Overview
- Headquarters
- Louisville, KY
- Average Client Assets
- $1.6 million
- Minimum Account Size
- $25,000
- SEC CRD Number
- 165474
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.50% |
| $1,000,001 | $2,500,000 | 1.00% |
| $2,500,001 | $5,000,000 | 0.75% |
| $5,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $48,750 | 0.98% |
| $10 million | $73,750 | 0.74% |
| $50 million | $273,750 | 0.55% |
| $100 million | $523,750 | 0.52% |
Clients
- HNW Share of Firm Assets
- 34.07%
- Total Client Accounts
- 8,606
- Discretionary Accounts
- 8,606
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Educational Seminars
Regulatory Filings
Additional Brochure: FORM ADV PART 2A (2026-03-23)
View Document Text
Form ADV Part 2A
Strategic Wealth Investment Group, LLC
Firm Brochure
Effective: March 17, 2026
This brochure provides information about the qualifications and business practices of Strategic Wealth
Investment Group, LLC. If you have any questions about the contents of this brochure, please contact us
at (502) 412-3354 or by email at: compliance@swdgroup.com
The information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority. Registration does not imply a certain level of
skill or training. This brochure provides information about Strategic Wealth Investment Group to assist you
in determining whether to retain the Advisor.
Additional information about Strategic Wealth Investment Group, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov. Strategic Wealth Investment Group, LLC’s CRD number is: 165474
111 North Orange Avenue
Suite 800, Office #853
Orlando, FL 32801
(877) 934-7687
Branch Office Locations:
500 North Hurstbourne Parkway
Suite 120
Louisville, KY, 40222
(502) 412-3354
Website: www.swdgroup.com
3030 North Rocky Point Drive
Suite 100
Tampa, FL 33607
(813) 999-2486
9220 West Union Hills Drive
Suite 101
Peoria, AZ 85382
(623) 544-3424
1100 Abernathy Road N.E.
Suite L-20
Atlanta, GA 30328
(678) 638-6363
4600 South Syracuse Street
Suite 100
Denver, CO 80237
(303) 952-4044
2680 East Main Street
Plainfield, IN 46168
(317) 644-0876
11030 Circle Point Road
Suite 140
Westminster, CO 80020
(303) 952-4044
9025 River Road
Suite 120
Indianapolis, IN 46240
(317) 644-0876
1 Alhambra Plaza
PH 15
Coral Gables, FL 33134
(877) 934-7687
13146 Ballantyne Corp Place
Suite 100
Charlotte, NC 28277
(704) 817-4233
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Form ADV 2A Version: 3.17.2026
8041 Arco Corporate Drive
Suite 130
Raleigh, NC 27617
(919) 426-2052
101 Summit Avenue
Suite 100
Fort Worth, TX 76102
(817) 539-8702
5181 Natorp Boulevard
Suite 100
Mason, OH 45040
(513) 492-2198
2000 West Sam Houston Parkway South
Suite 150
Houston, TX 77042
(346) 385-0948
123 S Broad Street
15th Floor #1555
Philadelphia, PA 19109
(877) 934-7687
8000 IH-10 West
Suite 970
San Antonio, TX 78230
(210) 764-4461
3711 South Mopac Expressway
Bldg. 2, Suite 175
Austin, TX 78746
(737) 247-7683
1921 Gallows Road
Suite 110
Vienna, VA 22182
(703) 718-6973
12377 Merit Drive
Suite 120
Dallas, TX 75251
(972) 327-6511
3535 Factoria Blvd SE
Suite 425
Bellevue, WA 98006
(425) 658-2197
Item 2: Material Changes
The following changes have occurred since our last filing dated September 30, 2025:
Signed an agreement to engage with wealth/tech firm Envestnet.
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Form ADV 2A Version: 3.17.2026
Item 3: Table of Contents
Item 2: Material Changes � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 3: Table of Contents� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 4: Advisory Business� � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 5: Fees and Compensation � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 6: Performance-Based Fees and Side-By-Side Management � � � � � � � � � � � � � � � � � � � � � � � � � � � 8
Item 7: Types of Clients � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss � � � � � � � � � � � � 8
Item 9: Disciplinary Information � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 10: Other Financial Industry Activities and Affiliations � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading �15
Item 12: Brokerage Practices � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 13: Reviews of Accounts � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 14: Client Referrals and Other Compensation � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 15: Custody � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Item 16: Investment Discretion � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �18
Item 17: Voting Client Securities (Proxy Voting) � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �18
Item 18: Financial Information � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � � �
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Form ADV 2A Version: 3.17.2026
Item 4: Advisory Business
A� DESCRIPTION OF THE ADVISORY FIRM
Strategic Wealth Investment Group, LLC (“SWIG”) is a Delaware limited liability company. The firm was
formed in July of 2002 and began conducting investment advisory business in 2012. The principal owners
are Matthew J. Dicken and Jordan Schwartz. SWIG may conduct business under the trade name Strategic
Wealth Designers.
B� TYPES OF ADVISORY SERVICES
Strategic Wealth Investment Group, LLC (hereinafter “SWIG”) offers the following services to advisory
clients:
Investment Supervisory Services
SWIG offers ongoing portfolio management services based on the individual goals, objectives, time
horizon, and risk tolerance of each client. SWIG creates an Investment Advisory Contract for each
client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and
then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation.
Investment Supervisory Services include, but are not limited to, the following:
Investment strategy
Personal investment policy
Asset allocation
Asset selection
Risk tolerance
Regular portfolio monitoring
SWIG evaluates the current investments of each client with respect to their risk tolerance levels and
time horizon. SWIG requires discretionary authority from clients in order to select securities and execute
transactions without permission from the client prior to each transaction. Risk tolerance levels are
documented in the Investment Advisory Contract, which is given to each client.
In performing its asset management services for each client, SWIG may utilize a third-party platform
operated by an unaffiliated investment advisor, Envestnet Asset Management (“Sub-Adviser”). The Sub-
Adviser provides SWIG with certain sub-advisory asset management, administrative, technical and
support services. When utilizing the asset management services of the Sub-Adviser, SWIG delegates
discretionary authority to Sub-adviser which authorizes the Sub-Adviser to buy and sell investments
in the account without asking you in advance. SWIG will provide you with the Sub-Adviser’s disclosure
documents, including Form ADV 2A. Please refer to these disclosure documents for additional details
regarding the Sub-Advisor.
SWIG engages a third-party investment advisor (the “Advisor”) to provide SWIG with certain investment
advisory consulting services. These services are provided to SWIG and not directly to SWIG’s advisory
clients.
The Advisor’s services may include, as requested by SWIG, consultation regarding investment strategies,
asset allocation, and portfolio construction, and participation in periodic meetings with SWIG to discuss
these and other advisory matters. SWIG may also request that the Advisor provide model portfolios based
on parameters established by SWIG. In developing such model portfolios, the Advisor uses proprietary,
internally developed analytical and screening tools. SWIG does not receive direct access to the Advisor’s
proprietary tools.
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Form ADV 2A Version: 3.17.2026
The Advisor does not provide investment advice to SWIG’s underlying clients, does not communicate
directly with SWIG’s clients as part of this arrangement, and does not have discretionary authority or
trading authority over any client account. SWIG retains full responsibility for determining whether any
strategy, model portfolio, security, or investment approach is appropriate for any particular client, and for
implementing any investment recommendation in client accounts.
Any model portfolios, strategy input, or other consulting recommendations provided by the Advisor are
general in nature and are considered by SWIG together with SWIG’s own analysis, the client’s investment
objectives, risk tolerance, financial circumstances, and other relevant considerations. SWIG is not
obligated to implement any recommendation or model provided by the Advisor.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment planning, life
insurance; tax planning; retirement planning; college planning; and debt/credit planning. These services
are based on hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning
Agreement.
Services Limited to Specific Types of Investments
SWIG generally limits its investment advice and/or money management to mutual funds, equities,
bonds, fixed income, structured notes, ETFs, REITs, insurance products including annuities, government
securities, and private equity (only available to accredited investors and qualified persons). SWIG may use
other securities as well to help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money may create some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this
special rule’s provisions, we must:
Meet a professional standard of care when making investment recommendations (give prudent
advice);
Never put our financial interests ahead of yours when making recommendations (give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best interest;
Charge no more than is reasonable for our services; and
Give you basic information about potential conflicts of interest.
C� CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS
SWIG offers the same suite of services to all of its clients. However, specific client financial plans and their
implementation are dependent upon the client Investment Advisory Contract which outlines each client’s
current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific
plan to aid in the selection of a portfolio that considers restrictions, and the client risk profile.
Clients may request restrictions in investing in certain securities or types of securities in accordance with
their values or beliefs. However, if the restrictions prevent SWIG from properly servicing the client account,
or if the restrictions would require SWIG to deviate from its standard suite of services, SWIG reserves the
right to suggest alternatives.
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Form ADV 2A Version: 3.17.2026
D� PRIVATE PLACEMENTS
As part of our investment advisory services, we may recommend or assist clients in evaluating and
investing in private placements and other alternative investments. Private placements generally include
investments offered outside of a public exchange, such as interests in private investment funds (e.g.,
private equity, venture capital, hedge funds, private credit), private real estate funds, limited partnerships,
private notes, and other offerings made in reliance on exemptions from registration under federal and state
securities laws (commonly Regulation D).
Private placements are typically available only to investors who meet certain eligibility standards (such as
“accredited investor,” “qualified client,” or “qualified persons” status, as applicable). We will generally rely
on the issuer, placement agent, sponsor, and/or the client’s representations regarding eligibility unless we
separately agree otherwise in writing.
SWIG’s principals are minority owners of TRCM, an affiliated private fund sponsor which SWD may
recommend to clients. While clients are not charged a second layer of advisory fees by SWIG, the affiliated
fund may pay management or performance-based compensation to its owners, including SWIG principals.
This creates a conflict of interest because SWIG and its principals may benefit financially when clients
invest in the TRCM fund, potentially influencing our recommendations.
E� WRAP FEE PROGRAMS
A wrap fee program is an investment program where the investor pays one stated fee that includes
management fees, transaction costs, and any other administrative fees. SWIG does not participate in any
wrap fee programs.
F� ASSETS UNDER MANAGEMENT
SWIG has the following assets under management:
Discretionary Amounts:
$1,384,291,490
Non-discretionary Amounts:
$0.00
Date Calculated:
December 31, 2025
Item 5: Fees and Compensation
A� FEE SCHEDULE
Investment Advisory Fees
The following table represents the base schedule of fees charged by Strategic Wealth Investment Group
LLC for services provided fees are based on assets under management and you will not pay separate
commission ticket charge or custodial fee for the execution of transactions in your account this does not
exclude the potential of additional fees being charged by our custodian for certain kinds of products as
dictated by their client account agreement terms
Total Assets Under Management Annual Fee
First $1,000,000
1,000,001- $2,499,999
$2,500,000 - $4,999,999
Above $5,000,000
1.50%
1.00%
0.75%
0.50%
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Form ADV 2A Version: 3.17.2026
Fees are negotiable based on the services requested and the complexity of the engagement. Your
specific fee schedule is set forth in the Investment Advisory Contract (and any exhibits). Unless otherwise
agreed in writing, portfolio management fees are calculated monthly and billed in arrears, and are
typically deducted from your custodial account with your written authorization. You may terminate the
Investment Advisory Contract upon fifteen (15) days written notice. Upon termination, we will calculate
any advisory fee due through the effective termination date; because fees are generally billed in arrears,
there is typically no unearned fee to refund. If any advisory fee is collected in advance for any reason, any
unearned portion will be refunded on a prorated basis. You may terminate without penalty within five (5)
business days of signing the contract, and any fees paid in advance (if any) will be refunded in full.
SWIG pays the Advisor an annual consulting fee, billed quarterly in advance, for the services described
above in Item 4. This fee is paid by SWIG from its own revenues and is not charged separately to clients as
a distinct fee.
To the extent this expense is a cost of operating SWIG’s advisory business, clients should understand
that SWIG’s advisory fee is intended to cover, among other things, SWIG’s general business expenses,
including amounts paid to third-party service providers such as the Advisor.
Financial Planning Fees
Financial planning fees are negotiable based on the scope and complexity of the planning engagement
and are set forth in the Financial Planning Agreement (and any exhibits). Planning fees are generally due
in advance; however, we do not require payment more than six (6) months in advance. You may terminate
the Financial Planning Agreement within five (5) business days of signing without penalty. If you terminate
after that period, any unearned portion of fees paid in advance will be refunded on a prorated basis based
on the work completed as of the termination date.
B� PAYMENT OF FEES
Payment of Investment Advisory Fees
Advisory fees are paid monthly in arrears to SWIG and are typically withdrawn from the client’s account
with one-time up-front written authorization.
Payment of Financial Planning Fees
Financial planning fees may be paid by check or credit card. To the extent fees are paid in advance, we will
not require payment more than six (6) months in advance, and any unearned portion will be refunded on a
prorated basis upon termination.
C� CLIENTS ARE RESPONSIBLE FOR THIRD PARTY FEES
We want clients to understand that, in addition to SWIG’s advisory fee, their account may include certain
routine third-party costs related to custody, brokerage, and investments. These charges are separate from
SWIG’s fee, are paid to the applicable third-party provider, and may include custodian fees, brokerage
commissions, transaction fees, and mutual fund or ETF expenses.
These types of costs are common for investment accounts and will vary based on the services used, the
investments selected, and account activity. Not all clients will incur all such charges. Please see Item 12 of
this brochure for additional information regarding brokerage and custodian arrangements.
D� PREPAYMENT OF FEES
Advisory fees are quoted on an annualized basis, and, unless agreed to otherwise in writing, will
be calculated and payable monthly in arrears, based on the market value of the client’s account (as
determined by the Custodian) as of the last business day of the billing period. Multiple related accounts
within a household shall be aggregated for purposes of determining the applicable annual fee rate to be
charged.
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Form ADV 2A Version: 3.17.2026
E� OUTSIDE COMPENSATION FOR THE SALE OF SECURITIES TO CLIENTS
Neither SWIG nor its supervised persons accept any compensation from outside sources for the sale of
securities or other investment products, including asset-based sales charges or services fees from the
sale of mutual funds.
F� ADDITIONAL COST OF STRUCTURED NOTES
In addition to our advisory fee, clients may incur product-level and transactional costs when purchasing
structured notes. These may include (depending on the offering) commissions or selling concessions,
structuring fees, and hedging costs that can be embedded in the note’s price and may cause the issue
price to be higher than the issuer’s estimated value at issuance. Clients may also experience bid/ask
spreads and price concessions on early sale or secondary-market transactions.
G� ADDITIONAL COMPENSATION
Our representatives may also be licensed insurance agents and recommend insurance products to any
client. They can earn commissions when selling these products. This is a potential conflict because they
may recommend the purchase of an insurance product resulting in a commission being paid.
In addition, our firm receives non-cash incentives and potential bonus compensation from Advisors Excel,
a third-party insurance marketing organization, if aggregate insurance sales by SWIG representatives
exceed certain thresholds. These incentives may include marketing support, reimbursement for
conferences, or other firm benefits. This creates a conflict of interest because SWIG may have an incentive
to promote insurance products in order to qualify for additional firm-level compensation.
Item 6: Performance-Based Fees and Side-By-Side Management
SWIG does not accept performance-based fees or other fees based on a share of capital gains on or
capital appreciation of the assets of a client.
Item 7: Types of Clients
SWIG generally provides investment advice and/or management supervisory services to the following
types of clients:
Individuals
High Net Worth Individuals
Corporations or Business Entities
Minimum Account Size
There is an account minimum, $7,500, which may be waived by the investment advisor, based on the
needs of the client and the complexity of the situation.
Item 8: Methods of Analysis, Investment Strategies, and Risk of
Investment Loss
A� METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
Methods of Analysis
SWIG may employ fundamental, charting, cyclical and technical analysis methods in developing
investment strategies for its clients. Research and analysis from SWIG are derived from numerous sources,
including financial media companies, third-party research materials, professional data subscriptions,
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Form ADV 2A Version: 3.17.2026
Internet sources, and review of company activities, including annual reports, prospectuses, press releases
and research prepared by others. The definitions of the different types of analysis are as follows:
Charting analysis involves the use of patterns in performance charts. SWIG uses this technique to
search for patterns used to help predict favorable conditions for buying and/or selling a security.
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages.
Technical analysis involves the analysis of past market data; primarily price and volume.
Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or
selling a security.
Investment Strategies
Advisors generally use one or more of the following investment strategies when implementing investment
advice to clients:
Long-term investments (investments held at least one year)
Short-term investments (investments sold within one year)
Model Portfolios
SWIG use internally developed model portfolios as a starting point (i.e., a baseline framework) for
managing client accounts. These model portfolios are designed to promote consistent and disciplined
investment practices; however, they may not be applied on a “one-size-fits-all” basis. Prior to
implementation and on an ongoing basis, we review each client’s investment objectives, risk tolerance,
time horizon, liquidity needs, tax considerations (as applicable), and any client-imposed restrictions. We
periodically reassess both the underlying model portfolio and each client’s tailored implementation for
continued appropriateness, and we make adjustments when a client’s circumstances or market conditions
warrant. Clients may request additional customization at any time, and we will determine whether such
customization is feasible and consistent with the client’s stated objectives and applicable guidelines.
SWIG may offer both internally managed model portfolios and third-party strategies provided through
Envestnet. In some cases, we may receive financial or operational benefits tied to client use of Envestnet.
Although we strive to recommend the most suitable model based on your risk profile and investment
goals, these affiliations create a potential conflict of interest when deciding which model to assign to a
client.
Selection of Third-Party Managers
In addition to utilizing our firm’s own model portfolios, SWIG has contracted with a Sub-Advisor Envestnet,
registered with the United States Securities and Exchange Commission. This contract provides SWIG
clients with access to model portfolios, and third- party money managers. Our selection process cannot
ensure that third-party money managers will perform as desired and SWIG has no control over the day-to-
day operations of any of its selected third-party money managers. SWIG conducts initial and ongoing due
diligence of third- party money manager and sub-advisors as part of its fiduciary duty to its clients.
Non-Traded Securities/Private Placements
Under certain circumstances, SWIG may recommend to accredited investors or qualified persons an
allocation to select private placements or other non-traded investment vehicles (vehicles), where the
investments inside the vehicle are managed by a third-party. Furthermore, the private placement or non-
traded investment vehicle may have little to no liquidity such that an investor may be required to maintain
their investment until such time that the manager of the investment liquidates the fund/vehicle and returns
capital to investors. These types of investments may not be suitable for all clients.
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Form ADV 2A Version: 3.17.2026
Structured Notes
From time to time, our models and portfolios may include structured notes. Structured notes are securities
issued by financial institutions with returns that are linked to a reference asset or index (e.g., an equity
index, a basket of securities, interest rates, commodities, or currencies), typically with a fixed maturity and
an embedded derivative component.
B� RISK OF LOSS
Investing in securities involves a risk of loss that you should be prepared to bear, including the loss of
your original principal. You should also be aware that past performance of any security is not necessarily
indicative of future results. Therefore, do not assume that future performance of any specific investment or
investment strategy will be profitable. We do not provide any representation or guarantee that client goals
will be achieved.
Investing in securities involves risk of loss. Further, depending on the different types of investments, there
may be varying degrees of risk:
Risk of Loss: Securities investments are not guaranteed, and clients may lose money on investments.
As with any investment , our investment recommendations are subject to market risk—the possibility that
security prices will decline over short or extended periods of time. As a result, the value of client accounts
will fluctuate with the market, and clients could lose money over short or long periods of time. Clients
should recognize whenever they determine to invest in the securities markets, the entire investment is at
risk. Clients should not invest money if they are unable to bear the risk of total loss of their investments.
Economic Risk: The prevailing economic environment is important to the health of all businesses and
security markets. Some companies, however, are more sensitive to changes in the domestic or global
economy than others. These types of companies are often referred to as cyclical businesses. Countries in
which a large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an security issuer is located in a country that experiences wide
economic swings, or in situations where certain elements of an investment instrument interact with such
countries, the investment instrument will generally be subject to a higher level of economic risk.
Financial Risk: Financial risk represents internal disruptions within an investment or the issuer that can
lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like
Enron or many of the “dot com” companies that had weak balance sheets despite initial strong market
performance.
Market Risk: The value of a client’s portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases. Further, regardless of how well individual companies
perform, the value of a client’s portfolio could also decrease if there are deteriorating economic or market
conditions. It is important to understand that the value of clients’ investments may fall, potentially sharply,
in response to changes in the market, and clients could lose money. Investment risks include price
risk as may be observed by a drop in a security’s price due to company specific events (e.g., earnings
disappointment or downgrade in the rating of a bond) or general market risk (e.g., such as a “bear” market
when stock values fall in general). For fixed-income securities, a period of rising interest rates could cause
security prices to fall.
Political & Regulatory Risks: Investments may be subject to risks resulting from a particular political
party or regulatory agency. For example, Exploration and Production companies may face additional
government and or regulatory oversight that either restricts their ability to develop resources or makes the
future development of resources uneconomical.
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Equity (Stock) Market Risk: Common stocks are susceptible to fluctuations and to volatile increases/
decreases in value as their issuers’ confidence in or perceptions of the market change. Investors holding
common stock (or common stock equivalents) of any issuer are generally exposed to greater risk than if
they hold preferred stock or debt obligations of the issuer.
Company Risk: There is always a certain level of company or industry specific risk when investing
in stock positions. This is referred to as unsystematic risk and can be reduced through appropriate
diversification. There is the risk that a company may perform poorly or that its value may be reduced
based on factors specific to it or its industry (e.g., employee strike, unfavorable media attention).
Fixed Income Risk: Investing in bonds involves the risk that the issuer will default on the bond and be
unable to make payments. In addition, individuals depending on set amounts of periodically paid income
face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular
payments that face the same inflation risk.
ETF and Mutual Fund Risk: ETF and mutual fund investments bear additional expenses based on a pro-
rata share of operating expenses, including potential duplication of management fees. The risk of owning
an ETF or mutual fund generally reflects the risks of owning the underlying securities held by the ETF or
mutual fund. Clients also incur brokerage costs when purchasing ETFs.
Management Risk: Client investments also vary with the success and failure of Advisor’s investment
strategies, research, analysis, and determination of portfolio securities. If Advisor’s strategies do not
produce the expected returns, the value of a client’s investments will decrease.
Cybersecurity Risk: SWIG’s information and technology systems could become vulnerable to damage
or interruption from computer viruses, network failures, computer and telecommunication failures,
infiltrations by unauthorized persons and security breaches, spyware, usage errors by its professionals,
power outages and catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes.
Although SWIG has implemented various measures to manage these risks, including, but not limited
to, creating redundant systems at all times, if these systems are compromised, become inoperable for
extended periods of time, or cease to function properly, SWIG could potentially have to make a significant
investment to fix or replace them. The failure of these systems and/or disaster recovery plans for any
reason could cause significant interruptions in our operations and result in a failure to maintain the
security, confidentiality, or privacy of sensitive data, including personal information relating to clients.
Such a failure could harm SWIG’s reputation or subject us to legal claims and otherwise affect our
business and financial performance. SWIG has taken steps to mitigate these risks by retaining the
services of cybersecurity specialists who are experts at monitoring, managing, and mitigating the risks of
cyberattacks. This monitoring is implemented seven days a week, 24 hours a day and 365 days a year.
Liquidity Risk: Privately held real estate, private equity investments, individual fixed income securities,
thinly- traded equity securities, non-traded securities, and other alternative investment products often
entail accepting liquidity risk. Liquidity risk is the inability to liquidate/exit an investment and/or liquidation
in a timely manner without potentially incurring a significant monetary penalty in order to access their
funds.
Structured Note Risk: In addition to general market risk, structured notes have certain material risks
and characteristics, which may be significant:
Issuer credit/counterparty risk: Structured notes are generally unsecured debt obligations of the
issuer. Any “principal protection” or repayment feature is subject to the issuer’s ability to pay; if the
issuer defaults, a client could lose some or all principal and any expected payments.
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Complexity and payoff-structure risk: Notes may include features such as participation rates,
caps, buffers/barriers/knock-ins, leverage or inverse exposure, and contingent coupons. These
features can cause outcomes where a client has limited upside, amplified losses, or losses even when
the reference asset increases (depending on the formula).
Liquidity and early-sale risk: A secondary market is often limited; clients may need to hold a note
to maturity and could be forced to sell at a significant discount (or may be unable to sell).
Valuation and pricing risk (including “estimated value”): The issuance price paid by investors
may exceed the issuer’s estimated value on the issue date due to selling, structuring, and hedging
costs embedded in the note’s price. After issuance, notes may be difficult to value due to complexity
and limited trading.
Call/early redemption risk: Some notes permit the issuer to redeem prior to maturity, potentially
limiting returns and creating reinvestment risk.
Tax risk: Tax treatment can be complicated and, in some cases, uncertain; clients should review
offering documents and consult their tax advisers.
Concentration and correlation risk: Notes can embed concentrated exposure to a single security,
issuer, sector, or proprietary index methodology; performance may differ materially from simpler
exposures to the same reference asset.
Client-specific use: Where structured notes are used, we generally evaluate (as applicable): product
terms (caps/buffers/barriers), issuer credit profile, maturity/expected holding period, expected liquidity,
estimated value vs. offering price, and role in overall portfolio construction.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve a
risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these
risks with the Advisor.
Item 9: Disciplinary Information
There are no legal, regulatory, or disciplinary events involving SWIG or its management persons. SWIG
values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due
diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor
and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.
adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 165474.
Item 10: Other Financial Industry Activities and Affiliations
A� REGISTRATION AS A BROKER/DEALER OR BROKER/DEALER REPRESENTATIVE
Neither SWIG nor its representatives are registered as or have pending applications to become a broker/
dealer or as representatives of a broker/dealer.
B� REGISTRATION AS A FUTURES COMMISSION MERCHANT, COMMODITY POOL
OPERATOR, OR A COMMODITY TRADING ADVISOR
Neither SWIG nor its representatives are registered as or have pending applications to become a Futures
Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor.
C� REGISTRATION RELATIONSHIPS MATERIAL TO THIS ADVISORY BUSINESS AND
POSSIBLE CONFLICTS OF INTERESTS
Consistent with the firm’s financial planning philosophy, our financial professionals may recommend
insurance products (for example, fixed index annuities (“FIAs”)) as part of a client’s overall financial plan,
including in lieu of allocating certain assets to advisory accounts (e.g., cash and fixed income allocations).
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You should understand that recommendations involving insurance products present conflicts of interest
because insurance transactions typically involve commission-based compensation and may involve
incentive programs. These conflicts are described below, and clients are under no obligation to implement
any recommendation through SWD or any affiliated insurance agency.
As an estimate, our financial professionals that are registered as investment advisor representatives
spend approximately half of their time on insurance sales and services and half of their time on investment
advisory services. Please refer to Item 5 – Fees and Compensation and Item 14 – Client Referrals and
Other Compensation for more details.
You may therefore work with your SWIG financial professional in both their capacity as an investment
adviser representative (IAR) of SWIG, as well as in their capacity as an insurance agent through our
affiliated company Strategic Wealth Designers, LLC (“SWD”). As such, your SWIG financial professional,
in their dual capacity as an IAR and insurance agent, may advise you to purchase insurance products
(general disability insurance, life insurance, annuities, and other insurance products), and then assist you
in implementing the recommendations by selling you those same products.
If you purchase an insurance product through one of our financial professionals acting as an insurance
agent, the agent will typically receive a commission from the insurance company or other third party.
The receipt of commissions presents a conflict of interest because it creates a financial incentive to
recommend insurance products (or particular products) that pay higher or more immediate compensation,
which could influence the products we recommend. SWIG seeks to mitigate this conflict by requiring that
recommendations be made in the client’s best interest, by disclosing the conflict, and through supervision
and periodic reviews of insurance recommendations.
Furthermore, because commissions vary by product, associated persons may have an incentive to
recommend certain products based on the compensation received. This presents a conflict of interest, as
the compensation received on one product may be greater than on another.
Insurance products may have different commission schedules and payment timing depending on the
product. In some cases, commissions may be paid substantially at the time of purchase, while advisory
fees are generally paid over time. This difference in timing can create an incentive to recommend a
product that pays compensation sooner rather than an advisory solution that pays over a longer period.
For illustration only, a one-time commission on an insurance purchase may be paid upfront, while an
advisory fee on a similarly sized account would typically be paid periodically over time.
Additional conflicts may arise because our affiliate company, Strategic Wealth Designers (“SWD”), utilizes
a third-party insurance marketing organization, Advisors Excel in connection with sourcing and placing
certain insurance products. Advisors Excel may offer incentive compensation (which may include cash
or non-cash awards) based on meeting specified sales goals or placing products through Advisors Excel.
These incentives are typically determined based on aggregate sales and may be paid to the firm and/
or individuals. Such incentives create a conflict of interest because they could influence the selection of
products or providers. Clients are not required to purchase any insurance product through Advisors Excel,
or SWD.
Advisors Excel provides SWD, with marketing assistance and business development tools; technology
intended to improve the client experience and firm efficiency; and back office and operations support
to assist in the processing of our insurance through Advisors Excel. SWIG seeks to address this conflict
through disclosure, supervision, and by requiring that all recommendations be made in the client’s best
interest.
As a fiduciary, SWIG requires its investment adviser representatives to recommend insurance and
annuities only when they believe the recommendation is in the client’s best interest, taking into account
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the client’s objectives, time horizon, risk tolerance, liquidity needs, and total costs. Commission-based
insurance activity is supervised by the firm’s Managing Members and/or designated supervisors.
SWIG conducts periodic reviews of insurance recommendations (including a review of suitability and
documentation) and addresses exceptions as appropriate. If you have questions or concerns about
an insurance or annuity recommendation, please contact your financial professional or SWIG’s Chief
Compliance Officer.
Finally, you should be aware that there are other insurance products that are offered by other insurance
agents other than those recommended by our financial professionals. You are under no obligation to
implement any insurance or annuity transaction through SWD.
Ownership Interest in Private Placement We Recommend
The principals of SWIG are also minority shareholders of the private fund Total Return Capital
Management, LLC (the Fund).
Investments in the Fund may be recommended to advisory clients for whom a partnership investment
may be more suitable than would a separate advisory account managed by our firm. While SWIG Clients
are not charged a second layer of advisory fees by SWIG, the affiliated fund may pay management or
performance-based compensation to its owners, including SWIG principals. This creates a conflict of
interest because SWIG and its principals may benefit financially when clients invest in the TRCM fund,
potentially influencing our recommendations. We seek to mitigate this conflict through policies and
procedures designed to ensure that our recommendations remain in clients’ best interests, including:
Full disclosure of the conflict in this Brochure and, where appropriate, in other client
communications
Investment due diligence and an investment selection process that considers the Private
Placement alongside comparable alternatives
Ongoing monitoring of the Private Placement and the applicable strategy, including periodic reviews
to determine whether the Private Placement continues to be appropriate relative to alternatives
The Fund is not required to register as an investment company under the Investment Company Act of
1940 in reliance upon an exemption available to funds whose securities are not publicly offered. The
Fund is managed on a discretionary basis in accordance with the terms and conditions of its offering and
organizational documents.
Ownership Interest in an ETF We Recommend
The principal(s) of SWIG are also minority shareholders in Coastal Compass 100 ETF ROPE (the “ETF”),
an exchange-traded fund that we may recommend to clients and/or include in our model portfolios. In
addition, through a minority ownership interest in TRCM, one of our owners also holds an indirect minority
ownership interest in Bancreek Capital, the sponsor of Bancreek International Large Cap ETF (BCIL) and
Bancreek US Large Cap ETF (BCUS) (together, the “Bancreek ETFs”), which may be in our models in
which we recommend to clients.
Because a principal has a financial interest in the ETF and because one of our principal(s) has an indirect
financial interest in Bancreek Capital and the Bancreek ETFs, these relationships create a conflict of
interest: SWIG has an incentive to recommend or cause clients to invest in the ETF and/or the Bancreek
ETFs in order to benefit from increases in the value of that ownership interest and/or from any economic
benefits associated with such ownership. We seek to mitigate this conflict through policies and
procedures designed to ensure that our recommendations remain in clients’ best interests, including:
Full disclosure of the conflict in this Brochure and, where appropriate, in other client
communications;
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Investment due diligence and an investment selection process that considers the ETF alongside
comparable alternatives (including cost, liquidity, tracking error, tax considerations, and risk/return
characteristics);
Ongoing monitoring of the ETF and the applicable strategy, including periodic reviews to determine
whether the ETF continues to be appropriate relative to alternatives;
Supervisory oversight of the inclusion of the ETF in models and client accounts; and
SWIG and our affiliates are not restricted from forming additional investment funds, entering into other
investment advisory relationships or engaging in other business activities.
D� SELECTION OF OTHER ADVISERS OR MANAGERS AND HOW THIS ADVISER IS
COMPENSATED FOR THOSE SELECTIONS
As described in Item 4, SWIG may engage an unaffiliated sub-adviser/platform provider (the “Sub-
Adviser”) to provide certain investment management and platform-related services. Through this
relationship, SWIG may receive access to technology and support services (for example, model and
manager selection tools, trading, reporting, billing, and client service support). In addition, the availability
and/or level of certain services, pricing concessions, service credits, or other non-cash benefits may
depend on the aggregate client assets that SWIG places with or through the Sub-Adviser.
These arrangements present a conflict of interest because they provide an incentive for SWIG to
recommend or continue using a particular platform, sub-adviser, or manager. SWIG seeks to mitigate this
conflict by evaluating Sub-Advisers and investment options based on client needs and by periodically
reviewing the relationship for reasonableness.
SWIG has a business relationship with the Advisor, which provides the Firm with consulting services and
model portfolio support as described in this Brochure. In some circumstances, the Advisor or its affiliates
may sponsor, manage, or be otherwise associated with investment funds or models that the Firm may
consider for client accounts.
This creates a conflict of interest because the Firm’s consideration or recommendation of an Advisor-
affiliated fund in one of our investment models could be viewed as being influenced by the Firm’s
relationship with the Advisor. The Firm is under no obligation to recommend any such fund or product and
will do so only if the Firm determines that the investment is appropriate for the client in light of the client’s
investment objectives, financial situation, and risk tolerance.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
A� CODE OF ETHICS
We have a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider
Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of
Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures,
Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance,
Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review,
and Sanctions. Our Code of Ethics is available free upon request to any client or prospective client.
B� RECOMMENDATIONS INVOLVING MATERIAL FINANCIAL INTERESTS
As noted above in Item 10, SWIG may recommend securities in which related persons to SWIG have a
material financial interest.
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The Code requires personnel to disclose any and all material financial interests as part of the ongoing
compliance process. Clients may receive recommendations to buy securities where a material financial
interest exists.
C� INVESTING PERSONAL MONEY IN THE SAME SECURITIES AS CLIENTS
From time to time, representatives of SWIG may buy or sell securities for themselves that they also
recommend to clients. This may provide an opportunity for representatives of SWIG to buy or sell the
same securities before or after recommending the same securities to clients resulting in representatives
profiting off the recommendations they provide to clients. Such transactions may create a conflict of
interest. SWIG will always document any transactions that could be construed as conflicts of interest and
will always transact client business before their own when similar securities are being bought or sold.
D� TRADING SECURITIES AT/AROUND THE SAME TIME AS CLIENTS’ SECURITIES
From time to time, representatives of SWIG may buy or sell securities for themselves at or around
the same time as clients. This may provide an opportunity for representatives of SWIG to buy or sell
securities before or after recommending securities to clients resulting in representatives profiting off the
recommendations they provide to clients. Such transactions may create a conflict of interest. SWIG will
always transact clients’ transactions before its own when similar securities are being bought or sold.
Item 12: Brokerage Practices
A� FACTORS USED TO SELECT CUSTODIANS AND/OR BROKER/DEALERS
1� Research and Other Soft-Dollar Benefits
SWIG receives no research, product, or services other than execution from a broker-dealer or third-party
in connection with client securities transactions (“soft dollar benefits”).
2� Brokerage for Client Referrals
SWIG receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or
third party.
3� Clients Directing Which Broker/Dealer/Custodian to Use
Clients do not have the ability to direct SWIG which Broker/Dealer/Custodian to use SWIG will require
clients to use Schwab’s broker-dealer to execute transactions, except when Schwab uses an outside
executing facility for liquidity or best execution.
4� Delegation of Processing Trades to Sub-Adviser
When a client’s account has been assigned to the sub-adviser, Envestnet, the processing of trades in
client accounts is delegated by SWIG, to the Sub-Advisor. The Sub-Advisor is responsible for submitting
transactions for clients on behalf of SWIG, on an individual or aggregated basis, according to the Sub-
Adviser’s policies. For a complete description of the Sub-Adviser’s policies regarding aggregate trading,
please refer to the Sub-Adviser’s Form ADV2A.
B� AGGREGATING (BLOCK) TRADING FOR MULTIPLE CLIENT ACCOUNTS
Through Schwab, SWIG maintains the ability to block trade purchases across accounts. Block trading may
benefit a large group of clients by providing SWIG the ability to purchase larger blocks resulting in smaller
transaction costs to the client. Declining to block trade can cause more expensive trades for clients.
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C� STRUCTURED NOTES
When structured notes are purchased, they are often sourced through broker-dealers and may be offered
on a new-issue basis or via limited secondary markets. As a result, price discovery and liquidity may differ
from exchange-traded securities. Clients should understand that structured notes are often not exchange-
listed and the issuer, an affiliate, or a distributor may be the only practical source of secondary liquidity (if
any).
In evaluating broker-dealers and execution for these transactions, we consider (as applicable)
availability of the desired exposure/structure, total expected cost (including embedded economic costs),
transparency of terms and estimated value disclosures, and the likelihood and terms of secondary liquidity
Item 13: Reviews of Accounts
A� FREQUENCY AND NATURE OF PERIODIC REVIEWS AND WHO MAKES THOSE REVIEWS
Client accounts are reviewed on a periodic sample basis by a compliance representative of the firm with
regards to their investment policies and risk tolerance levels. All financial planning accounts are reviewed
upon plan delivery by a compliance representative of the firm.
B� FACTORS THAT WILL TRIGGER A NON-PERIODIC REVIEW OF CLIENT ACCOUNTS
Reviews may be triggered by material market, economic or political events, or by changes in client’s
financial situations (such as retirement, termination of employment, physical move, or inheritance).
C� CONTENT AND FREQUENCY OF REGULAR REPORTS PROVIDED TO CLIENTS
Each client will receive at least quarterly from the qualified custodian, a statement or written report that
details the client’s account including assets held, asset value and management fees assessed.
Item 14: Client Referrals and Other Compensation
A� ECONOMIC BENEFITS PROVIDED BY THIRD PARTIES FOR ADVICE RENDERED TO
CLIENTS (INCLUDES SALES AWARDS OR OTHER PRIZES)
SWIG does not receive cash compensation from unaffiliated third parties in exchange for providing
investment advice to clients. However, as described elsewhere in this brochure, SWIG may receive certain
non-cash benefits or services from unaffiliated service providers (including platform or sub-adviser
providers) that are made available, in whole or in part, based on the overall client assets serviced through
those providers. These benefits create a conflict of interest because they may influence SWIG’s selection
of service providers. SWIG addresses this conflict through due diligence, periodic review, and by acting in
clients’ best interests.
B� COMPENSATION TO NON – ADVISORY PERSONNEL FOR CLIENT REFERRALS
From time to time, SWIG may provide nominal, non-cash tokens of appreciation (for example, a restaurant
gift card) to individuals who refer prospective clients to the firm. These tokens are not conditioned on the
referred person becoming a client, are not based on the size of any account opened, and are not intended
to compensate the referrer for solicitation activities. Nonetheless, this practice presents a conflict of
interest because it could create an incentive to make referrals. Any such non-cash items are limited in
value and frequency under the firm’s Code of Ethics.
Item 15: Custody
SWIG does not maintain physical possession of client assets. All assets are held by qualified custodians.
When advisory fees are deducted directly from client accounts at client’s custodian, SWIG is deemed to
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have limited custody of client’s assets and SWIG will have up-front written authorization from the client
to deduct advisory fees from the account. Clients will receive account statements from the custodian and
should carefully review those statements.
Each time a fee is directly deducted from the client accounts, SWIG or its partner Envestnet will send the
qualified custodian notice of the amount of fee to be deducted. At least quarterly, the qualified custodian
will send to the client an account statement identifying the amount of funds and each security in the
accounts at the end of the period and setting forth all transactions in the account during that period.
We maintain client assets with a “qualified custodian.” You must engage the custodian to hold your funds
and securities, and you will receive account statements directly from the custodian (at least quarterly).
SWIG does not maintain physical possession of client cash or securities. Under Rule 206(4)-2 under the
Advisers Act (the “Custody Rule”), SWIG is deemed to have limited custody of client funds because: (1)
with your written authorization, we may deduct advisory fees from your custodial account; and/or (2) you
may authorize the custodian, through a standing letter of authorization (“SLOA”) or similar instruction,
to permit SWIG to direct certain disbursements to third parties you designate. Clients may revoke such
authorization at any time by notifying the custodian (and, as applicable, SWIG).
SWIG may be deemed to have custody when a client establishes certain types of letters of instruction
or other asset transfer authorization arrangements with a qualified custodian that permit SWIG to direct
disbursements to one or more third parties specifically designated by the client. SWIG intends to structure
and administer any such SLOA arrangements in a manner consistent with applicable SEC staff guidance,
including maintaining written client authorization and implementing appropriate safeguards designed
to limit SWIG’s authority to the specific third parties and amounts authorized by the client. To the extent
SWIG satisfies the conditions in applicable SEC staff guidance for SLOA arrangements, SWIG believes it is
not required to obtain a surprise examination solely as a result of that limited custody. If those conditions
are not met, or if regulatory requirements change, SWIG will take steps to comply with the Custody Rule,
which may include obtaining a surprise examination.
The custodians recommended by SWIG send a statement to the client, generally on a monthly basis,
indicating all amounts disbursed from the account including the amount of management fees paid directly
to SWIG. Clients should review statements provided by the Custodian and compare them to any reports
provided by SWIG to ensure accuracy, as the Custodian does not perform this review. If you ever have a
question about an entry on your SWIG report(s), please call us immediately. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
Item 16: Investment Discretion
For those client accounts where SWIG provides ongoing supervision, the client has given SWIG written
discretionary authority over the client’s accounts with respect to securities to be bought or sold and the
amount of securities to be bought or sold. Details of this relationship are fully disclosed to the client before
any advisory relationship has commenced. The client provides SWIG discretionary authority via a limited
power of attorney in the Investment Advisory Contract and in the contract between the client and the
custodian.
Item 17: Voting Client Securities (Proxy Voting)
SWIG will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly
from the issuer of the security or the qualified custodian. Clients should direct all proxy questions to the
issuer of the security.
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Item 18: Financial Information
A� BALANCE SHEET
SWIG does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in
advance and therefore does not need to include a balance sheet with this brochure.
B� FINANCIAL CONDITIONS REASONABLY LIKELY TO IMPAIR ABILITY TO MEET
CONTRACTUAL COMMITMENTS TO CLIENTS
Neither SWIG nor its management have any financial conditions that are likely to reasonably impair our
ability to meet contractual commitments to clients.
C� BANKRUPTCY PETITIONS IN PREVIOUS TEN YEARS
SWIG has not been the subject of a bankruptcy petition in the last ten years.
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