capital appreciation of the assets of a client). Any related performance-
based fee compensation will be applied and assessed in accordance with the SEC
Performance Fee Rule (Rule 205-3).
However, Stavis Wealth will receive allocations of certain incentive fees earned by certain of
its private fund strategic partners as more fully described under “Private/Alternative Funds
& Third-Party Investment Platforms” above.
~ 18 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Item 7 – Types of Clients
Stavis Wealth provides financial, wealth and estate planning advisory services and related
wealth transfer consulting services to individual and high-net-worth investors, family
offices, trusts, charitable organizations and foundations, and small business companies and
other corporate clients.
Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss
Investment Strategies & Methods of Analysis
Stavis Wealth’s methods of analysis and investment strategies are focused on investment
advisor supervisory services. Additionally, regarding the cash value within life insurance
contracts (sub-accounts) and related sub-account investment or allocation options.
Variable Insurance & Variable Annuities (“VA”): Variable insurance and VAs are types of
insurance or annuity contracts that allow for the accumulation of capital on a tax-deferred
basis. As opposed to a fixed annuity that offers a guaranteed interest rate and a minimum
payment at annuitization, VAs offer investors the opportunity to generate higher rates of
return by investing in equity and bond sub-accounts. If a VA is annuitized for income, the
income payments can vary based on the performance of the subaccounts. Risks associated
with VAs may include:
• Taxes and federal penalties for early withdrawal;
• Enduring surrender charges for early withdrawal;
• Earnings taxed at ordinary income tax rates;
• Mortality expense to compensate the insurance company for insurance risks;
• Higher fees and expenses imposed for the subaccounts;
• Other features with additional fees and charges; and
• Investment losses.
Private Placement Life Insurance (PPLI) & Private Placement Variable Annuities (PPVA):
PPLI and PPVA products are long-term investments similar to variable life insurance
products, except that purchasers are able to invest policy premiums into various alternative
investments. In addition to the risks associated with VAs set forth above, PPLI and PPVA
products also present the risk that, as unregistered securities products, they are not subject
to the same regulatory requirements and oversight as their registered counterparts. PPLI
and PPVA products are not suitable for all investors. An investment in PPLI or PPVA products
is subject to fluctuating values of the underlying investment options and it entails risk,
including the possible loss of principal. You should consider the investment objectives, risks,
charges, and expenses of any PPLI or PPVA product carefully before investing. Additional
risk disclosures and other important information about PPLI and PPVA products are
contained in their offering memorandums, which clients are urged to carefully review with
their tax and legal advisors before investing.
~ 19 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
The Firm may manage various variable insurance or annuity sub-accounts that are
maintained directly with the insurance sponsor (“Sponsor”). Although such variable
products and their respective sub-accounts may be represented on various reports or
statements, the variable products are held directly with the Sponsor. Sub-account asset
allocations may be limited by the Sponsor’s product fund options, and certain asset
allocations may also be restricted by the Sponsor. In such cases when a reallocation is
required, the Firm will direct and execute such reallocation transactions directly through the
Sponsor. Clients must complete necessary documentation under the applicable variable
insurance or annuity contract to grant the Firm access to information necessary to perform
these services. Where client purchases a variable insurance or annuity contract, client will
receive a prospectus or private placement memorandum (PPM) and should rely solely on
the disclosure contained in such prospectus or PPM with respect to the terms and conditions
of the variable insurance or annuity investment product. Client should also be aware that
certain riders purchased with a variable insurance or annuity contract may limit the
investment options and the ability to manage the sub-accounts.
General Overview of Investments
Stavis Wealth typically enters into discretionary agreements with clients granting Stavis
Wealth the authority to engage and replace, if necessary, external investment managers and
select individual securities. Firm Staff review clients’ existing portfolios and deliver
recommendations based on a client’s individual risk tolerance, time horizon, and overall
objectives. Stavis Wealth is responsible for determining a client’s overall target asset
allocation, selecting investments, and implementing and maintaining the portfolio. Stavis
Wealth may construct portfolios using a mix of cash and cash equivalents, exchange traded
funds or notes, closed-end funds, mutual funds, individual equities, individual bonds, and
private pooled investment vehicles or by allocating some or all of a given portfolio to a third-
party separately managed account. In certain situations, Stavis Wealth can invest in
strategies that involve the use of other alternative assets such as financial derivatives or
structured notes by engaging third-party managers or directly transacting in those assets.
The Firm offers a platform of both equity, fixed income, and alternative investing strategies,
through customized asset allocation, and uses a goals-based customized approach to
portfolio management. Risk is considered at the security, strategy, manager, account, and/or
portfolio level depending on a client’s objectives and recommended portfolio.
Equity Investments/Strategies
The equity strategies vary by mandate, all with a focus on capital appreciation as a primary
objective. Philosophies include dividend-based strategies, growth and GARP (growth at a
reasonable price) strategies, value-based strategies, ESG/socially conscious strategies, and
ETFs/ETNs/direct indexing strategies. In strategies other than direct indexing, we will select
individual securities based upon fundamental analysis performed by our investment
professionals. Firm Staff rely primarily on publicly available information in our analysis,
supplemented by third-party research and analytical tools.
~ 20 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Fixed Income Investments/ Strategies
For our managed account fixed income strategies, our primary objective is capital
preservation. Secondary objectives include providing steady income and the potential for
capital appreciation. Our fixed income strategies are formed through a combined top-down
and bottom-up perspective. From the top-down, we develop our economic outlook and
interest rate strategy using macroeconomic and market data and trends. We will alter our
duration, sector, and yield curve exposure targets based on this outlook.
Risk of Loss
Stavis Wealth does not guarantee the future performance of sub-accounts managed or any
specific level of performance, the success of any investment decision or strategy. The client
understands that investment decisions made for the client’s sub account(s) are subject to
various market, economic, political, and business risks. These investments are only
recommended to sophisticated clients who meet required net worth and income
qualifications. Clients are reminded that investing in any security entails risk of loss they
should be willing to bear.
Alternative Investments – Private Funds & Pooled Investment Vehicles
Stavis Wealth does not guarantee the future performance of private funds and pooled
investment vehicles. These investments carry risk and are designed for investors that meet
qualified purchaser, qualified client, or accredited investor requirements as defined by SEC.
Private investments are not liquid and cannot be readily sold or converted to cash or other
securities. Clients should consider their liquidity needs before choosing to invest. Clients
should review offering documents carefully before investing. From time to time, the Firm
may recommend that qualified clients consider an investment in private investment funds,
where appropriate. Private investment funds involve various risk factors, including, but not
limited to, potential for complete loss of principal, liquidity constraints, and lack of
transparency. A complete discussion of risks is set forth in each fund’s offering documents
which will be provided to each client for review and consideration.
Item 9 – Disciplinary Information
Stavis Wealth has no disciplinary actions in its history and has no information applicable to
this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Stavis Wealth is not and does not have a related company that is a (1) broker/dealer,
municipal securities dealer, government securities dealer or broker, (2) investment
company or other pooled investment vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private investment company or “hedge fund,”
and offshore fund), (3) futures commission merchant, commodity pool operator, or
~ 21 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
commodity trading advisor, (4) banking or thrift institution, (5) accountant or accounting
firm, (6) lawyer or law firm, (7) insurance company or agency, (8) pension consultant, (9)
real estate broker or dealer, or (10) sponsor or syndicator of limited partnerships.
Other Financial/Investment Industry Activities
Any requested brokerage services or sales of investment brokerage products will be
provided under a commission-based brokerage relationship with securities offered through
Benefit Funding Services (BFS), a registered broker-dealer and Member FINRA/SIPC.
Benefit Funding Services and Stavis Wealth are not affiliated companies. Under such an
arrangement, you may choose to implement securities transactions through Firm Managing
Principal Deborah Stavis (or another Firm investment advisor representative or “IAR”) in
their respective capacity as a registered representative of BFS, a financial services company
registered with the Financial Industry Regulatory Authority (“FINRA”) as a broker-dealer
engaged in the offer and sale of securities and investment products. Brokerage commissions
will be charged by BFS to process these securities transactions and thereafter, a portion of
these commissions will be paid by BFS to our Firm’s BFS affiliated staff. Prior to effecting
any securities transactions if you choose to use BFS at your option, you will be required to
enter into a new account agreement with BFS. The brokerage commissions charged by BFS
may be higher or lower than those charged by other brokerage firms or broker-dealers.
The receipt of commissions creates an incentive to recommend those products for which a
commission will be received. Consequently, the objectivity of the advice rendered to clients
could be biased. This potential conflict of interest is controlled by generally informing clients
of both the advantages and disadvantages of establishing commission- based accounts with
BFS versus a fee-based advisory account through Stavis Wealth. Please be aware that you
are under no obligation to purchase products or services recommended by us or members
of our Firm in connection with providing you with any advisory service that we offer.
Also, certain investment product sponsors may provide Stavis Wealth with other economic
benefits as a result of the recommendation or sale of the product sponsors’ investments. The
economic benefits received by Stavis Wealth from product sponsors can include but are not
limited to, financial assistance or the sponsorship of conferences and educational sessions,
marketing support, incentive awards, payment of travel expenses, and tools to assist Stavis
Wealth in providing various services to clients. Although Stavis Wealth endeavors at all times
to put the interest of their clients ahead of those of Stavis Wealth’s officers or representatives
(“affiliated persons”), these arrangements present a conflict of interest which could affect
judgment when recommending investment products.
From time to time, Stavis Wealth strategic or alliance partners may refer prospective clients
or private fund investors to us. In turn, Stavis Wealth may also refer clients to certain of our
strategic or alliance partners. In such cases, Stavis Wealth will pay or receive direct or
indirect compensation regarding the referral. Referrals of prospective clients may present a
conflict of interest to recommend strategic or alliance partners over others. Stavis Wealth
seeks to mitigate this conflict by limiting recommendations to those Stavis Wealth believes
~ 22 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
to be in the best interest of our advisory clients and required disclosures are provided to
referred prospects. Stavis Wealth considers a variety of factors when considering referral
recommendations, including our advisory clients’ financial goals, objectives and portfolio,
and the scope of our engagement. In all cases, it is our goal to provide our advisory clients
with the services we believe best suit their needs.
Other Industry Affiliations & Arrangements – Insurance
Certain of Stavis Wealth’s advisory affiliates, including Firm Managing Principal Deborah
Stavis, in their individual capacities, are also licensed insurance agents with various
insurance companies, and in such capacity, may recommend, on a commission basis, the
purchase of certain insurance products. Stavis Wealth does permit such affiliated persons,
in their individual capacities as licensed insurance agents, to sell insurance products to its
investment advisory clients and may receive compensation for the sale of such insurance
products from advisory and non-advisory clients. A conflict of interest may exist to the
extent that Stavis Wealth recommends the purchase of insurance products where Stavis
Wealth’s affiliated persons receive insurance commissions or other additional compensation.
Variable life insurance or variable annuity business is also placed through BFS, although the
actual contracts are issued and serviced by insurance companies. Life insurance business is
generally placed through insurance brokerage houses. A conflict of interest exists when
Stavis Wealth recommends a commission-based product. The advisory client is informed of
this inherent conflict and that the client can purchase the recommended insurance product
from another agent.
We also serve as a member of First Financial Resources (FFR Group), an invitational member
association. The FFR Group is engaged to assist Stavis Wealth to select highly rated life
insurance carriers that can provide clients with “Best in Class” support. Its insurance carriers
generally include, but are not limited to, American General, Delaware Life, Genworth, John
Hancock, Lincoln, MetLife, Nationwide, One America, Pacific Life, Penn Mutual, Principal,
Insurance company licensing appointments are
Prudential, Securian and State Life.
generally set up both by carrier and the state in which business is conducted, and such
insurance carriers typically identify both the writing agent and the servicing agent for each
insurance product policy.
Where insurance carriers are selected by the client, the Firm Managing Principal will receive
compensation for the sale of insurance products to advisory and non-advisory clients. For
clients who purchase products causing commissions to be generated from such purchases,
these commissions are paid to the Firm Managing Principal in her separate capacity as an
insurance agent. This activity represents a conflict of interest and may give her an incentive
to recommend the purchase of insurance products for a client account based on that
person’s ability to receive compensation from such a purchase. However, the Firm believes
that it has addressed this conflict by (a) requiring that any such transaction will be on
commercially reasonable terms that are generally consistent with industry standards, and
(b) neither requiring nor expecting that a client will purchase any such insurance product
from or through Firm Managing Principal. In addition, the Firm Managing Principal must
~ 23 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
maintain compliance with applicable rules and regulations that govern the sale of such
products.
Other Fee-Sharing Arrangements – Financial/Estate Planning Fees
In certain instances, Stavis Wealth may pay certain fees to private wealth managers/advisors
that work in collaboration with the Firm and its staff and that obtain financial data and client
objectives in coordination with the governing estate plan and our related Firm services. Such
fees will be disclosed to the client in a separate form, and the amount will vary based upon
Insurance Commissions – Fee Sharing
the time and effort expended by the private wealth manager.
In certain cases, commissions may be shared with other licensed advisors. Any and all
sharing arrangements are disclosed to the client in advance of any transaction.
Item 11 – Code of Ethics
Stavis Wealth’s Code of Ethics covers all supervised persons of the firm and describes its
standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes
provisions relating to the confidentiality of client information, a prohibition on insider
trading, and personal securities trading and reporting procedures, among other things. All
supervised persons at Stavis Wealth must acknowledge the terms of the Code of Ethics
annually and also follow the Firm’s Code of Ethics.
The Code of Ethics is designed to assure that the personal securities transactions, activities
and interests of the employees of Stavis Wealth will not interfere with (i) making decisions
in the best interest of advisory clients and (ii) implementing such decisions while, at the
same time, allowing employees to invest for their own accounts. Employee trading is
monitored on a quarterly basis under the Code of Ethics to reasonably prevent conflicts of
interest between Stavis Wealth and its clients. To supervise compliance with its Code of
Ethics, the Firm requires that anyone associated with this advisory practice with access to
advisory recommendations provide annual securities holding reports and quarterly
transaction reports to the firm's Compliance department. The Firm also requires such access
persons to receive approval from the Compliance department prior to investing in any initial
public offerings or private placements. Stavis Wealth’s clients or prospective clients may
request a copy of the Firm's Code of Ethics by contacting Deborah Stavis, Firm Managing
Principal/CEO, at dstavis@staviswealth.com.
It is Stavis Wealth’s policy that the firm will not affect any principal or agency cross-
securities transactions for client accounts. Stavis Wealth will also not cross trades between
client accounts. Principal transactions are generally defined as transactions where an
adviser, acting as principal for its own account or the account of an affiliated broker-dealer,
buys from or sells any security to any advisory client. An agency cross transaction is defined
as a transaction where a person acts as an investment adviser in relation to a transaction in
which the investment adviser, or any person controlled by or under common control with
~ 24 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
the investment adviser, acts as broker for both the advisory client and for another person on
the other side of the transaction.
Item 12 – Brokerage/Trading Practices
Where the client grants discretion for or requests Stavis Wealth to recommend a broker-
dealer/custodian for execution and/or custodial services (exclusive of those clients that may
direct Stavis Wealth to use a specific broker-dealer/custodian), Stavis Wealth generally
recommends that investment management or advisory accounts be maintained at an
independent and unaffiliated broker-dealer/custodian. Factors that Stavis Wealth considers
in recommending such broker-dealer/custodians include historical relationship with the
Firm, financial strength, reputation, execution capabilities, pricing, research, and service.
Although the commissions and/or transaction fees paid by Stavis Wealth's clients will
comply with the firm's duty to obtain best execution, a client may pay a commission that is
higher than another qualified broker-dealer might charge to effect the same transaction
where Stavis Wealth determines, in good faith, that the commission/transaction fee is
reasonable in relation to the value of the brokerage and research services received. In
seeking best execution, the determinative factor is not the lowest possible cost, but whether
the transaction represents the best qualitative execution, taking into consideration the full
range of a broker-dealer’s services, including the value of research provided, execution
capability, commission rates, and responsiveness. Accordingly, although Stavis Wealth will
seek competitive rates, it may not necessarily obtain the lowest possible commission rates
for client account transactions. The brokerage commissions or transaction fees charged by
the designated unaffiliated broker-dealer/custodian are exclusive of, and in addition to,
Stavis Wealth's investment management or advisory fees. Stavis Wealth’s best execution
responsibility is qualified if securities that it purchases for client accounts are mutual funds
Custodian & Broker(s) Usage
that trade at net asset value as determined at the daily market close.
Stavis Wealth does not maintain custody of client assets on which we advise and that we may
manage from time to time. Your assets will be maintained in an account at a “qualified
custodian,” generally a broker-dealer or bank. We generally recommend that our clients use
Fidelity (Broker), a registered broker-dealer, as the qualified custodian, and we are
independently owned and operated and are not affiliated with Broker. Broker will hold your
assets in a brokerage account and buy and sell securities when we instruct them to. While
we recommend that you use Broker as custodian/ broker, you will decide whether to do so
and will open your account with Broker by entering into an account agreement directly with
them. Conflicts of interest associated with this arrangement are described below as well as
in Item 14 as applicable (advisory client referrals and other compensation). You should
consider these conflicts of interest when selecting your custodian. The Firm does not open
the account for you, although we may assist you in doing so with Broker. Even though your
account is maintained at Broker, and we anticipate that most trades will be executed through
Broker, we can still use other brokers to execute trades for your account as described below
(see “Brokerage and Custody Costs” and “Directed Brokerage”).
~ 25 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Selecting & Using Brokers/Custodians
We use Broker, a custodian/broker, to hold your assets and execute transactions. When
considering whether the terms that Broker provides are, overall, most advantageous to you
when compared with other available providers and their services, we take into account a
range of factors, including:
Brokerage and Custody Costs
• Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-
traded funds (ETFs), etc.)
• Availability of investment research and tools that assist us in making investment
decisions
• Quality of services and price competitiveness of such services (commission rates,
margin interest rates, other fees, etc.) and willingness to negotiate prices
• Reputation, financial strength, security and stability
• Prior and ongoing service to us and our clients
• Availability of other products and services that benefit us, as discussed below (see
“Products/Services Available from Broker”).
For our clients’ accounts that Broker maintains, Broker generally does not charge you
separately for custody services but is compensated by charging you commissions or other
fees on trades that it executes or that settle into your Broker account. Certain trades (for
example, mutual funds and ETFs) do not incur Broker commissions or transaction fees.
Broker is also compensated by earning interest on the un-invested cash in your account in
Broker’s Cash Features Program. Broker’s commission rates applicable to our clients’
accounts were negotiated based on the condition that our clients collectively maintain a
certain total level of aggregate assets in accounts at Broker. This commitment benefits clients
because the overall commission rates paid are lower than they would be otherwise. In
addition to commissions, Broker charges you a flat dollar amount as a “prime-broker” or
“trade-away” fee for each trade that we have executed by a different broker-dealer but where
the securities bought or the funds from the securities sold are deposited (settled) into your
Broker account. These fees are in addition to the commissions or other compensation you
pay the separate executing broker-dealer. Because of this, in order to minimize your trading
costs, we have Broker execute most trades for your account. We are not required to select
the broker-dealer that charges the lowest transaction cost, even if that broker-dealer
provides execution quality comparable to other broker-dealers. Although we are not
required to execute all trades through Broker, we have determined that having Broker
execute most trades is consistent with our duty to seek “best execution” of your trades. Best
execution means seeking the most favorable terms for a transaction or trade based on all
relevant factors under the surrounding circumstances, including those listed above (see
“Selecting & Using Brokers/Custodians”). By using another broker-dealer, you may pay
lower transaction costs in certain instances.
~ 26 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Products/Services Available to the Firm from Broker
Broker Fidelity operates a platform business serving independent investment advisory firms
like us. They provide our clients and us with access to their institutional brokerage services
(trading, custody, reporting and related services), many of which are not typically available
to Broker retail customers directly. However, certain retail investors may be able to get
institutional brokerage services from Broker without going through us. Broker also makes
available various support services. Some of those services help us manage or administer our
clients’ accounts, while others help us manage and grow our business. Broker’s support
services are generally available on an unsolicited basis (we do not have to request them) and
at no charge to us.
Services that Generally Benefit Clients
A more detailed description of Broker’s support services follows.
. Broker’s institutional brokerage services include
access to a broad range of investment products, execution of securities transactions, and
custody of client assets. The investment products available through Broker include some to
which we might not otherwise have access or that would require a significantly higher
minimum initial investment by our clients. Broker’s services described in this paragraph
Services that Do Not Directly Benefit Clients
generally benefit you and your account.
. Broker also makes available to us other products
and services that benefit us but do not directly benefit you or your account. These products
and services assist us in managing and administering our clients’ accounts and operating our
firm. They include investment research, both Broker’s own and that of third parties. We use
this research to service all or a substantial number of our clients’ accounts, including
accounts not maintained at Broker. In addition to investment research, Broker also makes
available software and other technology that: i) provide access to client account data (such
as duplicate trade confirmations and account statements); ii) facilitate trade execution and
allocate aggregated trade orders for multiple client accounts; iii) provide pricing and other
market data; iv) facilitate payment of our fees from our clients’ accounts; and v) assist with
Services that Generally Benefit Only the Firm
back-office functions, recordkeeping, and client reporting.
. Broker also offers other services intended to
help us manage and further develop our business enterprise. These services include: i)
Educational conferences and events; ii) Consulting on technology and business needs; iii)
Consulting on legal and compliance related needs; iv) Publications and conferences on
practice management and business succession; v) Access to employee benefits providers,
human capital consultants, and insurance providers; and vi) Marketing consulting and
support.
Broker provides some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Broker also discounts or waives its fees for some of
these services or pays all or a part of a third party’s fees. If you did not maintain your account
with Broker, we would be required to pay for those services from our own resources.
Our Interest in Broker’s Support Services
The availability of these support services from Broker benefits us because we do not have to
~ 27 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
produce or purchase them and do not have to pay for Broker’s services. The fact that we
receive these benefits from Broker is an incentive for us to recommend the use of Broker
rather than making such a decision based exclusively on your interest in receiving the lowest
price or cost in custody services and in the execution of your transactions. While this is a
conflict of interest, we believe, however, that taken in the aggregate our selection of Broker
as custodian and broker is in the best interests of our clients and is consistent with seeking
best execution under the circumstances. Our selection is primarily supported by the scope,
quality, and price of Broker’s services (see “Selecting & Using Brokers/Custodians” above)
Research/Additional Benefits
and not Broker’s services that benefit only us.
Although not a material consideration when determining whether to recommend that a
client utilize the services of a particular independent broker-dealer/custodian, Stavis Wealth
from time to time receives from such broker-dealer/custodians without cost (and/or at a
discount) support services and/or products, certain of which assist Stavis Wealth to better
monitor and service client accounts maintained at such institutions. Included within the
support services that may be obtained by Stavis Wealth may be 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 the Firm in furtherance
of its investment advisory business operations.
As indicated above, certain of the support services and/or products that may be received will
assist Stavis Wealth in managing and administering client accounts. Others do not directly
provide such assistance but rather assist Stavis Wealth in managing and further developing
its business enterprise and operations. However, there is no corresponding commitment
made by the Firm to such broker-dealer/custodians or any other entity to invest any specific
amount or percentage of client assets in any specific mutual funds, securities or other
Directed Brokerage
investment products as a result of the above broker-dealer/custodians arrangements.
Stavis Wealth may accept directed brokerage arrangements where a client requires that
account transactions be effected through a specific broker-dealer. In such client directed
arrangements, the client will typically negotiate terms and arrangements for their account
with that broker-dealer separate from Stavis Wealth, and Stavis Wealth will not seek better
execution services or prices from other broker-dealers or be able to aggregate or batch the
client's transactions for execution through other broker-dealers with orders for other
accounts managed by Stavis Wealth. As a result, in cases of a directed brokerage
arrangement the client may pay higher commissions or other transaction costs or greater
spreads, or receive less favorable net prices, on transactions for the account than would
Please Note
otherwise be the case.
: In the event that the client directs Stavis Wealth to effect securities transactions
for the client's accounts through a specific broker-dealer, the client correspondingly
acknowledges that such direction may cause the accounts to incur higher commissions or
~ 28 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
transaction costs than the accounts would otherwise incur had the client determined to
effect account transactions through alternative trade execution arrangements that may be
available through Stavis Wealth.
Batched-Bunched-Blocked/Aggregated Trading
To the extent that Stavis Wealth provides investment management services to its clients, the
transactions for each client account generally will be effected independently, unless Stavis
Wealth decides to purchase or sell the same securities for several clients at approximately
the same time. Stavis Wealth may (but is not obligated to) aggregate or “bunch” such orders
to obtain best execution, to negotiate more favorable commission rates or to allocate
equitably among Stavis Wealth’s clients differences in prices and commissions or other
transaction costs that might have been obtained had such orders been placed independently.
Under this procedure, transactions will be averaged as to price and will be allocated among
clients in proportion to the purchase and sale orders placed for each client account in any
given trade. Stavis Wealth does not receive any additional compensation or remuneration as
a result of such aggregation.
Also, client commission arrangements and related “soft-dollar” benefits used or received by
the Firm are being used within the parameters of Section 28(e) and its related safe harbor.
Please also note that such “soft-dollar” benefits are not limited to those clients who may have
generated a particular benefit although certain soft dollar allocations may be connected to
Sharing of Financial and Estate Planning Fees
particular clients or groups of clients.
In certain cases as described above, Stavis Wealth may share and pay certain advisory fees
to private wealth managers that obtain financial data and client objectives in coordination
with the governing estate/financial plan. Such fees will be disclosed to the client in a
separate form, and the amount will vary based upon the time and effort expended by the
private wealth manager.
Sharing of Insurance Broker-Commission Fees
In certain cases as described above, Stavis Wealth’s Firm Principal may share in as noted
above, variable life insurance business that is conducted through BFS, whereby insurance
commissions are received by the Firm’s Principal in such principal’s capacity as a registered
Item 13 – Review of Accounts
insurance broker-agent.
Review of subaccounts within insurance policies, are reviewed quarterly. Such reviews entail
a written report regarding overall asset allocation and the individual holdings within each
policy subaccount, on an annual basis, in accordance with each client’s investment
objectives, risk tolerance. Additional reviews are triggered by events, such as a client
meeting; a request for withdrawal from a loan, or deposit into an account; a change in a
client's risk tolerance, financial position or investment/estate planning objectives; a change
in a company or fund's management; unusual market or economic circumstances; or other
~ 29 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
unforeseen event(s). The Firm encourages clients to meet with estate planning advisors of
the Firm at least annually.
Item 14 – Client Referrals and Other Compensation
Where a client is introduced to Stavis Wealth by a third-party solicitor, Stavis Wealth can pay
such solicitor a referral fee in accordance with the regulatory requirements. The Firm will
only compensate such persons or entities for referrals of financial and estate planning
clients, and all such referral or solicitor arrangements will be in accordance with applicable
regulatory rules, which generally require a written agreement and certain related written
documentation.
The Firm may act as a third-party solicitor for compensation where and when it refers
investment business to another advisor. In certain cases, and fully disclosed to the client, the
Firm may serve as a third-party solicitor and accept a solicitor’s fee for referring a client to
an investment manager.
Third-Party Vendor Relationships
Stavis Wealth maintains relationships with certain third-party vendors, including
GLASfunds, a private equity investment platform. The Firm or its Staff may receive non-cash
compensation from its vendors, which includes reimbursement or payment for travel,
lodging, meals, entertainment, or participation in conferences and other events. To the
extent this situation occurs, it creates a conflict of interest, as these benefits create an
incentive for Stavis Wealth or its personnel to promote the vendor providing the incentive
or recommend investments on the GLASfunds platform over other platform options in order
to continue receiving such non-cash compensation benefits. To mitigate this conflict, we
focus on providing investment recommendations that are based on independent analysis
consistent with our fiduciary duty obligations and each client’s best interests. Additionally,
we monitor and oversee vendor relationships through our advisory services team.
Item 15 – Custody
Stavis Wealth does not accept, take or hold actual or physical custody of any clients’ assets
rd
Item 16 – Investment Discretion
or investments. All custody is held by or with 3
party independent qualified custodians.
Stavis Wealth may receive discretionary authority from the client at the outset of an advisory
relationship to identify the appropriate allocation of subaccounts/IDFs within the policy.
However, such discretion is to be exercised in a manner consistent with the stated insurance
company policies and client investment objectives. When selecting securities and
determining amounts, Stavis Wealth observes the investment policies, limitations and
restrictions of the client for which it advises. Related investment guidelines and restrictions
should be provided in writing to Stavis Wealth by the client. The Firm has the authority to
determine, without obtaining consent of the client before transactions are effected, both the
subaccounts/IDFs, which are to be reallocated within the account.
~ 30 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
Stavis Wealth may also generally receive discretionary authority from the client as part of an
advisory relationship under a governing written advisory agreement to provide wealth
advisory services, including selecting the identity and amount of securities to be bought or
sold in client accounts. Generally, however, such discretion is to be exercised in a manner
consistent with the written investment objectives or plan for that particular client account.
When selecting securities and determining amounts in exercising such discretion, Stavis
Wealth observes the investment policies, limitations and restrictions of the client for which
it advises, as provided in writing to the Firm by the client from time to time inclusive of any
periodic updates. In this scenario, the Firm has the authority to determine, without obtaining
consent of the client before transactions are effected, both the securities which are to be
bought or sold and the amount of such securities. Limitations or restrictions on this
authority would result if the client specified that certain investments were to be precluded
or prohibited such as "no tobacco stocks” or “no sin stocks" or the like.
Item 17 – Voting Client Securities
As a matter of firm policy, Stavis Wealth generally does not accept the authority to and does
Class Actions/Legal Proceedings
not generally vote proxies.
Clients should note that Stavis Wealth will neither advise nor act on behalf of the investment
advisor clients in legal proceedings involving companies whose securities are held or
previously were held in the investment advisor’s clients’ account(s), including, but not
limited to, the filing of “Proofs of Claim” in class action settlements. Unless directed
otherwise in writing, Stavis Wealth will transmit, or forward copies of class action notices
received to the client and/or a third-party advisor or representative as designated by the
client. Stavis Wealth will also make commercially reasonable efforts to forward such notices
in a timely manner.
Item 18 – Financial Information
Registered investment advisers are required in this Item to provide you with certain
financial information or disclosures about such advisory firm’s financial condition where
such financial condition would likely impair the advisory firm’s ability to meet contractual
and fiduciary commitments to its clients. Stavis Wealth has no such financial commitment
or condition that impairs its ability to meet contractual and fiduciary commitments to its
clients, and it has not been the subject of a bankruptcy proceeding. Also, the Firm does not
require prepayment of more than $1200 in fees per client for six months or more in advance.
~ 31 ~
STAVIS WEALTH
ADV-PART 2 BROCHURE
DATE: MAR. 2026
ADV-PART 2B BROCHURE SUPPLEMENT (PART 2B)
STAVIS WEALTH TRANSFER SOLUTIONS, LLC
1330 Post Oak Blvd, Suite 2050
Houston, TX 77056
(3/15/2026)
This Brochure Supplement provides information about advisors at Stavis Wealth Transfer
Solutions (Stavis Wealth) and is a supplement to the Stavis Wealth ADV-Part 2 Disclosure
Brochure (Part 2A above). Additional information about our advisors is available on the
SEC’s website at www.adviserinfo.sec.gov.
LISTING OF ADVISORS COVERED IN THIS BROCHURE SUPPLEMENT
DEBORAH M. STAVIS
SAMIR SINHA
~ 32 ~
PART 2B – BROCHURE SUPPLEMENT
DEBORAH M. STAVIS, CFP® - MANAGING PRINCIPAL/CHIEF EXECUTIVE OFFICER
EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Year of Birth: 1955
Post-Secondary Education:
Attended Wayne State University, 1974 – 1978, Communications
Business Background:
-History Back to 1980 is available upon request
2009-2023: Chief Executive Officer, Stavis & Cohen Private Wealth/CI Private Wealth
1996-2007: Chief Executive Officer, Stavis, Margolis Advisory Services, Inc.
Professional Designations Held:
Certified Financial Planner ™, CFP® - Since 1987
Licenses Held:
Series 7 General Securities Representative
Series 24 General Securities Principal
Series 63 Uniform Securities Agent State Law
Series 65 Uniform Registered Investment Adviser Law
Group 1
Life and Health Insurance
-For an explanation of qualifications required for any designations, please see Appendix A.
DISCIPLINARY INFORMATION
Deborah M. Stavis has no legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
Deborah M. Stavis is Managing Principal/CEO at Stavis Wealth but is also separately
licensed as a Registered Representative with Benefit Funding Services (BFS), a registered
securities broker/dealer, member of the Financial Industry Regulatory Authority (FINRA)
and the Securities Investors Protection Corporation (SIPC). Deborah Stavis is also a
licensed insurance agent. Please refer to the Other Business Activities section of the Stavis
Wealth ADV-Part 2 Brochure for more information on this topic.
ADDITIONAL COMPENSATION
Deborah M. Stavis’ primary source of income is derived from her activities conducted on
behalf of the firm. Incidental sources derived from affiliates are minimal and disclosed on
her Outside Business Activities form.
SUPERVISION
The Firm’s Managing Principal is also the Firm’s Chief Compliance Officer and is responsible
for overseeing and enforcing the firm’s compliance program that monitors and supervises
the activities and services provided by the firm and its advisory representatives. Deborah
Stavis can be contacted by email as listed above or at 713-391-8200.
PART 2B – BROCHURE SUPPLEMENT
SAMIR SINHA, CFA® - MANAGING DIRECTOR/CHIEF INVESTMENT OFFICER
Year of Birth: 1972
EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Post-Secondary Education:
Columbia University – B.S. Chemical Engineering
Business Background:
2018-2025: Sr. Investment Analyst, Franklin Templeton Institute
2017-2018: Director of Research, Post Oak Private Wealth Advisors
2015-2017: Managing Director, Sinsonte Capital Management
2013-2015: Sr. Portfolio Manager, MBM Financial Advisors
Professional Designations Held:
Chartered Financial Analyst, CFA® - Since 2004
Licenses Held:
Not Applicable
-For an explanation of qualifications required for any designations, please see Appendix A.
DISCIPLINARY INFORMATION
Samir Sinha has no legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
None currently.
ADDITIONAL COMPENSATION
None currently.
SUPERVISION
The Firm’s Managing Principal is also the Firm’s Chief Compliance Officer and is responsible for
overseeing and enforcing the firm’s compliance program that monitors and supervises the
activities and services provided by the firm and its advisory representatives. Deborah Stavis can be
contacted by email as listed above or at 713-391-8200.
(Appendix A – Professional Designations/Certifications Summary)
CHARTERED FINANCIAL ANALYST (CFA®)
The Chartered Financial Analyst (CFA®) and Certification Mark (collectively, the "CFA
marks") are professional certification marks granted in the United States and internationally
by the CFA Institute. The Chartered Financial Analyst® (CFA®) charter is a globally
respected, graduate-level investment credential established in 1962 and awarded by CFA
Institute — the largest global association of investment professionals. There are currently
more than 150,000 CFA charterholders working in more than 140 countries. To earn the CFA
charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least
four years of qualified professional investment experience; 3) join CFA Institute as members;
and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code
CERTIFIED FINANCIAL PLANNER (CFP®)
of Ethics and Standards of Professional Conduct.
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the United
States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification
is a voluntary certification; no federal or state law or regulation requires financial planners to hold
CFP® certification. It is recognized in the United States and a number of other countries for its (1)
high standard of professional education; (2) stringent code of conduct and standards of practice; and
(3) ethical requirements that govern professional engagements with clients. Currently, more than
62,000 individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
Education
requirements:
– Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and (since 2007) attain a Bachelor’s Degree from
a regionally accredited United States college or university (or its equivalent from a foreign
university). CFP Board’s financial planning subject areas include insurance planning and risk
management, employee benefits planning, investment planning, income tax planning, retirement
Examination
planning, and estate planning;
– Complete at least three years of full-time financial planning-related experience (or
Standards of Professional Conduct
– Pass the comprehensive CFP® Certification Examination. The examination,
administered in 10 hours over a two-day period, includes case studies and client scenarios designed
to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of
Experience
financial planning to real world circumstances;
Ethics
the equivalent, measured as 2,000 hours per year); and
– Agree to be bound by CFP Board’s
, a set of documents
Continuing
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
Education
requirements in order to maintain the right to continue to use the CFP® marks:
Code of Ethics
Standards of Professional Conduct
,
– Complete 30 hours of continuing education hours every two years, including
two hours on the
and other parts of the
Ethics
Standards of Professional Conduct
to maintain competence and keep up with developments in the financial planning field; and
– Renew an agreement to be bound by the
. The
Standards prominently require that CFP® professionals provide financial planning services at a
fiduciary standard of care. This means CFP® professionals must provide financial planning services
in the best interests of their clients.