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Summit Wealth Group LLC
Form ADV Part 2A – Disclosure Brochure
Effective: March 31, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Summit Wealth Group LLC. If you have any questions about the content of this Disclosure Brochure,
please contact us at (719) 633-4033.
Summit Wealth Group, LLC is a registered investment adviser with the U.S. Securities and Exchange
Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC
or by any state securities authority. Registration of an investment advisor does not imply any specific level of
skill or training.
Additional information about the Advisor and its associated persons is available on SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335242.
Summit Wealth Group LLC
13710 Struthers Road, Suite 115, Colorado Springs, CO 80921
Phone: (719) 633-4033 | Website: www.summitwealthgroup.com
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Item 2. Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of the Advisor. The Advisor believes that communication and transparency are the foundation of its
relationship with clients and will continually strive to provide you with complete and accurate information at all
times. The Advisor encourages all current and prospective clients to read this Disclosure Brochure and discuss
any questions you may have with the Advisor.
Material Changes
The following material changes have been made since the initial filing of our disclosure brochure:
• The firm’s Chief Compliance Officer (“CCO”) has been updated.
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Item 4 – Advisory Business has been updated to include estate planning services within Summit’s
financial planning program and Family Office Services as a new investment advisory program. We have
also added information regarding the Selection of Other Advisers and information about Summit’s wrap
fee program.
Item 5 – Fees and Compensation has been updated to include information about fees associated with the
Selection of Other Advisers and Family Office Services program, and information about other costs clients
may incur associated with our investment advisory programs.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss has been updated to include
information about the firm’s methods of analysis and various risks associated with investing in general
and investing in specific products.
Item 10 - Other Financial Industry Activities and Affiliations has been updated to include information about
the firm’s use of third-party money managers and information about our relationship with SEI Investments
Management Corporation.
Item 12 - Brokerage Practices has been updated to include information about SEI and Fidelity.
Additionally, we have clarified Summit’s policy on directed brokerage arrangements, aggregation of
orders, best execution, trading by third party money managers and research and other soft dollar
benefits.
Item 14 - Client Referrals and Other Compensation has been updated to include information about
Summit’s client referral relationships, custodial relationships and associated economic benefits and
secured loan programs.
Item 15 – Custody has been updated to include information on our ability to instruct account custodians to
perform withdrawals from client accounts for the purpose of directing funds to clients as well as directing
funds to third parties with written consent from clients.
Item 20 - Additional Information has been added to the brochure and contains information about the firm’s
policy on trade errors, class action lawsuits and considerations for clients requesting rollover transactions.
Future Changes
From time to time, Summit may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually or if a material change
occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335242.
You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (719) 633-
4033.
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Item 3. Table of Contents
Item 2. Material Changes............................................................................................................................2
Item 4. Advisory Business ..........................................................................................................................4
Item 5. Fees and Compensation.................................................................................................................6
Item 6. Performance-Based Fees and Side-by-Side Management ...........................................................8
Item 7. Types of Clients ..............................................................................................................................8
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ......................................................8
Item 9. Disciplinary Information ................................................................................................................14
Item 10. Other Financial Industry Activities and Affiliations ......................................................................14
Item 11. Code of Ethics..............................................................................................................................15
Item 12. Brokerage Practices ....................................................................................................................16
Item 13. Review of Accounts .....................................................................................................................18
Item 14. Client Referrals and Other Compensation ..................................................................................18
Item 15. Custody ........................................................................................................................................19
Item 16. Investment Discretion ..................................................................................................................19
Item 17. Voting Client Securities ...............................................................................................................19
Item 18. Financial Information ...................................................................................................................19
Item 19. Requirements for State-Registered Advisers .............................................................................20
Item 20. Additional Information .................................................................................................................20
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Item 4. Advisory Business
Summit Wealth Group LLC (“Summit” or “the Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as an LLC under the laws of the State of Colorado. Summit was
founded in February 2025 and became a registered investment advisor in April 2025. Summit Wealth is owned and
operated by Summit Wealth Group, Inc.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services
provided by Summit. For more information regarding this Disclosure Brochure, please contact Scott Wilkinson, Chief
Compliance Officer, at (719) 633-4033.
Investment Management Services
Summit offers wealth management services including investment management and financial planning services to individuals,
high net worth individuals, trusts, estates, charitable organizations, businesses, and retirement plans (each referred to as a
“Client”). The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of
interest. Summit’s fiduciary commitment is further described in our Code of Ethics. For more information regarding the Code
of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
The Advisor provides wealth management services specific to the needs of each individual client. Prior to formulating any
investment allocation recommendation, we work with our clients to ascertain each client’s financial profile, demographic
information, financial goals, liquidity needs, time horizon and willingness and ability to assume risk, as well as any special
considerations relevant to the formulation of the client’s investment program. Our advisors will then determine an appropriate
target investment allocation for each client. We may use third-party managers to provide clients with certain strategies or
asset allocations, based upon the information you provide us with.
Client investment portfolios generally include a mix of individual equity securities, mutual funds, individual bonds and
exchange traded funds. The decision of which target allocation, and which type of investments are utilized will be made in
accordance with the client's stated investment objective and risk/volatility parameters. Where appropriate, clients may also
engage the Advisor to manage and/or advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans
and qualified tuition plans (i.e., 529 plans). In such cases, Summit will make recommendations on a non-discretionary basis
for the allocation of client assets among the various investment options available within the product. These assets are
generally maintained at the underwriting insurance company or custodian for the plan trustee or administrator and clients
retain responsibility for effecting trades in these accounts.
Clients may, at any time, request restrictions on or customizations to their accounts. However, we reserve the right not to
accept and/or terminate the management of a client account if we feel that the customizations or restrictions imposed by
the client, in our opinion, prevent us from managing the account in a manner that is consistent with the client’s stated
investment objectives.
Clients are advised to promptly notify the Advisor if there are changes in their financial situation or investment objectives
or if they wish to impose any reasonable restrictions upon the Advisor’s management services.
Financial Planning Services
The Advisor starts with a review of a client's financial situation which includes assets and liabilities as well as estate, tax,
and insurance needs. The Firm then employs a risk tolerance and risk capacity-focused simulation to get a detailed cash
flow analysis and proposed asset allocation. Financial planning services are typically offered independently of our
investment management services. Financial plans include, but are not limited to:
Investment planning
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• Life insurance and annuities
• Tax planning*
• Retirement planning
• College planning
• Debt/credit planning
• Estate planning services*
The Advisor may recommend clients engage the firm for additional related services as part of the financial plan, or we may
recommend other professionals to implement recommendations made by the Advisor. Clients are under no obligation to act
upon any recommendations made by the Advisor under a financial planning engagement or to engage the services of a
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third-party professional. Clients retain the absolute right to decide whether to act on such recommendations, and if they
choose to act on such recommendations, whether to engage the Firm or such professional for such services or to engage
another investment adviser or professional of their choosing, which may charge less (or more) for such services. Should a
client choose to implement the recommendations contained in the plan, the Advisor suggests the client work closely with
his/her attorney, accountant and/or insurance agent.
*Summit will act solely in its capacity as a registered investment advisor and does not provide formal legal, accounting or
tax advice. We may assist clients with tax harvesting and recommend tax planning strategies and coordinate estate planning
considerations as required for the client’s specific situation, and we will work with a client’s tax specialist to answer any
questions related to the client’s portfolio account. Clients are advised to consult with an attorney or CPA for advice related
to estate planning or tax considerations in conjunction with their work with Summit to ensure all applicable considerations
are taken into account for their specific situation.
Retirement Plan Advisory Services
Summit Wealth provides 3(21) and 3(38) retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the
needs of the Plan and Plan Sponsor.
Services generally include:
Investment Oversight
• Plan Participant Enrollment and Education Tracking
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• Ongoing Investment Recommendation and Assistance
These services are provided by Summit Wealth serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is
provided with a written description of Summit Wealth’s fiduciary status, the specific services to be rendered and all direct
and indirect compensation the Advisor reasonably expects under the engagement.
Under the Retirement Plan Advisory Services Program, Summit may serve as a discretionary investment
manager, as defined in section 3(38) of ERISA, pursuant to written authorization granted by the client to
Summit. Neither Summit nor your advisor is granted any authority to take custody or possession of any plan assets.
Family Office and Wealth Planning Services
Summit Wealth offers Family Office and Wealth Planning Services designed to help our clients organize their
financial situation and plan for the successful transfer of wealth to the next generation in the most tax-advantaged manner.
Such services generally include assistance or advice in the following areas:
• Family Continuity;
• Estate Planning and Trustee Oversight;
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Integrated Tax and Financial Planning;
• Lifestyle Management;
• Personal Assistant;
• Family Philanthropy; and
• Risk Management
Selection of Other Advisers
When appropriate, Summit will engage with a Third-Party Money Manager (“TPMM”) for asset management services.
Depending on your needs and circumstances we may recommend that you use the services of a 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 include, but are not limited to, the TPMM's performance, methods of analysis, fees, your financial
needs, investment goals, risk tolerance and investment objectives. We will monitor the TPMM(s)' performance to ensure its
management and investment style remain aligned with your investment goals and objectives.
The TPMM(s) will actively manage your portfolio or a portion of your portfolio in such cases and will assume discretionary
investment authority over your account or a portion of your account. With some TPMM programs, we will assume
discretionary authority to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem such action
appropriate.
In cases where a TPMM is engaged to manage all or a portion of your account, clients will incur certain fees or charges
imposed by third parties in connection with investments made on behalf of the Client’s account[s]. Summit Wealth’s “wrap
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fee” (as detailed further in Item 5) includes “Covered Costs” (defined as Summit’s advisory fee plus any securities transaction
fees) as part of the overall wealth management fee. Fees charged by TPMMs are separate and distinct from the wrap fee,
as are other costs as outlined in the “Other Costs That Apply to the Programs Described in This Brochure” section in Item
5. Management fees charged by TPMMs vary. Applicable TPMM fees will be disclosed to you as part of the account opening
process.
Wrap Fee Programs
Summit’s Investment Management Services program is structured as a wrap fee program. A wrap fee program is an
investment advisory program in which the client pays specified fees for portfolio management services and trade execution.
Wrap fee programs differ from non-wrap fee programs in that the asset-based fee structure for wrap programs is intended to
be largely all inclusive, whereas non-wrap fee programs typically assess trade-by-trade execution costs that are in addition
to the asset-based fees. For the investment advisory services provided to you by Summit and your advisor, Summit and your
advisor receive a portion of the wrap fees you pay when you participate in any wrap fee program through Summit.
For more information relating to Summit’s wrap fee programs, please refer to Appendix 1 of this document, titled “The Wrap
Fee Program Brochure.”
Assets Under Management
As of January 1, 2026, Summit Wealth has a total of $2,306,090,776 in discretionary assets under management.
Item 5. Fees and Compensation
In addition to the information provided in Item 4 – Advisory Business, this section provides additional details regarding
our firm’s services along with descriptions of each service’s fees and compensation arrangements. It should be noted
that lower fees for comparable service may be available from other sources. The exact fees and other terms will be
outlined in the agreement between you and the Advisor.
Investment Management Fee (also referred to as “Advisory Fee”)
Fees charged for our investment management services are charged based on a percentage of assets under
management, billed quarterly in advance, calculated based on the previous quarter end. Fees are prorated (based on
the number of days service is provided during the initial billing period) when your account is opened at any time other
than the beginning of the billing period. If investment management services commence in the middle of a billing period,
the prorated fee for the initial billing period is billed in arrears at the same time as the next full billing period’s fee is
billed.
The asset management services continue in effect until terminated. Either you or Summit may terminate the services at
any time by providing the other party with written notice. Any prepaid, unearned fees will be promptly refunded by the
Advisor to you. Fee refunds will be determined on a pro rata basis using the number of days services are actually
provided during the final period.
Fees are negotiable based on the investment adviser representative providing the services, the type of client, the
complexity of the client's situation, the composition of the client's account (i.e., equities versus mutual funds), the
potential for additional account deposits, the relationship of the client with the investment adviser representative, and
the total amount of assets under management for the client.
To have fees deducted from your account, you must authorize the qualified custodian(s) of your account to deduct fees
from your account and pay such fees directly to Summit Wealth. You should review your account statements received
from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified
custodian(s) will not verify the accuracy of the investment advisory fees deducted.
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the
Client’s account[s]. Summit Wealth includes “Covered Costs” as part of the overall wealth management fee through the
Summit Wealth Wrap Fee Program. However, securities transaction fees for Client-directed trades may be charged
back to the Client.
In addition, all fees paid to Summit Wealth for wealth management services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each
fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund
expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A
Client may be able to invest in these products directly, without the services of Summit Wealth, but would not receive
the services provided by Summit Wealth which are designed, among other things, to assist the Client in determining
which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the
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Client should review both the fees charged by the fund[s] and the fees charged by Summit Wealth to fully understand
the total fees to be paid.
Financial Planning Fees
Fees charged for our financial planning services are negotiable based upon the type of client, the services requested, the
investment adviser representative providing advice, the complexity of the client's situation, the composition of the client's
account, other advisory services provided and the relationship of the client and the investment adviser representative.
The fees for financial planning and/or consulting services are billed on a project basis. A mutually agreed upon fixed fee is
charged for financial planning services under this arrangement which will be outlined in your financial planning agreement.
There is no minimum fee required for financial planning or consulting services.
The Advisor may request a retainer to initiate financial planning and consulting services. However, we will not request
prepayment of fees more than $1,200 in advisory fees more than six months in advance.
For financial planning services performed by the Advisor under a fixed fee arrangement, you will pay the Advisor a pro-rated
fixed fee equivalent to the percentage of work completed as determined by the Advisor. In the event there is a remaining
balance of any fees paid in advance after the deduction of fees from the final invoice, those remaining proceeds will be
refunded to you.
Retirement Plan Advisory Services
Fees charged for Retirement Plan Advisory Services are negotiable based upon the services requested, the investment
adviser representative providing advice, the complexity of the client's situation, other advisory services provided and the
relationship of the client and the investment adviser representative. Fees may be based on the assets in the qualified plan(s)
or expressed as a fixed fee and will be payable either in advance or in arrears as agreed to by the client and the investment
adviser representative.
For services performed by the Advisor under a fixed fee arrangement, you will pay the Advisor a pro-rated fixed fee
equivalent to the percentage of work completed as determined by the Advisor. In the event there is a remaining balance of
any fees paid in advance after the deduction of fees from the final invoice, those remaining proceeds will be refunded to
you.
Family Office and Wealth Planning
Our fee for family office and wealth planning services is negotiable. The fee is determined at the inception of your advisory
relationship with our firm. In determining the fee, we may include the assets in accounts of your family members (e.g.,
husband, wife, dependents, and related trust accounts) for whom we are providing services. We will endeavor to value your
assets based upon a fair value methodology. Our valuation will depend on the information you provide to our firm. We may
make certain assumptions when determining fair value, including but not limited to, comparable valuations on real estate,
third party business valuations and annual inflation rates.
Depending on the family office and wealth planning services provided, our fee will be a negotiated fixed fee that is payable
in advance or arrears on a monthly, quarterly, semi-annual, or annual basis, determined in advance of services rendered
and outlined in the firm’s financial planning agreement.
You may terminate the agreement for our family office and wealth planning services, without penalty, upon written notice
within five (5) business days after entering into the advisory agreement with us. Thereafter, you may terminate investment
advisory services upon written notice to terminate. You will be responsible for any time spent by us in providing advisory
services or analyzing your situation. If you terminate investment advisory services during a quarter, you will incur a pro rata
charge for services rendered prior to the termination of the financial planning agreement. If our family office and wealth
planning fees are payable in arrears, you will be responsible for a prorated fee based on services performed prior to
termination of the agreement. If you have prepaid family office and wealth planning fees that we have not yet earned, you
will receive a prorated refund of those fees.
Other Costs That Apply to the Programs Described in This Brochure
Other costs that are charged which are not part of the “Covered Costs” include fees for portfolio transactions executed away
from the broker/dealer or custodian selected by the client, dealer markups, electronic fund and wire transfers, spreads paid
to market-makers, and exchange fees, among others. The program fees do not cover certain charges associated with
securities transactions in clients’ accounts, including (i) dealer markups, markdowns, or spreads charged on transactions in
over-the-counter securities; (ii) costs relating to trading in certain foreign securities; (iii) the internal charges and fees
assessed on collective investment vehicles, such as mutual funds and closed-end funds, UITs, ETFs, or real estate
investment trusts (“REITs”); (iv) brokerage commissions or other charges imposed by broker/dealers or entities other than
the custodian if and when trades are cleared by another broker/dealer; (v) the charge to carry tax lot information on
transferred mutual funds or other investment vehicles, postage and handling charges, returned check charges, transfer
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taxes, stock exchange fees, or other fees mandated by law; and (vi) any brokerage commissions or other charges, including
contingent deferred sales charges (“CDSC”), imposed upon the liquidation of “in-kind assets” that are transferred into a
program account.
Summit or the appointed third-party investment adviser or Money Manager will liquidate assets transferred into a program
account at their sole discretion. Clients should be aware that if they transfer in-kind assets into a program account, such
assets are subject to immediate or future discretionary liquidation and clients will incur a brokerage commission or other
charge, including contingent deferred sales charges, as applicable. Clients will also be responsible for the payment of any
taxes when liquidations of assets held in their account take place. Accordingly, clients should consult with their advisor and
tax consultant before transferring in-kind assets into a program. The broker/dealer or custodian will charge the client certain
additional and/or minimum fees in accordance with their policies.
Client will also incur applicable redemption fees when the third-party investment adviser or Money Manager to an investment
strategy determines that it is in the client’s overall interest, in conjunction with the stated goals of the investment strategy,
to divest from certain collective investment vehicles prior to the expiration of the collective investment vehicle’s minimum
holding period. Depending on the length of the redemption period, the particular investment strategy, and/or market
circumstances, a third-party investment adviser or Money Manager may be able to minimize any redemption fees when, at
their discretion, it is reasonable to allow a client to remain invested in a collective investment vehicle until expiration of the
minimum holding period.
In certain programs, the total annual account fee does not cover certain custodial fees that are charged to clients by the
custodian. Clients will be charged for specific account services, such as ACAT transfers, electronic fund and wire transfers,
and for other optional services elected by clients. Accounts will be subject to transaction-based ticket charges for the
purchase or sale of certain mutual funds depending upon the specific program account selected by the client. Similarly, the
total annual account fee does not cover certain non-brokerage-related fees, such as IRA trustee or custodian fees and tax-
qualified retirement plan account fees and annual and termination fees for retirement accounts, such as IRAs.
Item 6. Performance-Based Fees and Side-by-Side Management
The Advisor does not provide any services for performance-based fees. Performance-based fees are those based on a
share of capital gains on or capital appreciation of the assets of a client.
Item 7. Types of Clients
Summit Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, businesses, and retirement plans. Summit Wealth does not impose a minimum relationship size.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
There are a few common approaches that may be used by Summit or your advisor, individually or collectively, in the
course of providing advice to clients. As a firm, Summit does not favor any specific method of analysis over another and,
therefore, would not be considered to have one approach deemed to be a “significant strategy.” There are, however, a
few common approaches that may be used by Summit and/or your advisor in the course of providing advice to clients. It
is important to note that there is no investment strategy that will guarantee a profit or prevent loss. Research
and analysis from Summit are derived from numerous sources, including financial media companies, third-party
research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press
releases and research prepared by others.
Dollar-cost averaging (“DCA”): This is the technique of buying a fixed dollar amount of a particular investment
on a regular schedule, regardless of the share price. More shares are purchased when prices are low, and fewer
shares are bought when prices are high. DCA is believed to lessen the risk of investing a large amount in a single
investment at a higher price. DCA strategies do not prevent loss in declining markets.
Risk: Dollar cost averaging reduces market timing risk but carries the main risk of lower overall returns in a rising
market compared to a lump-sum investment. It does not eliminate investment loss, can incur higher transaction
fees, and leaves cash idle, missing out on potential gains.
Asset allocation: This is an investment strategy that aims to balance risk and reward by allocating assets among
a variety of asset classes. At a high level, there are three main asset classes— equities (stocks), fixed income
(bonds), and cash/cash equivalents—each of which has different risk and reward profiles/behaviors. Asset classes
are often further divided into domestic and foreign investments, and equities are often divided into small,
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intermediate, and large capitalization. The general theory behind asset allocation is that each asset class will
perform differently from the others in different market conditions. By diversifying a portfolio of investments among a
wide range of asset classes, advisors seek to reduce the overall volatility and risk of a portfolio through avoiding
overexposure to any one asset class during various market cycles. Asset allocation does not guarantee a profit or
protect against loss.
Risk: Asset allocation risks involve failing to meet investment goals due to improper portfolio balance, such as
taking on too much volatility, failing to outpace inflation, or experiencing correlated asset declines. Key risks also
include over-diversification (diluted returns), “panic-selling” during downturns, and costs associated with frequent
rebalancing
Technical Analysis:
This is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices
and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and
other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using
technical analysis generally believes that performance of the stock, rather than performance of the company itself,
has more to do with the company’s future stock price. It is important to understand that past performance does not
guarantee future results.
Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or
predict future price movements. Current prices of securities may reflect all information known about the security and day-
to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable
degree of accuracy.
Fundamental Analysis: Involves analyzing individual companies and their industry groups, such as a company's
financial statements, details regarding the company's product line, the experience and expertise of the company's
management, and the outlook for the company and its industry. The resulting data is used to measure the true value of
the company's stock compared to the current market value.
Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide
an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new
information, utilizing fundamental analysis may not result in favorable performance.
Cyclical Analysis: A type of technical analysis that involves evaluating recurring price patterns and trends.
Economic/business cycles may not be predictable and may have many fluctuations between long-term expansions and
contractions.
Risk: The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical
analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be
affected by these changing trends.
Quantitative analysis: This is an analysis technique that seeks to understand behavior by using complex
mathematical and statistical modeling, measurement, and research. By assigning a numerical value to variables,
quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real-world
events, such as changes in share price.
Risk: Quantitative analysis carries risks centered on model failure, data inaccuracy, and over-reliance on past
patterns. Key dangers include overfitting models to historical data, inaccurate or incomplete data sets, high
implementation costs, and the inability of algorithms to adapt to sudden, unprecedented market shifts or qualitative
events
Qualitative analysis: This securities analysis uses subjective judgment based on nonquantifiable information, such
as management expertise, industry cycles, strength of research and development, and labor relations. This type of
analysis technique is different from quantitative analysis, which focuses on numbers. The two techniques, however,
are often used together.
Risk: Qualitative analysis relies on non-numerical data (management quality, brand strength, industry trends),
introducing risks of extreme subjectivity, cognitive bias, and inconsistency. Because it lacks hard, measurable metrics,
this approach can lead to misjudging risk severity, overlooking data, and difficulty in prioritizing threats.
Tax harvesting: Summit, when deemed appropriate, performs tax harvesting with the intention to offset gains or
losses in the client’s account to reduce tax liabilities.
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Risk: Tax-loss harvesting carries risks of triggering IRS wash-sale rules (negating tax benefits), incurring higher
transaction costs, and creating portfolio tracking errors. Reinvesting proceeds may lead to lower performance or
market timing risks, while lower future tax rates could reduce the strategy's overall value
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee
that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or
insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future performance.
Our investment strategies and advice varies depending upon each client's specific financial situation. As such, we
determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial
information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the
composition of your portfolio. It is important that you notify us immediately with respect to any material changes to your
financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or
employment status.
Recommendation of particular types of securities: Summit and your advisor will recommend various types of
securities and do not primarily recommend one particular type of security over another since each client has different
needs and different tolerance for risk. Each type of security has its own unique set of risks, and it would not be possible to
list all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. In
very general terms, however, the higher the anticipated return of an investment, the higher the risk of loss associated with
the investment. Descriptions of the types of securities Summit and your advisor may recommend to you and some of their
inherent risks are provided below:
Money market funds: A money market fund is technically a security, and, as such, there is a risk of loss of
principal, though it is rare. In return for this risk, you should earn a greater return on your cash than you would
expect from a Federal Deposit Insurance Corporation (“FDIC”) insured savings account (money market funds are
not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will
earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive
outcome. If it goes down, however, and you earn less than you expected to, you may end up needing more cash. A
final risk you are taking with money market funds has to do with inflation. Because money market funds are
considered to be safer than other investments, long-term average returns on money market funds tend to be less
than long-term average returns on riskier investments. Over long periods of time, inflation can eat away at your
returns.
Municipal securities: Although generally thought of as safe, municipal securities can have significant risks
associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the
bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to
mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to
replace it with a bond of equal character paying the same amount of interest or yield to maturity.
Bonds: Also known as corporate debt securities, bonds are typically safer investments than equity securities, but
their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, when
the bond is set to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not
be possible to replace it with a bond of equal character paying the same rate of return.
Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as “equities” or
“stocks”). In very broad terms, the value of a stock depends on the financial health of the company issuing it. Stock
prices, however, can be affected by many other factors, including, but not limited to, the class of stock (e.g.,
preferred or common), the health of the market sector of the issuing company, and the overall health of the
economy. In general, larger, more well-established companies (i.e., large-caps) tend to be safer than smaller start-
up companies (i.e., small-caps), but the mere size of an issuer is not, by itself, an indicator of the safety of the
investment.
Margin Transactions: A securities transaction in which an investor borrows money to purchase a security, in which
case the security serves as collateral on the loan. The primary risk of margin transactions is if the value of the
shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion
of the stock to maintain the margin requirements of the account. This is known as a “margin call.” An investor’s
overall risk includes the amount of money invested plus the amount that was loaned to them.
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Alternatives: A financial asset that does not fall into one of the conventional investment categories. Alternative
investments can include private equity or venture capital, hedge funds, managed futures, art and antiques, commodities,
and derivatives contracts. Real estate is also often classified as an alternative investment. Alternatives are less liquid
than many other investments, with some private funds and real estate investments having set periods in which the
assets invested cannot be redeemed and that investment cannot be sold. There is also a higher risk of loss of principal
with alternative assets, in part due to the illiquidity of these types of investments.
Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which invests in real estate
and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or
privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable
income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong or the
REIT must either dip into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After
2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically.
The credit markets are no longer frozen, but banks are demanding, and getting, harsher terms to re-extend REIT debt.
Some REITs may be forced to make secondary stock offerings to repay debt, which will lead to additional dilution of the
stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends.
Real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and
increasing concerns about the future long-term variability of stock and bond returns. In fact, real estate is known for its
ability to serve as a portfolio diversifier and inflation hedge. The asset class still bears a considerable amount of market
risk, however. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall
economy. In addition to employment and demographic changes, real estate is influenced by changes in interest rates
and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes
in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for
property concentrations by area or property type. Because property returns are directly affected by local market basics,
real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes
and bear additional risk by being too influenced by local or sector market changes.
Private Placements: A private placement (non-public offering) is an illiquid security sold to qualified investors and
are not publicly traded nor registered with the Securities and Exchange Commission. Private placements generally
carry a higher degree of risk due to illiquidity. Most securities that are acquired in a private placement will be restricted
securities and must be held for an extended amount of time and therefore cannot be sold easily. The range of risks is
dependent on the nature of the partnership and are disclosed in the offering documents.
Mutual funds and ETFs: Mutual funds and ETFs are professionally managed collective investment systems that pool
money from many investors and invest in stocks, bonds, short term money market instruments, other mutual funds,
other securities, or any combination thereof. The fund will have a manager who trades the fund’s investments in
accordance with the fund’s investment objective. Although mutual funds and ETFs generally provide diversification,
risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in
small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (e.g., equities) rather than balancing the fund with different types of securities. ETFs differ
from mutual funds in that they can be bought and sold throughout the day like stock and their price can fluctuate
throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also,
while some mutual funds are “no load,” meaning there’s no fee to buy into or sell out of the fund, other types of
mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be “closed-end” or “open-
end.” Open-end mutual funds continue to allow new investors indefinitely, whereas closed-end funds have a fixed
number of shares to sell, which can limit their availability to new investors. ETFs are investment companies that are
usually classified as open-end or UITs. Some ETFs, particularly those that invest in commodities, are not registered
as an investment company and may be closed and liquidated at the discretion of the issuing company. Active ETFs
are different from traditional passive index ETFs in that there is a portfolio manager who makes buy/sell decisions on
the underlying holdings. Certain ETF sponsors also offer actively managed mutual funds with different fees and
expenses even though they have the same or substantially similar objective, strategies, and holdings. The impact of
such fees and expenses will vary depending on whether you invest in an ETF or mutual fund based on the size of
your initial investment, the length of time you hold the investment, and other factors. In certain situations, mutual fund
fees and expenses you pay will be more than in a significantly similar ETF.
Variable annuities: A variable annuity is a form of insurance where the seller or issuer (typically an insurance
company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate payment of a lump
sum (single-payment annuity) or a series of regular payments (regular-payment annuity). The payment stream from
the issuer to the annuitant has an unknown duration based principally upon the date of death of the annuitant. At this
point, the contract will terminate, and the remainder of the funds accumulated will be forfeited unless there are other
annuitants or beneficiaries in the contract. Annuities can be purchased to provide an income during retirement. Unlike
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fixed annuities that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable
annuities pay amounts that vary according to the performance of a specified set of investments, typically bond and
equity mutual funds. Many variable annuities typically impose asset-based sales charges or surrender charges for
withdrawals within a specified period. Variable annuities may impose a variety of fees and expenses, in addition to
sales and surrender charges, such as mortality and expense risk charges, administrative fees, underlying fund
expenses, and charges for special features, all of which can reduce the return.
Limited partnerships: A limited partnership is a financial affiliation that includes at least one general partner and a
number of limited partners. The partnership invests in a venture, such as real estate development or oil exploration,
for financial gain. The general partner has management authority and unlimited liability. The general partner runs the
business and, in the event of bankruptcy, is responsible for all debts not paid or discharged. The limited partners have
no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided
between general and limited partners according to an arrangement formed at the creation of the partnership. The
range of risks is dependent on the nature of the partnership and disclosed in the offering documents if privately
placed. Publicly traded limited partnerships have similar risk attributes to equities; however, like privately placed
limited partnerships, their tax treatment is under a different tax regime from equities. You should speak to your tax
advisor in regard to their tax treatment.
Options contracts: Options are complex securities that involve risks and are not suitable for everyone. Option
trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you invest
only in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or
sell an underlying asset at a specific price on or before a certain date (i.e., the expiration date). The two types of
options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period of
time. Calls are similar to having a long position on a stock. Buyers of calls hope that the stock will increase
substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a
specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the price
of the stock will fall before the option expires. Selling options is more complicated and can be even riskier. Option
trading risks are closely related to stock risks, as stock options are a derivative of stocks.
Private Equity: Private equity investments are speculative and involve significant risks. These investments offer
limited diversification, use leverage, and have limited liquidity. The investment timeline for private equity can be a
decade or more. Some issuers or general partners may penalize limited partners who redeem before holding units for
a specified amount of time or may disallow redemptions entirely.
Structured products: A structured product is generally a prepackaged investment strategy based on derivatives,
such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign
currencies, and, to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates
thereof. In addition to a fixed maturity, they have two components: a note and a derivative. The derivative component
is often an option. The note provides for periodic interest payments to the investor at a predetermined rate, and the
derivative component provides for the payment at maturity. Some products use the derivative component as a put
option written by the investor that gives the buyer of the put option the right to sell to the investor the security or
securities at a predetermined price. Other products use the derivative component to provide for a call option written
by the investor that gives the buyer of the call option the right to buy the security or securities from the investor at a
predetermined price. A feature of some structured products is a “principal guarantee” function, which offers protection
of principal if held to maturity. These products are not always FDIC insured, however; they may only be insured by the
issuer and, thus, have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with
the issuing company. Investing in structured products involves several risks, including, but not limited to, fluctuations
in the price, level, or yield of underlying instruments; interest rates; currency values; and credit quality. It also involves
the risk of substantial loss of principal, limits on participation in any appreciation of the underlying instrument, limited
liquidity, credit risk of the issuer, conflicts of interest, and other events that are difficult to predict.
Leveraged/inverse ETFs, ETNs, and mutual funds: Leveraged products seek to deliver multiples (e.g., 2x) of the
performance of the index or benchmark they track. Some leveraged products are inverse or short funds, meaning
they seek to deliver the opposite of the performance of the index or benchmark they track. They can track broad
indices, sector specific, or are linked to commodities or currencies. Leveraged and inverse products have unique
characteristics and can be riskier than traditional ETFs, ETNs, and mutual funds. Most leveraged and inverse
products “reset” daily, meaning they are designed to achieve their stated objectives on a daily basis. To accomplish
these objectives, these products may not be diversified and use a range of strategies, including swaps, future
contracts, and other derivatives. Due to fund expenses, continuous resetting of returns and other factors, these
products may not be able to replicate the index or benchmark they are tracking, also known as tracking error. In
addition, for leveraged products, compounding of the returns can produce a divergence over time, which could be
amplified in a volatile market with large positive and negative swings.
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Value-based investing risk: Value-based investing is also sometimes referred to as “environmental, social, and
governance (ESG) investing,” “socially responsible investing,” “faith-based investing” or “sustainable investing.” These
types of strategies may seek to achieve value-based outcomes to achieve exposure to particular goals or themes,
and/or to screen out certain companies and industries. Advisors may consider social or environmental goals,
including but not limited to corporate governance structures and international, domestic or industry agreements, when
determining which securities to include in a portfolio. These investment strategies may reduce or increase a portfolio’s
exposure to certain companies or industries and the portfolio may forego certain investment opportunities as a result.
Investing in value-based investments or strategies may underperform the market as a whole or underperform other
strategies that employ a different type of focus or screening methodology. Fund managers, portfolio managers,
advisors, and investors likely define the criteria for a particular value-based goal, such as ESG, differently. Review
fund prospectuses and other materials to gain an understanding of how the term is being used in connection with
their investment offerings.
Direct Indexing risk
We offer direct indexing strategies in which client accounts invest directly in many or all of the individual securities
comprising a specified market index, rather than investing in a mutual fund or exchange-traded fund that tracks the
index. Portfolios are typically managed in separately managed accounts and may be customized to reflect client
preferences (e.g., tax management, ESG considerations, or security exclusions). Direct indexing may allow for
individual security-level tax-loss harvesting and other customization; however, these benefits are not guaranteed and
depend on the client’s individual circumstances, including tax status and account size.
Direct indexing involves market risk and the risk of loss of principal. Account performance may deviate from the
referenced index due to tracking error, transaction costs, rebalancing, tax-management activity, cash holdings,
account restrictions, or customization. Tax-loss harvesting strategies may not produce the intended tax benefits and
could increase transaction costs or alter portfolio exposures. Excluding certain securities, sectors, or industries may
reduce diversification and increase volatility. The strategy relies on portfolio management systems and trading
platforms, which are subject to operational and technology risks. Smaller account sizes may experience greater
tracking error and reduced diversification.
Clients should carefully consider whether direct indexing is appropriate in light of their investment objectives, financial
circumstances, tax situation, and risk tolerance
Other Risk Considerations
When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks,
each of which may affect the probability and magnitude of any potential losses. The following risks are not all-inclusive
but should be considered carefully by a prospective client before retaining our services.
Market risk: The prices of, and the income generated by, the common stocks, bonds, and other securities you own may
decline in response to certain events taking place around the world, including those directly involving the issuers;
conditions affecting the general economy; overall market changes; local, regional, or global political, social, or economic
instability; governmental or governmental agency responses to economic conditions; currency, interest rate, and
commodity price fluctuations.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack
of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income
or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer's
securities held by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in inflation
and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a
client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the
value of many types of fixed income investments to decline.
Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for
example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If
you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of outliving your
savings. This risk is particularly relevant for people who are retired or are nearing retirement.
Risk of investing outside the U.S.: Investments in securities issued by entities based outside the U.S. are often
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subject to the risks described above, to a greater extent.
Pledging assets: Pledging assets in an account to secure a loan involves additional risks. The bank holding the loan
has the authority to liquidate all or part of the securities at any time without prior notice in order to maintain required
maintenance levels, or to call the loan at any time, and this may cause you to sell assets and realize losses in a
declining market. In addition, because of collateral requirements imposed by the bank, investment decisions for the
account may be restricted. These restrictions, or a forced liquidation, may interfere with your long-term investment goals
and/or result in adverse tax consequences.
Tax considerations: Our strategies and investments may have unique and significant tax implications. Unless
specifically agreed otherwise, and in writing, however, tax efficiency is not our primary consideration in the management
of your assets. Regardless of your account size or any other factors, it is strongly recommended that you consult a tax
professional regarding the investment of your assets. Custodians and broker/dealers must report the cost basis of
equities acquired in client accounts. Your custodian will default to average cost for mutual fund positions and the first-in,
first-out (“FIFO”) accounting method for calculating the cost basis of your equity investments. You are responsible for
contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes
another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert your
account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will
need to be made before trades settle; the cost basis method cannot be changed after settlement.
Investments may also be affected by currency controls; different accounting, auditing, financial reporting, disclosure,
and regulatory and legal standards and practices; expropriation (occurs when governments take away a private
business from its owners); changes in tax policy; greater market volatility; different securities market structures; higher
transaction costs; and various administrative difficulties, such as delays in clearing and settling portfolio transactions or
in receiving payment of dividends. These risks may be heightened in connection with investments in developing
countries. Investments in securities issued by entities domiciled in the U.S. are also subject to many of these risks.
Any of the common risks described above could adversely affect the value of your portfolio and account performance,
and you can lose money. Even though these risks exist, Summit and your advisor will still earn the fees and other
compensation described in this Brochure. Clients should carefully consider the risks of investing and the potential that
they may lose principal while Summit and your advisor continue to earn fees and other forms of compensation.
Your investments are not bank deposits and are not insured or guaranteed by the FDIC or any other governmental
agency, entity, or person, unless otherwise noted and explicitly disclosed as such, and as such may lose value.
Item 9. Disciplinary Information
The Advisor is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of its
advisory business or the integrity of management. Summit does not have any required disclosures in this Item.
Item 10. Other Financial Industry Activities and Affiliations
Broker Dealer Affiliation
Some of our advisory representatives are also registered representatives of Purshe Kaplan Sterling Investments (“PKS”) a
registered broker/dealer, member FINRA/SIPC. If you choose to implement your all or a portion of your financial plan
through PKS, commissions will be earned by your advisory representative in addition to any fees paid for advisory
services. In addition, where applicable, the advisory representative is entitled to a portion of the internal expense fees
(such as 12b-1 fees) charged by mutual funds.
Insurance Agency Affiliations
Certain Advisory Persons are also licensed insurance professionals. As an insurance professional, an Advisory Person
will receive customary commissions and other related revenues from the various insurance companies whose products
are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset advisory fees. This causes a conflict of interest in recommending insurance
products given the additional compensation that will be received by Summit and/or the Advisory Person. Clients are
under no obligation to implement any recommendations made by Advisory Persons or the Advisor and may use the
agent of their choice to purchase insurance products.
Use of Third-Party Money Managers (“TPMMs”)
The Advisor may implement all or a portion of a client’s investment portfolio with one or more TPMMs. In such cases,
the Advisor does not receive any additional compensation from TPMMs. The Advisor will only earn its wealth
management fee as described in Item 5.A.
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Sub-Advisory Agreement with SEI Investments Management Corporation
Summit has a Sub-Advisor Agreement with SEI Investments Management Corporation (“SIMC”), a registered
investment advisor affiliated with SEI Private Trust Company (“SPTC”) located in Oaks, Pennsylvania. This agreement
allows Summit to allocate client assets for participation in SIMC’s Sub-Advised Program. Summit is responsible to
determine whether participation in the program is appropriate for our clients.
Under the program, SIMC provides discretionary investment management services to Summit and makes available
investment strategy models of SIMC or investment managers appointed by SIMC. These models seek to achieve
particular investment goals and are not tailored to individual clients. Summit may allocate client assets to one or more
of SIMC’s models which match a client’s objectives. SIMC then invests the allocated funds in accordance with the
selected models as updated from time to time by SIMC or investment managers appointed by SIMC. In most cases,
SIMC will implement those models and execute transactions; in others, the investment manager will do so.
SIMC charges Summit an investment management fee for participation in the program. SIMC’s investment management
fee is paid for by Summit, as are associated transaction costs including without limitation execution charges imposed
by unaffiliated broker/dealers or exchanges, wire transfer fees, auction fees, and transfer taxes.
Clients with assets allocated to the program are subject to certain risks, including the investment manager implementing
its model for its other accounts before implementing it for our clients. In that case, securities may be traded by our
clients at prices different than those obtained by the manager’s other clients. The risk of price deviations is greater for
large orders and thinly traded securities. Additionally, performance of our client’s investments in a model may deviate
from the performance of other accounts in such models or those managed by SIMC or the investment manager.
Fund and ETF models-based program
Summit may choose to invest its clients’ assets into model portfolios of mutual funds and exchange-traded funds
(“ETFs”) created by SIMC. This includes the SEI Asset Allocation Models that consist of allocations to SEI Funds and
SEI ETFs and the Independent Funds Models Program which consists of model portfolios of allocations to certain
families of third-party mutual funds or ETFs.
Under the SEI Asset Allocation Models and the Independent Funds Models Program, SIMC provides non-discretionary
services to Summit through the publication of investment models consisting of allocations to these different funds (i.e.,
SEI Funds, SEI ETFs, third-party funds, or third-party ETFs) allocated to the models. Specifically, SIMC: (1) makes
available the models, developed and periodically updated by SIMC designed to achieve the model’s stated investment
objective or goal based upon SIMC’s capital market assumptions and any other criteria that SIMC, in its sole discretion,
determines is relevant; and (2) periodically publishes for consideration by firm revisions to a model’s percentage asset
allocations among the underlying SEI Funds, SEI ETFs, third-party funds, or third-party ETFs, or adds, removes, or
otherwise changes the individual SEI Funds, SEI ETFs, third-party funds, or third-party ETFs underlying an existing
model.
SIMC and its affiliates earn fees from the SEI Funds and SEI ETFs, which costs are indirectly borne by Clients invested
in these models. As a result, SIMC does not charge Summit or its clients a direct fee for the use of the SEI Asset
Allocation Models, although SEI Private Trust Company (“SPTC”), the custodian to the Client and an affiliate of SIMC,
will charge a custodial platform fee on Client assets invested in SEI ETF products. In the Independent Funds Model
Program, SIMC and its affiliates (including SPTC) charge direct fees that will be assessed to Clients.
Item 11. Code of Ethics
The Advisor is committed to providing investment advice with the utmost professionalism and integrity. Our firm strives to
identify, manage and/or mitigate conflicts of interest and has adopted policies, procedures and oversight mechanisms to
address conflicts of interest. We have adopted a Code of Ethics that emphasizes our fiduciary obligation to put client
interests first and is designed to ensure personal securities transactions, activities, and interests of employees will not
interfere with the responsibilities to make decisions in the best interest of clients. All supervised persons must acknowledge
and comply with our Code of Ethics.
Employee Personal Trading
The Advisor and persons associated with The Advisor (“Associated Persons”) are permitted to buy or sell securities that
it also recommends to clients consistent with The Advisor’s policies and procedures. The Advisor has adopted a code
of ethics that sets forth the standards of conduct expected of its associated persons and requires compliance with
applicable securities laws (“Code of Ethics”). The Advisor’s Code of Ethics contains written policies reasonably designed
to prevent the unlawful use of material non-public information by the Advisor or any of its associated persons. The
Code of Ethics also requires that certain of the Advisor’s personnel (called “Access Persons”) report their personal
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securities holdings and transactions and obtain pre-approval of certain investments such as initial public offerings and
limited offerings.
The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees
of the Advisor 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. Under the Code of Ethics, certain
classes of securities have been designated as exempt transactions, based upon a determination that these would materially
not interfere with the best interest of the Advisor’s clients. Nonetheless, because the Code of Ethics would permit employees
to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client
in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably
prevent conflicts of interest between the Advisor and its clients. Certain affiliated accounts may trade in the same securities
with client accounts on an aggregated basis when consistent with the Advisor’s obligation of best execution. In such
circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total
average price. The Advisor’s will retain records of the trade order (specifying each participating account) and its allocation,
which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the
initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market
instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other
high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money
market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds.
This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit
transactions by Access Persons to be completed without any appreciable impact on the markets of such securities.
Therefore, under certain limited circumstances, exceptions may be made to the policies stated above. Clients and
prospective clients may contact the Advisor to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
Summit does not maintain custody of client assets, though we may be deemed to have custody if a client grants us
authority to debit fees directly from their account (see Item 15 below). Assets will be held with a qualified custodian,
which is typically a bank, trust company or broker-dealer. Summit generally recommends that investment accounts be
held in custody by The SEI Private Trust Company. (“SPTC”) or Fidelity Brokerage Services, LLC. (“Fidelity”).
SPTC: SPTC is a limited purpose federally registered savings association supervised by the Office of the Comptroller
of the Currency. Summit is independently owned and operated and not affiliated with SPTC. SPTC will hold your assets
and buy and sell securities when Summit or you instruct them to. When we recommend that you use SPTC as custodian,
you will decide whether to do so and open your account with SPTC by entering into an account agreement directly with
them.
Fidelity: – Access to the Fidelity platform is provided at no charge to Summit. The Fidelity platform includes brokerage,
custody, administrative support, record keeping, technology, and related services designed to support registered
investment advisors like Summit in serving Clients. These services are intended to serve the best interests of the
Advisor’s Clients. Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain
securities transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction
fees and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered
discounted from customary retail commission rates. However, the commissions and transaction fees charged by Fidelity
may be higher or lower than those charged by other custodians and broker dealers.
Summit recommends the services of SPTC or Fidelity based on a number of factors including financial strength,
reputation, execution, pricing, responsiveness, fees, research, and other services.
Directed Brokerage
Summit does not engage in or permit directed brokerage arrangements.
Aggregation of Orders
Summit advisors may use the firm’s model portfolios, manage client accounts independently, or both. In cases where client
accounts are managed independently, transactions in such accounts will generally be executed independently rather than
being aggregated or “blocked.” However, when Summit and its advisors believe it is appropriate, feasible, or beneficial to
do so, however, they will aggregate the purchase or sale of multiple clients’ securities together to help facilitate best
execution and provide each client with the same execution price. Aggregating multiple client orders together is particularly
useful when Summit or your advisor is using model portfolio management strategies.
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When Summit and its advisors aggregate orders, they do so in a manner reasonably designed to ensure that no participating
client obtains a more favorable execution price than other clients. When Summit or your advisor aggregates multiple client
orders, transactions are typically allocated pro-rata to the participating client accounts in proportion to the size of the order
placed for each account. Summit or your advisor may increase or decrease the amount of securities allocated to each
account, if necessary, to avoid holding odd lot or small numbers of shares for particular clients. Additionally, if Summit is
unable to fully execute an aggregated order and determines it would be impractical to allocate a small number of securities
among the accounts participating in the transaction on a pro-rata basis, Summit will allocate such securities in a manner
determined in good faith to be fair and equitable to the clients involved. Clients should understand that in instances where
their assets are maintained at multiple custodians, orders cannot be blocked.
Best Execution
Summit seeks to obtain, through its clearing firms, the best combination of net price and execution when effecting brokerage
transactions for client accounts. A number of judgmental factors are used by Summit in analyzing overall trade execution
quality and its selection of clearing firms. Such factors include, but are not necessarily limited to:
• The nature of the securities being purchased or sold
• Access to market participants, which may be limited due to thin or no trading activity for a particular security
• The size of the transaction
• The speed of the transaction
• The size of the spread
• The ability to obtain price improvement
• The desired timing of the transaction
• The activity existing and anticipated in the market for the particular security
• The execution, clearance, and settlement capabilities of the executing broker/dealer
• The overall trade execution quality of the executing broker/dealer as compared with other leading executing
broker/dealers
• The executing broker/dealer’s financial stability and industry reputation
• The efficiency and reliability of the executing broker/dealer’s systems and technologies
• The quality of Summit’s access to the executing broker/dealer’s senior management and the executing
broker/dealer’s responsiveness to Summit
• The extent to which Summit can leverage the strength of its relationship with the clearing broker/dealer to improve
overall service and technology
Trading by Third Party Money Managers (“TPMMs”)
In the event a TPMM is selected by Summit to manage your account, clients should be aware that TPMM is free to trade
the account using the broker-dealer of its choice. In some cases, a TPMM may need to effect a transaction in a security
with a broker-dealer other than the custodian with which your account is held (commonly referred to as “stepping out” a
trade). In such cases, brokerage commissions, markups and markdowns, and other charges for those transactions are
generally charged to the client by the executing broker/dealer, whereas the wrap fees assessed by Summit cover the costs
of brokerage commissions and other charges on transactions. In such cases, the net purchase or sale price reflected on
trade confirmations and brokerage statements provided by the custodian for those trades will include the cost of brokerage
commissions or dealer markups or markdowns charged by the executing broker and paid for by the client. Due to the
additional costs often incurred by clients when TPMMs engage in step-out trades, TPMMs who elect to engage in step-out
trades will generally cost clients more than TPMMs who don’t engage in step-out trades.
In the selection of brokers/dealers to effect transactions, the TPMM is expected to comply with best-execution obligations
and consider all relevant factors, including, but not limited to, the speed and efficiency, execution quality, commission rates,
and responsiveness of the executing broker/dealer. The TPMM may select brokers/dealers that provide the TPMM research
or other transaction-related services and may cause the client to pay such brokers/dealers commissions or other
transaction-related fees in excess of those that other brokers/dealers may have charged. Such research and other services
may be used for the benefit of the TPMM’s accounts where permitted by rule or regulation. TPMMs who specialize in fixed
income, international, small-cap, or ETP disciplines may be more likely to trade away due to market conditions, liquidity,
exchange availability, or other factors they consider relevant in satisfying their best-execution obligations to clients.
Clients should understand that Summit does not evaluate whether a TPMM is meeting their best-execution obligations to
clients when trading away, as it is not a party to those transactions and is not able to negotiate the prices obtained or
transaction-related charge(s) assessed between the TPMM and the executing broker/dealer. Summit does not discourage
or restrict a TPMM’s ability to trade away.
Research and Other Soft-Dollar Benefits
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Summit does not use commissions to pay for research and brokerage services (i.e., soft-dollar transactions).
Item 13. Review of Accounts
The Advisor monitors clients’ portfolios as part of an ongoing process while regular account reviews are conducted on at
least an annual basis for clients. For those clients to whom the Advisor provides financial planning and/or consulting
services, reviews are conducted on an “as needed” basis. All investment advisory clients are encouraged to discuss their
needs, goals, and objectives with the Advisor and to keep the Advisor informed of any changes thereto. The Advisor contacts
ongoing investment advisory clients at least annually to review its previous services and/or recommendations and to
discuss the impact of any changes in the client’s financial situation and/or investment objectives.
Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary account
statements directly from the broker-dealer or custodian for the client accounts. Clients should compare the account
statements they receive from their custodian with any reports they receive from the Advisor. In the event of a discrepancy,
the custodian’s account statement will prevail. Those clients to whom the Advisor provides financial planning and/or
consulting services will receive reports from the Advisor summarizing its analysis and conclusions upon request and as
otherwise agreed to in writing by the Advisor.
Item 14. Client Referrals and Other Compensation
Summit is required to disclose any relationship or arrangement where it receives an economic benefit from a third party
(non-client) for providing advisory services. In addition, The Advisor is required to disclose any direct or indirect
compensation that it provides to any person who is not a supervised person for client referrals.
Summit maintains a program that allows us to enter into written agreements with certain unaffiliated investment advisers,
financial institutions and other professionals (such as CPAs, attorneys, etc.) to compensate them for referring clients to
us. We will pay these individuals (referred to as “solicitors”, “promoters” or “endorsers”) a percentage of the advisory fee
that you pay us if you become a client of ours as a result of their referral.
The payments we make to a solicitor, promoter or endorser will not result in an increase in the amount of the advisory fee
that the referred client will pay.
Our solicitation or referral arrangements will comply with applicable laws that govern:
the nature of the services provided
the fees to be paid
•
•
• disclosure of solicitor arrangements to clients
•
client consents, as required
Custodial Relationships and Economic Benefits
As noted previously in this brochure, Summit recommends that clients maintain their assets with qualified custodians,
including SEI and Fidelity. In connection with the establishment and operation of our advisory business, we received
transition assistance and other economic benefits from these custodians. These benefits include financial support,
reimbursement of expenses, access to electronic systems that assist us in the management of client accounts, as well as
research, software and other technology that provide access to client account data (such as trade confirmations and account
statements), pricing information and other market data, trade execution and client reporting capabilities, consulting services,
and other resources intended to assist with the launch and growth of our firm.
The receipt of these benefits creates a conflict of interest because it provides us with a financial incentive to recommend
that clients custody their assets with SEI and/or Fidelity and to maintain client assets with those custodians. In some cases,
these arrangements may be conditioned on maintaining a certain level of client assets or business with the custodian. As a
result, our recommendation of SEI or Fidelity is not based solely on the interest of our clients in receiving the most favorable
custody services or execution but is also influenced by the economic benefits we receive. We seek to mitigate this conflict
by evaluating custodians based on factors such as service quality, execution capability, technology, and cost, and by acting
in the best interests of our clients at all times. Clients should consider this conflict of interest when selecting a custodian.
Secured Loan Program
Summit offers a program that enables clients to collateralize certain accounts to obtain secured loans through Goldman
Sachs Bank. The program presents conflicts of interest. Summit and its advisors have an interest in continuing to receive
investment advisory fees, which creates an incentive to recommend that clients maintain their assets at Summit and use
the program to access funds rather than liquidate assets in the account. Because Summit and its advisors are compensated
primarily through advisory fees paid on client accounts, there is an incentive to manage an account serving as collateral for
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a loan in a manner that will preserve sufficient collateral value to support the loan and avoid a bank call. Clients are not
required to use the program and can work directly with other banks to negotiate loan terms or obtain other financing
arrangements.
Item 15. Custody
When you establish a relationship with our firm for investment management services, your assets will be maintained by a
bank, broker-dealer, mutual fund transfer agent or other such institution deemed a ‘qualified custodian’ by the SEC. We rely
on the custodian to price and value assets, execute and clear transactions, maintain custody of assets in your account and
perform other custodial functions. The Advisor does not maintain physical possession of any client account assets. Clients’
assets must be held by a bank, broker dealer, mutual fund transfer agent or other such institution deemed a qualified
custodian. We utilize SEI and Fidelity as qualified custodians for client accounts.
Nevertheless, the Advisor is deemed to have custody, pursuant to Rule 206(4)-2 of the Investment Advisers Act of 1940,
as amended, due to its authority over certain accounts deduct advisory fees from Client accounts and to distribute assets
subject to a third-party standing letter of authorization. The firm relies on the seven requirements outlined in the SEC’s No-
Action Letter to the Investment Advisers Associated, dated February 21, 2017, which provides relief from an annual surprise
custody examination by an independent public accountant.
You will receive monthly and/or quarterly account statements directly from the qualified custodian. The Advisor may also
provide you with written quarterly performance reports for your account. We urge you to carefully review your account
statements and compare the account balances with the balances reflected on any performance report you may receive from
our firm for accuracy. Balances on our reports may vary slightly from custodial statements due to differences in accounting
procedures, reporting dates, valuation methodologies of certain securities or other operational factors. You should promptly
notify us if you do not receive account statements from your custodian at least quarterly or if you believe the information on
your account statements is inaccurate.
Summit has the ability to instruct account custodians on certain transfers or withdrawals from your account(s) at the
custodian. Specifically, Summit may instruct custodians to distribute assets via check to your name and address of record
on file with the custodian. With your written permission on file with the custodian, Summit may transfer assets to a bank
account or account held at another custodian provided the account is in your name. All third-party distributions from account
custodians must be signed by you. Summit does not have authority to instruct custodians to distribute assets from your
account at the custodian to a third-party.
Item 16. Investment Discretion
The Advisor substantially always has discretion over the selection and amount of securities to be bought or sold in
Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by
the Advisor. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such
authority will be evidenced by the Client’s execution of Summit’s Investment Advisory Agreement (“IAA”) containing all
applicable limitations to such authority. All discretionary trades made by the Advisor will be in accordance with each
Client’s investment objectives and goals.
Typically, under third-party investment management arrangements, the third-party investment manager exercises discretion
in the management of your account. All securities transactions are selected and executed by that manager. We do not
manage or obtain discretionary authority over the assets in those accounts. In such cases, you will grant discretion to the
third party investment manager by executing an agreement directly with the manager. You may, however, grant Summit the
discretionary authority to hire and fire such third-party managers on your behalf.
Item 17. Voting Client Securities
Summit Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly
from the Custodian. At your request, we may offer you advice regarding corporate actions and the exercise of your
proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a
shareholder.
Item 18. Financial Information
Neither Summit Wealth, nor its management, have any adverse financial situations that would reasonably impair the ability
of Summit Wealth to meet all obligations to its Clients. Neither Summit Wealth, nor any of its Advisory Persons, have been
subject to a bankruptcy or financial compromise. Summit Wealth is not required to deliver a balance sheet along with this
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Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six
months or more in the future.
Item 19. Requirements for State-Registered Advisers
Summit is registered with the Securities and Exchange Commission and is not required to respond to this item.
Item 20. Additional Information
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been
in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade,
adjusting an allocation, and/or reimbursing the account.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to
participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your
behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's
retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If
you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth
in the agreement you executed with our firm. This practice presents a conflict of interest because persons providing
investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based
compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete
the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed
by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees
can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to
complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and
benefits of:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer's retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage you to speak with
your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider
before you do so:
• Determine whether the investment options in your employer's retirement plan address your needs or whether you
might want to consider other types of investments.
• Employer retirement plans generally have a more limited investment menu than IRAs.
• Employer retirement plans may have unique investment options not available to the public such as employer
securities, or previously closed funds.
• Your current plan may have lower fees than our fees.
•
If you are interested in investing only in mutual funds, you should understand the cost structure of the share
classes available in your employer's retirement plan and how the costs of those share classes compare with those
available in an IRA.
• You should understand the various products and services you might take advantage of at an IRA provider and the
potential costs of those products and services.
• Our strategy may have higher risk than the option(s) provided to you in your plan.
• Your current plan may also offer financial advice.
•
If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum
distribution beyond the required minimum distribution age.
• Your 401k may offer more liability protection than a rollover IRA; each state may vary.
• Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been
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generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules
so you should consult with an attorney if you are concerned about protecting your retirement plan assets from
creditors.
• You may be able to take out a loan on your 401k, but not from an IRA.
•
IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be
subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education
expenses or the purchase of a home.
If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate.
•
• Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and decide whether a rollover is best
for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number
as listed on the cover page of this brochure.
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Summit Wealth Advisors LLC
Form ADV Part 2A – Appendix 1 Wrap Fee Program Brochure
Effective: March 31, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of
the Advisor (“Summit Wealth Group LLC” or the “Advisor”). If you have any questions about the content of this Disclosure
Brochure, please contact the Advisor at (719) 633-4033.
The Advisor is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority.
Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure
provides information about the Advisor to assist you in determining whether to retain the Advisor.
Additional information about the Advisor and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335242.
Summit Wealth Advisors LLC
13710 Struthers Road, Suite 115, Colorado Springs, CO 80921
Phone: (719) 633-4033 | Website: www.summitwealthgroup.com
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Item 2. Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes
materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to
notify you and provide you with a description of the material changes.
The following material changes have been made since the last filing of the adviser’s disclosure brochure:
•
Item 4 - Services, Fees, and Compensation has been updated to include additional information about program
fees and costs.
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Item 3. Table of Contents
Item 2. Material Changes...........................................................................................................................23
Item 3. Table of Contents ..........................................................................................................................24
Item 4. Services, Fees, and Compensation ..............................................................................................25
Item 5. Account Requirements and Types of Clients ................................................................................26
Item 7. Client Information Provided to Portfolio Managers .......................................................................28
Item 8. Client Contact with Portfolio Managers .........................................................................................28
Item 9. Additional Information ....................................................................................................................28
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Item 4. Services, Fees, and Compensation
Services
Summit Wealth Group, LLC (“Summit” or the “Advisor”) provides customized wealth management services for its Clients.
This Wrap Fee Program Brochure is provided as a supplement to the Summit Disclosure Brochure (Form ADV 2A). This
Wrap Fee Program Brochure is provided along with the Disclosure Brochure to provide full details of the business
practices and fees when selecting Summit as your investment advisor.
As part of the wealth management fees noted in Item 5 of the Disclosure Brochure, Summit includes securities transaction
fees (herein “Covered Costs”) as part of the overall wealth management fee. Securities regulations often refer to this
combined fee structure as a “Wrap Fee Program”.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of
Covered Costs into a single “bundled” wealth management fee. This Wrap Fee Program Brochure references back to the
Summit Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 of the
Disclosure Brochure for details on Summit’s investment philosophy and related services
Program Costs
We charge an annual "wrap-fee" for participation in the Program depending upon the market value of your assets under
our management. The wrap fee is negotiable between the advisor and the client. You are not charged separate fees for
the different components of the services provided by the Program. Our firm pays all trade expenses placed on your
behalf. Assets in each of your account(s) are included in the fee assessment unless specifically identified in writing for
exclusion. In our sole discretion, we may negotiate a lower management fee based upon certain criteria (i.e., anticipated
future earning capacity, dollar amount of assets to be managed, related accounts, account composition, pre-existing client
relationship, account retention, etc.).
Fees
Our annual portfolio management fee is billed and payable quarterly in advance and is based on the account balance at
the end of the previous quarter.
If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will
apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the month
for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances.
As a client, you should be aware that the wrap fee charged by our firm may be higher (or lower) than those charged by
others in the industry, and that it may be possible to obtain the same or similar services from other firms at lower (or
higher) rates. A client may be able to obtain some or all of the types of services available through our firm's wrap fee
program on an individual basis through other firms and, depending on the circumstances, the aggregate of any separately
paid fees may be lower or higher than the annual fees shown above.
We will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We
will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly
from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These
account statements will show all disbursements from your account. You should review all statements for accuracy.
Other Costs That Apply to the Programs Described in This Brochure
Other costs that are charged which are not part of the “Covered Costs” include fees for portfolio transactions executed
away from the broker/dealer or custodian selected by the client, dealer markups, electronic fund and wire transfers,
spreads paid to market-makers, and exchange fees, among others. The program fees do not cover certain charges
associated with securities transactions in clients’ accounts, including (i) dealer markups, markdowns, or spreads charged
on transactions in over-the-counter securities; (ii) costs relating to trading in certain foreign securities; (iii) the internal
charges and fees assessed on collective investment vehicles, such as mutual funds and closed-end funds, UITs, ETFs, or
real estate investment trusts (“REITs”); (iv) brokerage commissions or other charges imposed by broker/dealers or entities
other than the custodian if and when trades are cleared by another broker/dealer; (v) the charge to carry tax lot
information on transferred mutual funds or other investment vehicles, postage and handling charges, returned check
charges, transfer taxes, stock exchange fees, or other fees mandated by law; and (vi) any brokerage commissions or
other charges, including contingent deferred sales charges (“CDSC”), imposed upon the liquidation of “in-kind assets” that
are transferred into a program account.
Summit or the appointed third-party investment adviser or Money Manager will liquidate assets transferred into a program
account at their sole discretion. Clients should be aware that if they transfer in-kind assets into a program account, such
assets are subject to immediate or future discretionary liquidation and clients will incur a brokerage commission or other
25
charge, including contingent deferred sales charges, as applicable. Clients will also be responsible for the payment of any
taxes when liquidations of assets held in their account take place. Accordingly, clients should consult with their advisor
and tax consultant before transferring in-kind assets into a program. The broker/dealer or custodian will charge the client
certain additional and/or minimum fees in accordance with their policies.
Client will also incur applicable redemption fees when the third-party investment adviser or Money Manager to an
investment strategy determines that it is in the client’s overall interest, in conjunction with the stated goals of the
investment strategy, to divest from certain collective investment vehicles prior to the expiration of the collective investment
vehicle’s minimum holding period. Depending on the length of the redemption period, the particular investment strategy,
and/or market circumstances, a third-party investment adviser or Money Manager may be able to minimize any
redemption fees when, at their discretion, it is reasonable to allow a client to remain invested in a collective investment
vehicle until expiration of the minimum holding period.
In certain programs, the total annual account fee does not cover certain custodial fees that are charged to clients by the
custodian. Clients will be charged for specific account services, such as ACAT transfers, electronic fund and wire
transfers, and for other optional services elected by clients. Accounts will be subject to transaction-based ticket charges
for the purchase or sale of certain mutual funds depending upon the specific program account selected by the client.
Similarly, the total annual account fee does not cover certain non-brokerage-related fees, such as IRA trustee or
custodian fees and tax-qualified retirement plan account fees and annual and termination fees for retirement accounts,
such as IRAs.
Selection of Other Advisers
When appropriate, Summit will engage with a Third-Party Money Manager (“TPMM”) for asset management services.
Depending on your needs and circumstances we may recommend that you use the services of a 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 include, but are not limited to, the TPMM's performance, methods of analysis, fees, your
financial needs, investment goals, risk tolerance and investment objectives. We will monitor the TPMM(s)' performance to
ensure its management and investment style remain aligned with your investment goals and objectives.
The TPMM(s) will actively manage your portfolio or a portion of your portfolio in such cases and will assume discretionary
investment authority over your account or a portion of your account. With some TPMM programs, we will assume
discretionary authority to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem such
action appropriate.
In cases where a TPMM is engaged to manage all or a portion of your account, clients will incur certain fees or charges
imposed by the TPMM in connection with investments made on behalf of the Client’s account[s]. Summit’s “wrap fee”
includes “Covered Costs” (defined as Summit’s advisory fee plus any securities transaction fees) as part of the overall
wealth management fee. Fees charged by TPMMs are separate and distinct from the wrap fee, as are other costs as
outlined in the “Other Costs That Apply to the Programs Described in This Brochure” section in Item 5. Management fees
charged by TPMMs vary. Applicable TPMM fees will be disclosed to you as part of the account opening process.
Compensation
Summit is the sponsor and portfolio manager of this Wrap Fee Program. Summit receives wealth management fees paid
by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the management of the
Client’s account[s].
Item 5. Account Requirements and Types of Clients
Summit offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations and businesses.
In general, we do not require a minimum dollar amount to open and maintain an advisory account; however, we have the
right to terminate your account if it falls below a minimum size which, in our sole opinion, is too small to manage
effectively. We, at our sole discretion, may establish a minimum portfolio asset value size requirement for participation in
our Wrap Program.
We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of
related accounts to meet the stated minimum.
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Item 6. Portfolio Manager Selection and Evaluation
Summit serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Performance-Based Fees and Side-by-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees
that are based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to
the practice of managing accounts that are charged performance-based fees while at the same time managing accounts
that are not charged performance- based fees. Our fees are calculated as described above and are not charged on the
basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure for details on the research and analysis methods employed by the Advisor.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our
services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate
clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in
no way an indication of future performance.
When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks,
each of which may affect the probability and magnitude of any potential losses. The following risks may not be all-
inclusive but should be considered carefully by a prospective client before retaining our services.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of
active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or
bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer's securities
held by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in inflation and
interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a
client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the
value of many types of fixed income investments to decline.
Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for
example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If
you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of outliving your
savings. This risk is particularly relevant for people who are retired or are nearing retirement.
We recommend various types of securities and we do not primarily recommend one particular type of security over
another since each client has different needs and different tolerance for risk. Each type of security has its own unique set
of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even
within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated
return of an investment, the higher the risk of loss associated with the investment. A description of the types of securities
we may recommend to you and some of their inherent risks are provided below.
Proxy Voting
The Advisor will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding
corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are
responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to
receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have
authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitations to vote
proxies.
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Item 7. Client Information Provided to Portfolio Managers
In order to provide the Program services, we will share your private information with your account custodian. We may also
provide your private information to mutual fund companies and/or private managers as needed. We will only share the
information necessary in order to carry out our obligations to you in servicing your account. We share your personal
account data in accordance with our privacy policy as described below.
Item 8. Client Contact with Portfolio Managers
Without restriction, you may contact our firm or your advisory representative directly with any questions regarding your
Program account. You should contact your advisory representative with respect to changes in your investment objectives,
risk tolerance, or requested restrictions placed on the management of your Program assets.
Item 9. Additional Information
Disciplinary Information and Other Financial Industry Activities and Affiliations
We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our
advisory business or the integrity of our management. We do not have any required disclosures under this item.
Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes
guidelines for professional standards of conduct for persons associated with our firm. Our goal is to protect your interests
at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All
persons associated with our firm are expected to adhere strictly to these guidelines. Persons associated with our firm are
also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account
holdings by persons associated with our firm. More information on the Summit Code of Ethics can be found under Item 11
in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
Review of Accounts
Client accounts are monitored on a regular and continuous basis by Advisory Persons of Summit under the supervision of
the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in Item 13 of the Form
ADV Part 2A – Disclosure Brochure.
Other Compensation
We receive economic benefits from a non-client for providing investment advice or other advisory services to you.
Through our participation in certain programs or use of a custodian we are entitled to receive economic benefits. As part
of our fiduciary duty, we endeavor at all times to put the interests of our clients first. Clients should be aware, however,
that the receipt of economic benefits by our firm from a non-client in and of themselves creates a potential conflict of
interest and may influence our choice in providing services to your account. This arrangement does not cause our clients
to pay any additional transaction fees beyond those that are traditionally charged by our firm and/or other service
providers.
Refer to the Services, Fees, and Compensation section above for disclosures on research and other benefits we may
receive resulting from our relationship with your account custodian.
Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program
Brochure) for details on additional compensation that may be received by Summit or its Advisory Persons. Each Advisory
Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure) provides details on any outside
business activities and the associated compensation.
Client Referrals from Solicitors
The Advisor compensates, either directly or indirectly, persons who are not supervised persons, for Client referrals as
described in Item 14 of the Form ADV Part 2A – Disclosure Brochure.
Financial Information
Neither Summit, nor its management, have any adverse financial situations that would reasonably impair the ability of
Summit to meet all obligations to its Clients. Neither Summit, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. Summit is not required to deliver a balance sheet along with this Disclosure Brochure
as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the
future.
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Item 10. Requirements for State-Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this item.
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Summit Wealth Group, LLC Privacy Notice
Effective Date: March 31, 2026
Our Commitment to You
Summit Wealth Advisors, LLC (“Summit Wealth” or the “Adviser”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Adviser, as described
here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. Summit Wealth (also referred to as "we", "our" and
"us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that
such information is used for proper business purposes in connection with the management or servicing of our relationship
with you.
Summit Wealth does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for reasonable business purposes in connection with the servicing and management of our relationship
with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this
Policy.
Why you need to know
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your
account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we
collect, share, and protect your personal information.
What information do we collect from you?
Social security or taxpayer identification number Assets and liabilities
Name, address, and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What information do we collect from other sources?
Custody, brokerage, and advisory agreements
Account applications and forms
Other advisory agreements and legal documents
Investment questionnaires and suitability
documents
Transactional information with us or others
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural, and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure
office environment. Our technology vendors provide security and access control over personal information and have
policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal
information. We require third parties that assist in providing our services to you to protect the personal
information they receive from us.
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
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Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties as necessary for us to provide agreed upon services to you,
including but not limited to: processing transactions; general account
maintenance; responding to regulators or legal investigations; and credit
reporting.
Yes
No
Marketing Purposes
Summit Wealth may disclose personal information with non-affiliated third
parties to offer you services. Certain laws may give us the right to share
your personal information with financial institutions where you are a
customer and where Summit Wealth or the client has a formal agreement
with the financial institution.
Yes
Yes
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
No
Not Shared
Information About Former Clients
Summit Wealth does not disclose non-public personal information to non-
affiliated third parties with respect to persons who are no longer our
Clients.
Changes to our Privacy Policy
We will send you a copy of this Privacy Notice annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Notice and will provide you with a revised version if the changes materially alter the
previous Privacy Notice. We will not, however, revise our policies to permit the sharing of non-public personal information
other than as described in this notice unless we first notify you and provide you with an opportunity to prevent information
sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at
(719) 633-4033.
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