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CLIENT RELATIONSHIP
SUMMARY
January 31, 2025
Summit Wealth Group, LLC (“SWG”) is registered with the Securities and Exchange Commission as an investment
adviser. Brokerage and investment advisory services and fees differ and it is important for you to understand the
differences. Free and simple tools are available to research firms and financial professionals at Investor.gov/CRS,
which also provides educational materials about broker‐dealers, investment advisers, and investing.
What investment services and advice can you provide me?
SWG creates a Vision based Financial Life Plan using sustainable accumulation and distribution strategies that are
monitored in accordance with the success of your plan. Our Phase 1 focuses on your personal Vision, Values and
Goals from beginning to end. As a fiduciary, we work to understand your issues and challenges to gain clarity. This
clarity leads to decisions that are in your best interest. Together we implement our recommendations from your
Financial Life Plan. All clients are required to complete a Financial Life Plan for a fee. Our Phase 2 is a Service
that continuously keeps your Financial Life Planning on track along with Investment Management for a separate
fee. Ongoing financial advice and services are included as your life and needs change over time. In addition, as a
separate service we offer Income Tax Preparation and planning. Clients who enroll in this service enjoy the
coordination of their Financial Life Plan, Investment Management, Income tax planning and preparation.
When we perform Wealth Management Services, it is typically on a discretionary basis. This means you give us the
authority to make transactions within your accounts. The investments we manage within your portfolio are based
upon your Financial Life Plan. In addition, we create an Investment Policy Statement that outlines the high level
asset allocation targets that we prescribe. In some cases, we may manage accounts on a non‐discretionary basis. In
this case, we would manage your portfolio in the same manner; however, we would require your approval prior to
making transactions. We allow for reasonable account restrictions and do not limit the type of investments available
to our clients. We also may invest with third party managers, who have been carefully sourced and researched.
Clients that we advise may include individuals, families, trusts, charitable organizations and foundations, pensions,
and corporations. SWG requires each client to place at least $1,000,000 with the firm. This minimum may be waived
in the discretion of SWG.
For more detailed information, please refer to our Disclosure Brochure, the ADV Part 2A, under Item 4 Advisory
Business and Item 7 Types of Clients, which can be found by CLICKING HERE.
What fees will I pay?
Financial Life Planning fees for initial planning work will vary but are generally range from $5,000 to $7,500 per plan.
However, these fees are guidelines. Please see our Form ADV Part 2A for more information. SWG provides wealth
management services for an annual fee based upon a percentage of the assets being managed by SWG. All
Wealth Management clients will be required to execute an Investment Management Agreement. This asset‐
based fee typically varies between 0.25% and 1.5%. This rate is based on a blended tiered fee schedule Tax
Preparation and planning services are charged on a fixed fee subscription basis paid in advance on a calendar year
basis. We offer three tiered levels of service from Basic to Advanced depending on complexity. The annual fee ranges
from $750 ‐ $2,500. Services include tax preparation and filing, tax planning scenario analysis, electronic filing, audit
representation, year‐round access for all tax matters, and no hourly fees.
Financial Life Planning and Financial Consulting fees will be due upon receipt of invoice from SWG. For clients whose
assets are managed by the firm, investment advisory fees will be debited directly from each client’s account. The
advisory fee is paid quarterly, in advance, and the value used for the fee calculation is the gross value as of the
ADV PART 3: FORM CRS
last market day of the previous quarter. This means that if your annual fee is 1.00%, then each quarter we will
multiply the value of your account by 1.00% then divide by 4 to calculate our fee. For clients whose assets are
managed through third party managers the terms of fee payment may vary dependent upon the manager or
managers selected. When clients’ assets are allocated to a third party manager, the manager may collect client’s
advisory fees, and remit a portion of that fee back to SWG.
There are a number of other fees that can be associated with holding and investing in securities. Some of these fees
includes: custodian fees, account maintenance fees, fess related to mutual funds and variable annuities, and other
transactional fees and product‐level fees.
You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any a
mount of money you make on your investments over time. Please make sure you understand what fees and costs yo
u are paying.
For more specific information regarding our fees, please refer our Disclosure Brochure, the ADV Part 2A under Item
5 Fees and Compensation by CLICKING HERE.
What are your legal obligations to me when acting as my investment adviser? How else does
your firm make money and what conflicts of interest do you have?
When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of
yours. At the same time, the way we make money creates some conflicts with your interests. You should understand
and ask us about these conflicts because they can affect the investment advice we provide you. Here’s example to
help you understand what this means.
For example, certain investment adviser representatives of SWG are also associated with Purshe Kaplan Sterling
Investments, Inc. (PKS) as broker‐dealer registered representatives (“Dually Registered Persons”). In their capacity
as registered representatives of PKS, certain Dually Registered Persons may earn commissions for the sale of
securities or investment products that they recommend for brokerage clients. They do not earn commissions on
the sale of securities or investment products recommended or purchased in advisory accounts through SWG.
How do your financial professionals make money?
We are paid a portion of the asset management fees collected from clients and not rewarded with sales bonuses
or commissions related to advisory accounts. However, as noted above, registered representatives may earn a
commission for the sale of securities or investment products that they recommend for brokerage clients.
Do you or your financial professionals have legal or disciplinary history?
No. SWG has no legal or disciplinary history. Feel free to go to Investor.gov/CRS for a simple search.
You may find additional information about SWG by CLICKING HERE or calling (802) 295‐5300 to request up‐to‐date
information and a copy of the relationship summary.
Here are some Conversation Starters suggested by the SEC:
Given my financial situation, should I choose an investment advisory service? Should I choose a
brokerage service? Should I choose both types of services? Why or why not?
How will you choose investments to recommend to me?
What is your relevant experience, including your licenses, education, and other qualifications? What
do these qualifications mean?
Help me understand how these fees and costs might affect my investments. If I give you $10,000 to
invest, how much will go to fees and costs, and how much will be invested for me?
How might your conflicts of interest affect me, and how will you address them?
As a financial professional, do you have any disciplinary history? For what type of conduct?
Who is my primary contact person? Is he or she a representative of an investment adviser or a
broker‐dealer? Who can I talk to if I have concerns about how this person is treating me?
ADV PART 3: FORM CRS
Item 1: Cover Page
FORM ADV PART 2A INFORMATIONAL BROCHURE
SUMMIT WEALTH GROUP, LLC
205 Billings Farm Road, Suite 2A | White River Junction, VT 05001
20B Hampton Road | Exeter, NH 03833 (802) 295-5300 | www.summitwg.com
Erik Randall, CCO
Version: December 11, 2025
This brochure provides information about the qualifications and business practices of Summit Wealth Group LLC. If you
have any questions about the contents of this brochure, please contact us at (802) 295-5300 or via email at
ERandall@summitwg.com. The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority. Our registration does not imply a certain level
of skill or training.
Additional information about Summit Wealth Group LLC (CRD# 282205) is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2:
Statement of Material Changes
As of January 1, 2025, Summit Wealth Group has changed its Chief Compliance Officer from Thomas Hartman
to Erik Randall. In addition, Summit Wealth Group has changed its corporate domicile to New Hampshire.
Item 3:
Table of Contents
TABLE OF CONTENTS
Item 1: Cover Page ............................................................................................................................ 1
Contents
Item 2:Statement of Material Changes ............................................................................................... 2
Item 3:Table of Contents .................................................................................................................... 2
Item 4:Advisory Business ................................................................................................................... 3
Item 5:Fees and Compensation .......................................................................................................... 5
Item 6:Performance-Based Fees ........................................................................................................ 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, Participation or Interest in Client Transactions and Personal Trading ........ 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 ........................................................................................................ 20
Item 18:Financial Information ........................................................................................................... 20
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INFORMATIONAL BROCHURE
SUMMIT WEALTH GROUP LLC
Item 4:
Advisory Business
Summit Wealth Group LLC (“SWG”) has been in business since January 2003 and registered with the
Securities and Exchange Commission since January 2016. Thomas Hartman, Abigail Hurlburt, and Erik
Potts are the firm’s principal owners.
SWG provides personalized life planning and wealth management services to individuals, families,
trusts, charitable organizations, and foundations, pensions, and corporations. Our mission is to
improve our clients’ financial well-being and lives. We strive to know more about each client and their
situation than anyone else, so that we can make a meaningful impact on their lives.
Financial Life Planning
Our Financial Life Planning process is designed to help you identify your financial goals in life, and how
we may help you accomplish them. SWG aims to look at your life in a way that perhaps you haven’t
before, to determine what needs to be done to achieve your goals.
Discovery involves gathering information from the client but is not limited to just a client’s financial
circumstances. We gather as much information as possible to find out what motivates each client to
identify their life goals. This discovery process may take place over multiple meetings with the client.
These underlying motivational factors may not always be quantitative but are as important as a
number such as age or years to retirement, as they help us find the client’s true goals. The life plan
SWG ultimately produces is intended to be a suggested roadmap of how to meet the client’s goals.
Services Provided:
Discovery and Planning Process
• Discover and help to prioritize Client’s short- and long-term financial goals and aspirations.
• Identify life transitions that Client is and expects to be experiencing.
• Gather and organize Client’s data and documents.
• Analyze Client’s financial condition, challenges, and opportunities as they relate to the
goals of the Client.
• Develop an investment strategy that attempts to balance Client’s goals and tolerance for
volatility.
• Help Client with the financial implications of life transitions.
• Provide written recommendations and alternatives to help Client achieve stated goals.
• Help to implement financial decisions.
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Ongoing Financial Advice and Service
• Monitor financial decisions made in the initial discovery process.
• Provide on-going continuous Financial Life Planning.
• Continue to help prioritize and implement Client’s short- and long-term goals and
aspirations.
• Meet regularly with Client to review goals and progress.
• Asset management services (See below).
• Monitor life transitions that Client is and expects to be experiencing.
• Strategize/coordinate with other Advisors (accountants, attorneys, insurance agents,
etc.).
SWG may recommend the services of other professionals for implementation purposes. You are under
no obligation to engage the services of any such recommended professional. You retain absolute
discretion over all such implementation decisions and are free to accept or reject any recommendation
from SWG. If you engage any professional recommended by SWG, and a dispute arises thereafter
relative to such engagement, you agree to seek recourse exclusively from and against the engaged
professional.
Wealth Management
Each client who engages SWG for wealth management services may be required to complete a
financial plan.
The wealth management process involves developing an investment strategy that attempts to balance
a client’s goals and tolerance for volatility. We assess a client’s risk tolerance through a Risk Tolerance
Questionnaire. In some cases, a client’s risk tolerance may not be suitable to enable them to meet
their goals. SWG may then create planning options and numerous scenarios that SWG feels would
enable the client to meet their goals most likely and develops an appropriate asset allocation strategy
accordingly.
Wealth Management Services
• Develop written Investment Policy Statement.
• Portfolio construction, investment selection and execution of trades.
• Periodic performance reporting.
• Periodic advice on accounts held-away from SWG’s recommended custodian, when
appropriate.
• Re-balance the portfolio when appropriate.
• Re-allocate the portfolio due to changes the Client’s objectives or performance of the
mutual fund manager selected.
When we perform asset management services, we will do so on a discretionary basis. This means that
while we will continue an ongoing relationship with each client, being involved in various stages of
their lives and decisions to be made, but we will not seek specific approval of changes to client
accounts. Clients can always make deposits or withdrawals in their accounts at any time. Clients should
be aware that if SWG is managing your assets, you may not be able to place restrictions on the
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types of investments in an account or portfolio. Because we take discretion when managing accounts,
clients engaging us will be asked to execute a Limited Power of Attorney (granting us the discretionary
authority over the client accounts) as well as an Investment Management Agreement that outlines the
responsibilities of both the client and SWG.
In very limited circumstances, we may provide investment management services on a non-
discretionary basis, which means we will manage the clients’ accounts as we do for our discretionary
clients, except we will consult with the client prior to implementing any investment recommendation.
Clients should be aware that some recommendations may be time-sensitive, in which case
recommendations not implemented because we are unable to reach a non-discretionary client may
not be made on a timely basis and therefore client’s account may not perform as well as it would have
had SWG been able to reach the client for a consultation on the recommendation.
Tax Preparation
SWG also offers tax preparation services in addition to comprehensive Financial Life Planning and
investment management. SWG’s tax services are designed to make the tax filing process simple and
stress free for each client, while also working to reduce a client’s tax liability on current and future
returns.
Financial Consulting
SWG may provide additional financial consulting services. Clients are required to enter into a written
agreement with SWG setting forth the terms and conditions of the engagement (including
termination), describing the scope of the services to be provided, and the portion of the fee that is
due from the client prior to SWG commencing services.
Assets Under Management
As of December, 31 2024, SWG had $656,268,782 in assets under management, and $42,313,990 in
assets under advisement. All accounts are managed on a discretionary basis. SWG defines “assets
under advisement” as assets for which we provide investment recommendations but are not otherwise
considered regulatory assets under management.
Item 5:
Fees and Compensation
Fees Charged
A.
All investment management clients will be required to execute an Investment Management
Agreement that will describe the type of management services to be provided and the fees, among
other items. Clients are advised that they may pay fees that are higher or lower than fees they may
pay another advisor for the same services and may in fact pay lower fees for comparable services from
other sources. Clients are under no obligation at any time to engage, or to continue to engage, SWG
for investment services.
Financial Life Planning
Financial Life Planning fees for initial planning work will vary but are generally expected to be in the
fixed fee range of $5,000 to $7,500 per plan. However, these fees are guidelines, subject to change
according to the complexity of the plan and the specific client’s circumstances. Such changes may
5
include providing services pro bono for matters such as charities or higher fees for highly complex
matters. In limited circumstances, family members can receive discounted services for Financial Life
Planning.
The Financial Life Planning fee also includes any actions on the part of SWG required to implement the
plan for a period of up to 12 months from the Agreement signing. In some instances, there may be
additional planning not identified in the initial plan that will require more services and resources of
SWG. These additional services are provided on an hourly basis, at $500 per hour.
Wealth Management
SWG provides investment management services for an annual fee based upon a percentage of the
assets being managed by SWG. This asset-based fee typically varies between .25% and 1.5%. Fees are
negotiable, and may be higher or lower than this range, based on the nature of the account. This rate
is based on a blended tiered fee schedule. Factors affecting fee percentages include the size of the
account, complexity of asset structures, and other factors such as whether or not ongoing financial
planning is incorporated into asset management. All clients, but especially those with smaller
accounts, should be advised they may receive similar services from other professionals for higher or
lower overall costs.
Tax Preparation & Planning
Tax Preparation and planning services are charged on a fixed fee subscription basis paid in advance on
a calendar year basis. We offer three tiered levels of service from Basic to Advanced depending on
complexity. The annual fee ranges from $750 - $2,500. Services include tax preparation and filing, tax
planning scenario analysis, electronic filing, audit representation, year-round access for all tax matters,
and no hourly fees.
Financial Consulting
Financial consulting is done on a fixed fee basis. Fixed fees will be between $5,000 and $10,000. The
fee range stated is a guide. Fees may be higher or lower than this range, based on the nature of the
engagement. Fees are negotiable and will depend on the anticipated complexity of the project.
Fee Payment
B.
Financial Life Planning & Financial Consulting
Financial Life Planning and Financial Consulting fees will be due upon receipt of invoice from SWG.
Financial Life Planning fees are due at the presentation of the plan. Consulting fees may be billed 50%
up front on a case-by-case basis.
Wealth Management
For clients whose assets are managed by the firm, investment advisory fees will be debited directly
from each client’s account. The advisory fee is paid quarterly, in advance, and the value used for the
fee calculation is the gross value as of the last market day of the previous quarter. This means that if
your annual fee is 1.00%, then each quarter we will multiply the value of your account by 1.00% then
divide by 4 to calculate our fee. For assets deposited into or withdrawn from an account, known as
capital flows, after the inception of a billing period, the fee payable is prorated based on the number
of days remaining in the billing period. Any reduction in fees related to the withdrawal of assets in an
account will be credited against the next billing period’s investment advisory fees. Additionally, to the
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extent there is cash in your account, it will be included in the value for the purpose of calculating fees.
Once the calculation is made, we will instruct your account custodian to deduct the fee from your
account and remit it to SWG.
Clients whose fees are directly debited will provide written authorization to debit advisory fees from
their accounts held by a qualified custodian chosen by the client. Each quarter, clients will receive a
bill itemizing the fees to be debited, including the formula used to calculate the fee, the amount of
assets upon which the fee is based, and the time period covered by the fee. The invoice will also state
that the fee was not independently calculated by the custodian. The client will also receive a statement
from their account custodian showing all transactions in their account, including the fee.
Third Party Managers
For clients whose assets are managed through third party managers (please see Item 8 for more
information regarding the use of third-party managers), the terms of fee payment may vary dependent
upon the manager or managers selected. For example, while SWG generally debits fees quarterly, in
advance, some managers calculate fees quarterly in arrears, or potentially even monthly. For details
on the exact methodology of calculating fees by each of the managers in a client’s portfolio, clients
should refer to the Form ADV for such managers.
Tax Preparation
Invoices for tax preparation services will be documented on each Client Engagement Letter and are
payable in advance on a calendar year basis.
Other Fees
C.
There are a number of other fees that can be associated with holding and investing in securities. Where
applicable, you will be responsible for fees including transaction fees for the purchase or sale of a
mutual fund or Exchange Traded Fund., Expenses of a fund will not be included in management fees,
as they are deducted from the value of the shares by the mutual fund manager. When selecting mutual
funds that have multiple share classes for recommendation to clients, SWG will consider the internal
fees and expenses associated with each share class, and it is SWG policy to choose the lowest- cost
share class available, absent circumstances that dictate otherwise. For complete discussion of
expenses related to each mutual fund, you should read a copy of the prospectus issued by that fund.
SWG can provide or direct you to a copy of the prospectus for any fund that we recommend to you.
Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and
custodial issues.
Pro-rata Fees
D.
If you become a client during a quarter, you will pay a management fee for the number of days left in
that quarter. If you terminate our relationship during a quarter, you will be entitled to a refund of any
management fees for the remainder of the quarter. Once your notice of termination is received, we
will assess pro-rated fees for the number of days between the end of the prior billing period and the
date of termination to be paid in whatever way you direct (check, wire). SWG will cease to perform
services, including processing trades and distributions, upon termination. Assets not transferred from
terminated accounts within 30 (thirty) days of termination may be “de-linked”, meaning they will no
longer be visible to SWG and will become a retail account with the custodian.
7
If you terminate our relationship before the completion of the financial plan, any unearned fees will be
returned to you on a pro rata basis.
Compensation for the Sale of Securities.
E.
To permit SWG clients to have access to as many investment solutions as possible, certain
professionals of SWG are registered representatives of Purshe Kaplan Sterling Investments, Inc.
(“PKS”), a FINRA member broker-dealer. The relationship with PKS allows these professionals to
provide additional products to clients’ portfolios that would not otherwise be available. Because PKS
supervises the activities of these professionals as registered representatives of PKS, the relationship
may be deemed material. However, PKS is not affiliated with SWG or considered a related party. PKS
does not make investment decisions for client accounts. Registered representative status enables
these professionals to receive customary commissions for the sales of various securities, including
those recommended to clients. In addition, when mutual funds are utilized, depending on the share
class selected, the registered representatives also receive additional ongoing 12b-1 fees from the
mutual fund company for mutual fund purchases during the period you maintain the mutual fund
investment. Commissions charged and 12b-1 fees received for these products will not offset
management fees owed to SWG.
The receipt of commissions and 12b-1 fees for investment products that are recommended to clients
gives rise to a conflict of interest for the representative, in that the individual who will receive the
commissions is also the individual that is recommending that the client purchase a given product.
There is an additional conflict of interest when a registered representative is selecting a more
expensive 12b-1 fee paying mutual fund share class when a lower-cost share class is available for the
same fund. These conflicts are disclosed to clients verbally and in this brochure. Clients are advised
that they are not obligated to implement any recommendation provided by the registered
representative or may choose to implement any investment recommendation through another
brokers or agents that are not affiliated with SWG. SWG attempts to mitigate this conflict by requiring
that all investment recommendations have a sound basis for the recommendation, and by requiring
employees to acknowledge their fiduciary responsibility toward each client.
Item 6:
Performance-Based Fees
SWG will not charge performance-based fees.
Item 7:
Types of Clients
Clients advised may include individuals, families, trusts, charitable organizations and foundations,
pensions, and corporations. SWG require each client to place at least $1,000,000 with the firm. This
minimum may be waived in the discretion of SWG.
Item 8:
Methods of Analysis, Investment Strategies and Risk of Loss
It is important for you to know and remember that all investments carry risks. Investing in securities
involves risk of loss that clients should be prepared to bear.
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As described in Item 4, our goal at SWG is to understand each client’s needs and goals, even if they do
not obviously directly connect to their financial circumstances or investing. After we determine what
a client’s goals are, we can manage their assets accordingly. Each client’s portfolio may be similar to,
or vary greatly from, another client who on the surface seems quite similar. This is because each
client’s portfolio is constructed based on that client’s life goals, needs and other circumstances, which
may not be readily apparent to even a close friend.
Once we ascertain your objectives for each portfolio, we will develop a set of asset allocation
guidelines, and then in most cases place the assets in an asset allocation strategy. One goal of asset
allocation is to maximize the potential for meeting your life goals and investment objectives. An asset
allocation strategy is a percentage-based allocation to different investment types. For example, an
asset allocation strategy that calls for 40-60% of the portfolio to be invested in equity securities, with
the remaining balance in fixed income. Another client may have an asset allocation of 50-60% in fixed
income securities, 20% in equities, and the remainder in cash. The percentages in each type that we
recommend are based on the typical behavior of that security type, individual securities we follow,
current market conditions, your current financial situation, your financial goals, and the timeline to
get you to those goals. Once we agree on allocation guidelines, risk tolerance, time horizon, and how
to achieve these results, we will develop a plan to guide all parties involved in the execution of these
goals, including but not limited to, SWG, the client, the custodian, and the investment managers.
Upon completion of the plan, we will periodically recommend securities transactions in your portfolio
to meet the guidelines of the asset allocation strategy. It is important to remember that because
market conditions can vary greatly, your asset allocation guidelines are not necessarily strict rules.
Rather, we review accounts individually, and may deviate from the guidelines as we believe necessary.
If we are managing your account directly, the specific securities we recommend for your account will
depend on market conditions and our research at the time. Generally, we recommend a mix of mutual
funds, index funds, exchange traded funds, stocks, and bonds. Specific funds are chosen based on
where its investment objective fits into the asset allocation recommended by SWG, its risk parameters,
past performance, peer rankings, fees, expenses, and any other aspects of the fund SWG deems
relevant to that particular fund. We base our conclusions on predominantly publicly available research,
such as regulatory filings, press releases, competitor analyses, and in some cases research we receive
from our custodian or other market analyses. We will also utilize technical analyses, which means that
we will review the past behaviors of the security and the markets in which it trades for signals as to
what might happen in the future.
Most mutual funds offer different share classes with varying fee structures, including share classes
with sales load, sales charges, or 12B-1 fees. 12B-1 fees are deducted from the mutual funds’ assets
on an ongoing basis and are paid to broker-dealers and registered representatives whose clients own
those shares to cover fund distribution and shareholder services. This receipt of fees presents a
potential conflict of interest, as SWG has an incentive to recommend more expensive share classes to
clients based on the compensation received, rather than based upon the client’s needs. However, it is
SWG policy that when specific funds offer more than one share class, SWG will select the lowest-cost
share class available to the client, absent circumstances that dictate otherwise.
Additionally, as assets are transitioned from a client’s prior advisors to SWG, clients may hold legacy
securities and may place restrictions on individual security types. Legacy securities are those that a
client owned prior to or separate from its SWG portfolio. If a client transitions mutual fund shares to
SWG that are not the lowest-cost share class, and SWG is not recommending disposing of the security
altogether, SWG will attempt to convert such mutual fund share classes into the lowest-cost share
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classes the client is eligible for, considering any adverse tax consequences associated with such
conversion.
Depending on a client’s given circumstances, SWG may recommend that a client rollover retirement
plan assets to an Individual Retirement Account (IRA) managed by us. As a result, SWG may earn fees
on those accounts. This presents a conflict of interest, as SWG has a financial incentive to recommend
that a client roll over retirement assets into an IRA we will manage. This conflict is disclosed to clients
verbally and in this brochure. Clients are also advised that they are under no obligation to implement
the recommendation to roll over retirement plan assets. SWG attempts to mitigate this conflict by
requiring that all investment recommendations have a sound basis for the recommendation, and by
requiring employees to acknowledge their fiduciary responsibility toward each client.
Additionally, part of the SWG process includes, where appropriate, involving multiple generations in
order to facilitate family financial planning. This can increase the financial education of the later
generations and manage expectations. However, potential for conflicts of interest exist with the
exchange of intergenerational information. SWG attempts to minimize these conflicts by treating each
household as its own fiduciary relationship. Information can only be shared across generations with
each household’s consent.
Third Party Managers
We may recommend that certain portions of a client's portfolio be managed by independent third-
party managers or recommend direct investment with independent third-party managers, typically
when those managers demonstrate knowledge and expertise in a particular investment strategy. Fees
charged by independent third-party managers are in addition to fees charged by SWG.
Prior to referring any client to another manager, SWG will confirm that such manager is registered, or
exempt from registration, as an investment adviser. SWG will obtain appropriate due diligence on all
independent third-party managers, making reasonable inquiries into their performance calculations,
policies and procedures, code of ethics policies and other operational and compliance matters to
account for performance and risk management. We examine the experience, expertise, investment
philosophies and past performance of third-party investment managers in an attempt to determine if
that manager has demonstrated an ability to invest over a period of time and in different economic
conditions. We monitor the manager’s underlying holdings, strategies, concentrations, and leverage
as part of our overall periodic risk assessment. Additionally, as part of our due-diligence process, we
survey the manager’s compliance and business enterprise risks.
Based on a client’s individual circumstances and needs, we will determine which selected money
manager's portfolio management style is appropriate for that client. Factors considered in making this
determination include account size, risk tolerance and the investment philosophy of the selected
money manager. We encourage clients to review each third-party manager’s disclosure document
regarding the particular characteristics of any program and managers selected by us.
We will regularly and continuously monitor the performance of the selected money managers. If we
determine that a particular selected money manager is not providing sufficient management services
to the client or are not managing the client's portfolio in a manner consistent with the client's
investment objectives, we will remove the client's assets from that selected money manager and place
the client's assets with another money manager at our discretion and without prior consent from the
client.
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When clients’ assets are allocated to a third-party manager, the manager may collect client’s advisory
fee, and remit a portion of that fee back to SWG. The fees remitted to SWG are a portion of the
manager’s fee, and clients will not be charged an additional advisory fee. This fee is not in
compensation for a client referral. Rather, it is SWG’s compensation for the ongoing diligence of that
manager as it is part of client’s portfolio.
Risk of Loss
There are always risks to investing. Clients should be aware that all investments carry various types of
risk including the potential loss of principal that clients should be prepared to bear. It is impossible to
name all possible types of risks. Among the risks are the following:
• Political Risks. Most investments have a global component, even domestic stocks. Political events
anywhere in the world may have unforeseen consequences to markets around the world.
• General Market Risks. Markets can, as a whole, go up or down on various news releases or for no
understandable reason at all. This sometimes means that the price of specific securities could go up
or down without real reason and may take some time to recover any lost value. Adding additional
securities does not help to minimize this risk since all securities may be affected by market fluctuations.
• Currency Risk. When investing in another country using another currency, the changes in the value
of the currency can change the value of your security value in your portfolio.
• Regulatory Risk. Changes in laws and regulations from any government can change the value of a
given company and its accompanying securities. Certain industries are more susceptible to
government regulation. Changes in zoning, tax structure or laws impact the return on these
investments.
• Tax Risks Related to Short Term Trading: Clients should note that SWG may engage in short-term
trading transactions. These transactions may result in short term gains or losses for federal and state
tax purposes, which may be taxed at a higher rate than long term strategies. SWG endeavors to invest
client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals
regarding the transactions in client accounts.
• Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline
as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative
value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a
growing economy and a rising money supply.
• Business Risk. This can be thought of as certainty or uncertainty of income. Management comes
under business risk. Cyclical companies (like automobile companies) have more business risk because
of the less steady income stream. On the other hand, fast food chains tend to have steadier income
streams and therefore, less business risk.
• Financial Risk. The amount of debt or leverage determines the financial risk of a company.
• Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided
by several rating services help to identify those companies with more risk. Obligations of the U.S.
government are said to be free of default risk.
• Margin Risk. “Margin” is a tool used to maximize returns on a given investment by using securities
in a client account as collateral for a loan from the custodian to the client. The proceeds of that loan
are then used to buy more securities. In a positive result, the additional securities provide additional
return on the same initial investment. In a negative result, the additional securities provide additional
losses. Margin therefore carries a higher degree of risk than investing without margin. Any client
account that will use margin will do so in accordance with Regulation T. SWG may utilize margin on a
limited basis for clients with higher risk tolerances.
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• Short Sales. “Short sales” are a way to implement a trade in a security SWG feels is overvalued. In
a “long” trade, the investor is hoping the security increases in price. Thus, in a long trade, the amount
of the investor’s loss (without margin) is the amount paid for the security. In a short sale, the investor
is hoping the security decreases in price. However, unlike a long trade where the price of the security
can only go from the purchase price to zero, in a short sale, the prince of the security can go infinitely
upwards. Thus, in a short sale, the potential for loss is unlimited and unknown, where the potential for
loss in a long trade is limited and knowable. SWG utilizes short sales only when the client’s risk
tolerances permit.
• Risks specific to private placements, sub-advisors, and other managers. If we invest some of your
assets with another advisor, including a private placement, there are additional risks. These include
risks that the other manager is not as qualified as we believe them to be, that the investments they
use are not as liquid as we would normally use in your portfolio, or that their risk management
guidelines are more liberal than we would normally employ.
•
Information Risk. All investment professionals rely on research in order to make conclusions about
investment options. This research is always a mix of both internal (proprietary) and external (provided
by third parties) data and analyses. Even an adviser who says they rely solely on proprietary research
must still collect data from third parties. This data, or outside research is chosen for its perceived
reliability, but there is no guarantee that the data or research will be completely accurate. Failure in
data accuracy or research will translate to a compromised ability by the adviser to reach satisfactory
investment conclusions.
• Small Companies. Some investment opportunities in the marketplace involves smaller issuers.
These companies may be starting up or are historically small. While these companies sometimes have
potential for outsized returns, they also have the potential for losses because the reasons the company
is small are also risks to the company’s future. For example, a company’s management may lack
experience, or the company’s capital for growth may be restricted. These small companies also tend
to trade less frequently that larger companies, which can add to the risks associated with their
securities because the ability to sell them at an appropriate price may be limited a compared to the
markets as a whole. Not only do these companies have investment risk, if a client is invested in such
small companies and requests immediate or short-term liquidity, these securities may require a
significant discount to value in order to be sold in a shorter time frame.
• Concentration Risk. While SWG selects individual securities, including mutual funds, for client
portfolios based on an individualized assessment of each security, this evaluation comes without an
overlay of general economic or sector specific issue analysis. This means that a client’s equity portfolio
may be concentrated in a specific sector, geography, or sub-sector (among other types of potential
concentrations), so that if an unexpected event occurs that affects that specific sector or geography,
for example, the client’s equity portfolio may be affected negatively, including significant losses.
• Transition risk. As assets are transitioned from a client’s prior advisers to SWG there may be
securities and other investments that do not fit within the asset allocation strategy selected for the
client. Accordingly, these investments will need to be sold in order to reposition the portfolio into the
asset allocation strategy selected by SWG. However, this transition process may take some time to
accomplish. Some investments may not be unwound for a lengthy period of time for a variety of
reasons that may include unwarranted low share prices, restrictions on trading, contractual
restrictions on liquidity, or market-related liquidity concerns. In some cases, there may be securities
or investments that are never able to be sold. The inability to transition a client's holdings into
recommendations of SWG may adversely affect the client's account values, as SWG’s
recommendations may not be able to be fully implemented.
• Restriction Risk. Clients may at all times place reasonable restrictions on the management of their
accounts. However, placing these restrictions may make managing the accounts more difficult, thus
lowering the potential for returns.
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• Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in value.
All securities will have periods of time when the current price of the security is not an accurate
measure of its value. If you require us to liquidate your portfolio during one of these periods, you will
not realize as much value as you would have had the investment had the opportunity to regain its
value. Further, some investments are made with the intention of the investment appreciating over an
extended period of time. Liquidating these investments prior to their intended time horizon may result
in losses.
• REITs: In very limited circumstances, SWG may recommend that portions of client portfolios be
allocated to real estate investment trusts, otherwise known as “REITs”. A REIT is an entity, typically a
trust or corporation, that accepts investments from a number of investors, pools the money, and then
uses that money to invest in real estate through either actual property purchases or mortgage loans.
While there are some benefits to owning REITs, which include potential tax benefits, income, and the
relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also
have some increased risks as compared to more traditional investments such as stocks, bonds, and
mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen may
have a focus such as commercial real estate or real estate in a given location. Such investment focus
can be beneficial if the properties are successful but lose significant principal if the properties are not
successful. REITs may also employ significant leverage for the purpose of purchasing more investments
with fewer investment dollars, which can enhance returns but also enhances the risk of loss. The
success of a REIT is highly dependent upon the manager of the REIT. Clients should ensure they
understand the role of the REIT in their portfolio.
• Excess Cash Balance Risk. Client accounts may have cash balances in excess of $250,000, which is
the insurance limit of the Federal Deposit Insurance Corporation. For cash balances in excess of that
amount, there is an enhanced risk that operation related counterparty risk related to the account
custodian could cause losses in the account. We mitigate this risk by carrying cash balances in amounts
either subject to protection or as limited as you, the client, directs. You may elect to participate in a
“cash sweep” program through your account custodian which automatically moves excess cash from
your investment account into a cash account and then invests that cash into cash-based investments,
such as money market funds. We do not receive compensation of any kinds for facilitating your
participation in such cash sweep accounts.
• Environmental, Social and Governance. While ESG is only one of the many factors SWG will
consider in making investment decisions, there is no guarantee that SWG will successfully implement
and make investments that create positive environmental, social or governance (“ESG”) impact while
enhancing long-term growth and achieving financial returns. Successful investment efforts on the part
of SWG will depend upon SWG’s skill in properly identifying and analyzing material ESG and other
factors to determine their impact-related value, and there can be no assurance that the strategy or
techniques employed will be successful. Considering ESG qualities when evaluating an investment may
result in the selection or exclusion of certain investments based on SWG’s view of certain ESG- related
factors. As a result, the integration of ESG-related data carries with it the risk that SWG may
underperform investments that do not take ESG-related factors into account.
• Artificial Intelligence. SWG utilizes artificial intelligence platforms for the purpose of non-specific
research regarding general industry metrics, public filings summaries, and general economic
indicators. In addition, SWG may, in the future, utilize the platforms for the purpose of assisting in
creating marketing materials or general communications. SWG will at no time provide any client
information to any artificial intelligence platform. In addition, SWG will always evaluate the results of
any artificial intelligence use, and will not unilaterally accept the output from artificial intelligence
platforms for the purpose of determining investment advice.
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Item 9:
Disciplinary Information
There are no disciplinary items to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Broker-dealer
Please see response to Item 5E with regards to Purshe Kaplan Sterling Investments Inc.
B. Futures Commission Merchant/Commodity Trading Advisor
Neither the principal of SWG, nor any related persons are registered, or have an application pending
to register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or an associated person of the foregoing entities.
C. Relationship with Related Persons
Certain professionals of SWG are separately licensed as independent insurance agents for purposes of
servicing existing clients that have insurance products. SWG does not intend to sell new insurance
products but has the ability to do so if warranted. As such, these professionals may conduct insurance
product transactions for SWG clients in their capacity as licensed insurance agents and will receive
customary commissions for these transactions in addition to any compensation received from advisory
services. Commissions from the sale of insurance products will not be used to offset or as a credit
against advisory fees. These certain professionals therefore have an incentive to recommend
insurance products based on the compensation to be received. The receipt of additional fees for
insurance commissions is therefore a conflict of interest, and clients should be aware of this conflict
when considering whether to engage SWG to implement any insurance recommendations. SWG
attempts to mitigate this conflict of interest by disclosing the conflict to clients and informing the
clients that they are always free to purchase insurance products through other agents that are not
affiliated with SWG, or to determine not to purchase the insurance product at all. SWG also attempts
to mitigate the conflict of interest by requiring employees to acknowledge in the firm’s Code of Ethics,
their individual fiduciary duty to the clients of SWG, which requires that employees put the interests
of clients ahead of their own.
Erik Potts has personal investments in entities where clients of Summit Wealth manage these entities.
This presents a conflict where Mr. Potts has an opportunity to personally gain from the business efforts
of the client and the client’s company, which may incentivize Mr. Potts to render investment advice to
such client on the basis of what Mr. Potts believes would likely improve his personal investment
performance rather than that of the client in question. These investments are not presented to other
clients. However, in the event such an opportunity were to be presented to other clients, that
participation would be in the client’s sole discretion. Further, the investment is segregated from the
investment management assets for which Summit Wealth provides advice. We attempt to mitigate
the conflict is mitigated by disclosing it to the client in question, by reiterating to all employees of
Summit Wealth the fiduciary obligations of each employee, and through the monitoring of private
investments as discussed in the Firm’s Code of Ethics.
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D. Recommendations of Other Advisers
SWG occasionally recommends other advisers, and SWG may be compensated by the independent
manager for referring clients. For more information regarding SWG’s use of third-party managers
please see response to Item 8 for a full discussion. A conflict of interest exists for Advisers who
recommend the services of a third-party manager who has agreed to share a portion of its
management fee with the Adviser as opposed to other managers who have not agreed to pay
compensation to the Adviser. Compensation paid to the Adviser from various third-party managers
may vary; therefore, there is a conflict of interest in recommending a manager who shares a larger
portion of its advisory fees over another manager. Fees for such programs may be higher or lower
than if client directly obtained services of the third-party manager or if client obtained advisory
services separately.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. Code of Ethics
A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of our
fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines.
B. Recommendations Involving Material Financial Interests
Not applicable. SWG does not recommend to clients that they invest in any security in which SWG or
any principal thereof has any financial interest.
Investing Personal Money in the Same Securities as Clients
C.
On occasion, an employee of SWG may purchase for his or her own account securities which are also
recommended for clients. Our Code of Ethics details rules for employees regarding personal trading
and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade
before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades
are reviewed by the Compliance Officer. All employee trades must either take place in the same block
as a client trade or sufficiently apart in time from the client trade, so the employee receives no added
benefit. Employee statements are reviewed to confirm compliance with the trading procedures.
D. Trading Securities At/Around the Same Time as Clients’ Securities
On occasion, an employee of SWG may purchase for his or her own account securities which are also
recommended for clients at the same time the clients purchase the securities. Our Code of Ethics
details rules for employees regarding personal trading and avoiding conflicts of interest related to
trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or
after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All
employee trades must either take place in the same block as a client trade or sufficiently apart in time
from the client trade, so the employee receives no added benefit. Employee statements are reviewed
to confirm compliance with the trading procedures.
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Item 12: Brokerage Practices
Recommendation of Broker-Dealer
A.
SWG does not maintain custody of client assets, though SWG may be deemed to have custody if a
client grants SWG authority to debt fees directly from their account (see Item 15 below). Assets will
be held with a qualified custodian, which is typically a bank or broker-dealer. SWG recommends that
investment accounts be held in custody by Schwab Advisor Services (“Schwab”), which is a qualified
custodian. SWG is independently owned and operated and is not affiliated with Schwab. Schwab will
hold your assets in a brokerage account and buy and sell securities when SWG instructs them to, which
SWG does in accordance with its agreement with you. While SWG recommends that you use Schwab
as custodian/broker, you will decide whether to do so and will open your account with Schwab by
entering into an account agreement directly with them. SWG does not open the account for you,
although SWG may assist you in doing so. Even though your account is maintained at Schwab, we can
still use other brokers to execute trades for your account as described below (see “Your brokerage and
custody costs”).
How we select brokers/custodians
We seek to recommend a custodian/broker that will hold your assets and execute transactions on
terms that are, overall, most advantageous when compared with other available providers and their
services. We consider a wide range of factors, including both quantitative (Ex: costs) and qualitative
(execution, reputation, service) factors. We do not consider whether Schwab or any other broker-
dealer/custodian, refers clients to SWG as part of our evaluation of these broker-dealers.
Your brokerage and custody costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it
executes or that settle into your Schwab account. These fees are in addition to the commissions or
other compensation you pay the executing broker-dealer. Because of this, in order to minimize your
trading costs, we have Schwab execute most trades for your account. We have determined that having
Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best
execution means the most favorable terms for a transaction based on all relevant factors, including
those listed above (see “How we select brokers/custodians”).
Products and services available to us from Schwab
Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving
independent investment advisory firms like SWG. They provide SWG and our clients with access to its
institutional brokerage services (trading, custody, reporting, and related services), many of which are
not typically available to Schwab retail customers. Schwab also makes available various support
services. Some of those services help SWG manage or administer our clients’ accounts, while others
help SWG manage and grow our business. Schwab’s support services are generally available on an
unsolicited basis (we don’t have to request them) and at no charge to SWG. Following is a more
detailed description of Schwab’s support services:
Services that benefit you
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Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this
paragraph generally benefit you and your account.
Services that may not directly benefit you.
Schwab also makes available to us other products and services that benefit us but may not directly
benefit you or your account. These products and services assist us in managing and administering our
clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We
may use this research to service all or a substantial number of our clients’ accounts, including accounts
not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements)
Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
Facilitate payment of our fees from our clients’ accounts
•
• Provide pricing and other market data
•
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us.
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to us. Schwab may also discount or waive its fees for some of these services or
pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as
occasional business entertainment of our personnel.
Our interest in Schwab’s services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon
us committing any specific amount of business to Schwab in trading commissions or assets in custody.
We may have an incentive to recommend that you maintain your account with Schwab, based on our
interest in receiving Schwab’s services that benefit our business rather than based on your interest in
receiving the best value in custody services and the most favorable execution of your transactions.
This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian
and broker is in the best interests of our clients. Our selection is primarily supported by the scope,
quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s
services that benefit only us.
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Directed Brokerage
SWG generally recommends that clients utilize Schwab Advisor Services. However, in very limited
circumstances, SWG will allow directed brokerage arrangements (when a client requires that account
transactions be effected through a specific broker-dealer). In such client directed arrangements, the
client will negotiate terms and arrangements for their account with that broker-dealer, and SWG will
not seek better execution services or prices from other broker-dealers or be able to “batch” the client's
transactions for execution through other broker-dealers with orders for other accounts managed by
SWG. As a result, clients may pay higher commissions or other transaction costs or greater spreads, or
receive less favorable net prices, on transactions for the account than would otherwise be the case.
We do not consider whether Schwab or any other broker-dealer/custodian, refers clients to SWG as
part of our evaluation of these broker-dealers.
Aggregating Trades
B.
Commission costs per client may be lower on a particular trade if all clients in whose accounts the trade
is to be made are executed at the same time. This is called aggregating trades. Instead of placing a number
of trades for the same security for each account, we will, when appropriate, executed one trade for all
accounts and then allocate the trades to each account after execution. If an aggregate trade is not fully
executed, the securities will be allocated to client accounts on a pro rata basis, except where doing so
would create an unintended adverse consequence (For example, if a pro rata division would result in a
client receiving a fraction of a share, or a position in the account of less than 1%.)
Item 13:
Review of Accounts
All accounts and corresponding financial plans will be managed on an ongoing basis, with formal
reviews with the client by a senior or lead advisor on at least an annual basis. However, it is expected
that market conditions, changes in a particular client’s account, or changes to a client’s circumstances
will trigger a review of accounts.
The annual report in writing provided by SWG is intended to review asset allocation. All clients will
receive statements and confirmations of trades directly from Schwab. Additionally, all clients will
receive quarterly itemized Statement of Fees from SWG. Please refer to Item 15 regarding Custody.
Item 14:
Client Referrals and Other Compensation
A. Economic Benefit Provided by Third Parties for Advice Rendered to Client.
Please refer to Item 12, where we discuss recommendation of Broker-Dealers.
B. Compensation to Non-Advisory Personnel for Client Referrals.
If a client is introduced to SWG by either an unaffiliated or an affiliated solicitor, SWG may pay
that solicitor a referral fee in accordance with the requirements of Rule 206(4)-1 of the Investment
Advisers Act of 1940, and any corresponding state securities law requirements. Unaffiliated or
affiliated solicitors will be licensed in accordance with applicable state laws. Any such referral fee
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shall be paid solely from SWG’s investment management fee, and shall not result in any additional
charge to the client. If the client is introduced to SWG by an unaffiliated solicitor, the solicitor, at
the time of the solicitation, shall disclose the nature of the solicitor relationship, and shall provide
each prospective client with a copy of SWG’s. ADV and a copy of the written disclosure statement
from the solicitor to the client disclosing the terms of the solicitation arrangement between SWG
and the solicitor, including the compensation to be received by the solicitor from SWG.
The solicitation or referral of prospective clients by an adviser’s existing client (“promoter”) is a
testimonial, and the solicitation or referral of prospective clients by anyone else (also “promoter”)
is an endorsement. Testimonials also include statements by an adviser’s existing client about the
existing client’s experience with the adviser, even if not explicitly constituting a solicitation or
referral of the adviser. Endorsements also include statements by non-clients that indicate
approval, support, or recommendation of the adviser, even if not explicitly constituting a
solicitation or referral of the adviser.
Item 15:
Custody
There are two avenues through which SWG has custody of client funds; by directly debiting its fees
from client accounts pursuant to applicable agreements granting such right, and potentially by
permitting clients to issue standing letters of authorization (“SLOAs”). SLOAs permit a client to issue
one document that directs SWG to make distributions out of the client’s account(s).
Clients whose fees are directly debited will provide written authorization to debit advisory fees from
their accounts held by a qualified custodian chosen by the client. Each quarter, clients will receive a
bill itemizing the fees to be debited, including the formula used to calculate the fee, the amount of
assets the fee is based, and the time period covered by the fee. The invoice will also state that the fee
was not independently calculated by the custodian. The client will also receive a statement from their
account custodian showing all transactions in their account, including the fee.
We encourage clients to carefully review the statements and confirmations sent to them by their
custodian, and to compare the information on your quarterly report prepared by SWG against the
information in the statements provided directly from Schwab. Please alert us of any discrepancies.
In addition to the account custodian’s custody procedures, clients issuing SLOAs will be requested to
confirm, in writing, that the accounts to which funds are distributed are parties unrelated to SWG.
Item 16:
Investment Discretion
When SWG is engaged to provide asset management services on a discretionary basis, we will monitor
your accounts to ensure that they are meeting your asset allocation requirements. If any changes are
needed to your investments, we will make the changes. These changes may involve selling a security
or group of investments and buying others or keeping the proceeds in cash. You may at any time place
restrictions on the types of investments we may use on your behalf, or on the allocations to each
security type. You may receive at your request written or electronic confirmations from your account
custodian after any changes are made to your account. You will also receive monthly statements from
your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited
Power of Attorney (granting us the discretionary authority over the client accounts) as well as an
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Investment Management Agreement that outlines the responsibilities of both the client and SWG.
Item 17:
Voting Client Securities
Copies of our Proxy Voting Policies are available upon request.
From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities
may be permitted to vote on various types of corporate actions. Examples of these actions include
mergers, tender offers, or board elections. Clients are required to vote proxies related to their
investments, or to choose not to vote their proxies. SWG will not accept authority to vote client
securities. Clients will receive their proxies directly from the custodian for the client account. In some
circumstances, SWG will give clients advice on how to vote proxies.
Item 18:
Financial Information
SWG does not require the prepayment of fees more than six (6) months or more in advance and
therefore has not provided a balance sheet with this brochure.
There are no material financial circumstances or conditions that would reasonably be expected to
impair our ability to meet our contractual obligations to our clients.
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ITEM ONE: COVER PAGE
FORM ADV PART 2B BROCHURE SUPPLEMENT:
THOMAS C. HARTMAN
SUMMIT WEALTH GROUP, LLC
205 Billings Farm Road, Suite 2A | White River Junction, VT 05001
20B Hampton Road | Exeter, NH 03833
(802) 295-5300 | www.summitwg.com
Erik Randall, CCO
Version: January 31, 2025
This Brochure Supplement provides information about Thomas C. Hartman that supplements the Summit
Wealth Group, LLC Brochure. You should have received a copy of that Brochure. Please contact Erik Randall at
the number above if you did not receive Summit Wealth Group, LLC Brochure or if you have any questions
about the contents of this supplement. Registration does not imply any certain level of skill or training.
Additional information about Thomas C. Hartman is available on the SEC’s website at www.adviserinfo.sec.gov.
1
Item 2: Educational Background and Business Experience
Thomas C. Hartman
Born: 1961
EDUCATION:
Castleton State College, BS, AS – Accounting, Computer Sciences, 1983
Nasson College, attended, 1981
BUSINESS EXPERIENCE:
Summit Wealth Group, LLC
Principal, 01/2016 – present
Chief Compliance Officer, 1/2016 – 01/2025
Purshe Kaplan Sterling Investments, Inc.
Registered Representative, 01/2016 – 12/2023
Summit Wealth Realty LLC
Co-Owner, 06/2004 – 12/2024
Cambridge Investment Research Advisors, Inc.
Investment Advisor Representative, 03/2005- 01/2016
Cambridge Investment Research, Inc.
Registered Representative, 11/2003- 01/2016
PROFESSIONAL DESIGNATIONS:
CERTIFIED FINANCIAL PLANNER® professional
Individuals who are certified for financial planning services in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”). Therefore, may refer to themselves as a CERTIFIED FINANCIAL
PLANNER® professional or a CFP® professional, and may use these and the other certification marks (the “CFP
Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning,
Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law
or regulation requires financial planners to hold the CFP® certification. You may find more information about
the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® professional, an individual must fulfill the following requirements:
•
Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The
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•
•
•
coursework covers the financial planning subject areas CFP Board has determined are necessary for the
competent and professional delivery of financial planning services, as well as a comprehensive financial
plan development capstone course. A candidate may satisfy some of the coursework requirement
through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher
requirement in 2007 and the financial planning development capstone course requirement in March
2012. Therefore, a CFP® professional who first became certified before those dates may not have earned
a bachelor’s or higher degree or completed a financial planning development capstone course.
Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
Experience – Complete 6,000 hours of professional experience related to the personal financial planning
process, or 4,000 hours of apprenticeship experience that meets additional requirements.
Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals
Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct
(“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board Certification Marks:
•
•
Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP
Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP®
professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional's services. A client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the client.
Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Certified Public Accountant
To become a CPA in the United States, the candidate must sit for and pass the Uniform Certified Public
Accountant Examination (Uniform CPA Exam), which is set by the American Institute of Certified Public
Accountants and administered by the National Association of State Boards of Accountancy. The CPA was
established in law on April 17, 1896.
Eligibility to sit for the Uniform CPA Exam is determined by individual State Boards of Accountancy. Typically
the requirement is a U.S. bachelor’s degree which includes a minimum number of qualifying credit hours in
accounting and business administration with an additional 1 year study. This requirement for 5 years study is
known as the "150 hour rule" and has been adopted by the majority of state boards, although there are still
some exceptions (e.g. California). This requirement mandating 150 hours of study has been adopted by 45
states.
3
The primary functions CPA fulfill relate to assurance services, or public accounting. In assurance services, also
known as financial audit services, CPAs attest to the reasonableness of disclosures, the freedom from material
misstatement, and the adherence to the applicable generally accepted accounting principles (GAAP) in
financial statements. CPAs can also be employed by corporations-termed "the private sector"-in finance
functions such as Chief Financial Officer (CFO) or finance manager, or as CEOs subject to their full business
knowledge and practice. These CPAs do not provide services directly to the public.
CPAs also have a niche within the income tax preparation industry. They may also provide business
consultation in the areas of entity set-up, QuickBooks assistance, financial statements, and buying v. leasing of
equipment.
Whether providing services directly to the public or employed by corporations or associations, CPAs can
operate in virtually any area of finance. While some CPAs are generalists and offer a range of services
(especially those in small practices) many CPAs specialize in just one area and do not provide all services.
Individuals who become certified must complete the following ongoing ethics and education requirements in
order to maintain the right to continue to use the CPA marks:
• Ethics -- Over 40 of the state boards now require applicants for CPA status to complete a special
examination on ethics, which is effectively a Fourth E in terms of requirements to become a CPA. The
majority of these will accept the AICPA self-study Professional Ethics for CPAs CPE course or another
course in general professional ethics. Many states, however, require that the ethics course include a
review of that state's specific rules for professional practice.
• Continuing Professional Education (CPE)--CPAs are required to take continuing education courses in
order to renew their license. Requirements vary by state but the vast majority requires 120 hours of
CPE every 3 years with a minimum of 20 hours per calendar year. The requirement can be fulfilled
through attending live seminars, webcast seminars, or through self-study (textbooks, videos, online
courses, all of which require a test to receive credit). As part of the CPE requirement, most states
require their CPAs to take an ethics course during every renewal period. Again, ethics requirements
vary by state but the courses range from 2-8 hours.
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Mr. Hartman.
Item 4:
Other Business Activities
Mr. Hartman is separately licensed as an independent insurance agent for purposes of servicing existing clients
that have insurance products. SWG does not intend to sell new insurance products but can do so if warranted.
As such, Mr. Hartman may conduct insurance product transactions for SWG clients in his capacity as licensed
insurance agent and will receive customary commissions for these transactions in addition to any
compensation received from advisory services. Commissions from the sale of insurance products will not be
used to offset or as a credit against advisory fees. Mr. Hartman therefore has an incentive to recommend
insurance products based on the compensation to be received. The receipt of additional fees for insurance
commissions is therefore a conflict of interest, and clients should be aware of this conflict when considering
4
whether to engage SWG or utilize Mr. Hartman to implement any insurance recommendations. SWG attempts
to mitigate this conflict of interest by disclosing the conflict to clients, and informing the clients that they are
always free to purchase insurance products through other agents that are not affiliated with SWG, or to
determine not to purchase the insurance product at all. SWG also attempts to mitigate the conflict of interest
by requiring employees to acknowledge in the firm’s Code of Ethics, their individual fiduciary duty to the clients
of SWG, which requires that employees put the interests of clients ahead of their own.
Item 5:
Additional Compensation
Please see response to Item 4, above.
Item 6:
Supervision
Mr. Hartman is a principal of the firm, and is supervised by Erik Randall, the firm’s Chief Compliance Officer.
In addition, all employees of SWG are required to follow the supervisory guidelines and procedures manual
which is designed to ensure compliance with securities laws in the states where SWG is registered.
5
ITEM ONE: COVER PAGE
FORM ADV PART 2B BROCHURE SUPPLEMENT:
ABIGAIL L. HURLBURT
SUMMIT WEALTH GROUP, LLC
205 Billings Farm Road, Suite 2A | White River Junction, VT 05001
20B Hampton Road | Exeter, NH 03833
(802) 295-5300 | www.summitwg.com
Erik Randall, CCO
Version: January 31, 2025
This Brochure Supplement provides information about Abigail L. Hurlburt that supplements the Summit
Wealth Group, LLC Brochure. You should have received a copy of that Brochure. Please contact Erik Randall
at the number above if you did not receive Summit Wealth Group, LLC Brochure or if you have any questions
about the contents of this supplement. Registration does not imply any certain level of skill or training.
Additional information about Abigail L. Hurlburt is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2:
Educational Background and Business Experience
6
Abigail L. Hurlburt
Born: 1972
EDUCATION:
University of Colorado, BS – Environmental Science, 1994
BUSINESS EXPERIENCE:
Summit Wealth Group, LLC
Principal, 01/2016 – present
Purshe Kaplan Sterling Investments, Inc.
Registered Representative, 01/2016 – 10/2016
Cambridge Investment Research Advisors, Inc.
Investment Advisor Representative, 09/2013- 01/2016
Cambridge Investment Research, Inc.
Registered Representative, 09/2013- 01/2016
New England Securities
Registered Representative, 05/2003 – 09/2013
PROFESSIONAL DESIGNATIONS:
CERTIFIED FINANCIAL PLANNER® professional
Individuals who are certified for financial planning services in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”). Therefore, may refer to themselves as a CERTIFIED FINANCIAL
PLANNER® professional or a CFP® professional, and may use these and the other certification marks (the “CFP
Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning,
Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law
or regulation requires financial planners to hold the CFP® certification. You may find more information about
the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® professional, an individual must fulfill the following requirements:
•
Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The
coursework covers the financial planning subject areas CFP Board has determined are necessary for the
competent and professional delivery of financial planning services, as well as a comprehensive financial
plan development capstone course. A candidate may satisfy some of the coursework requirement
through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher
requirement in 2007 and the financial planning development capstone course requirement in March
7
•
•
•
2012. Therefore, a CFP® professional who first became certified before those dates may not have earned
a bachelor’s or higher degree or completed a financial planning development capstone course.
Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
Experience – Complete 6,000 hours of professional experience related to the personal financial planning
process, or 4,000 hours of apprenticeship experience that meets additional requirements.
Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals
Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct
(“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board Certification Marks:
•
•
Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP
Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP®
professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional's services. A client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the client.
Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Retirement Income Certified Professional
The Retirement Income Certified Professional (RICP®) designation is granted by The American College and
requires three college-level courses with anticipated total study and preparation time of 150 hours.
Prerequisite of three years of fulltime, relevant business experience are required. The three courses required
are: Retirement Income Process, Strategies & Solutions; Sources of Retirement Income; and Managing the
Retirement Income Plan. Three closed-book, course specific, two-hour proctored exams must be passed. A
total of 15 hours of continuing education every two years through The American College's PACE recertification
program are required. Designees must adhere to The American College's Code of Ethics. Designation may be
removed for unethical conduct through the Certification Committee of The American College's Board of
Trustees.
Registered Life Planner
The Registered Life Planner® (RLP®) is a course of study offered through the Kinder Institute that includes a
client-centered financial planning, to include:
comprehensive curriculum in
• The 2-day Seven Stages of Money Maturity® Workshop: A New Model for Developing Client
Relationships
8
• The Life Planning Advanced Training: Applying the EVOKE® Life Planning Methodology to Client
Engagements
• The RLP® Mentorship: A 6-month Online Case Study Seminar
Successful completion of the curriculum qualifies participants to receive the Registered Life Planner® (RLP®)
designation. Every two years, designation holders must complete continuing education (CE) requirements to
maintain their qualification. CE requirements include 16 hours of life planning with at least eight hours
from programs offered by the Kinder Institute (up to four hours may come from non-Kinder Institute
programs that have been reviewed an accredited by the Kinder Institute),
and of the 6 hours, at least
four hours must be devoted to additional training on the EVOKE® method either from the institute or another
accredited program. [EVOKE® = Exploration, Vision, Obstacles, Knowledge and Execution]
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Ms. Hurlburt.
Item 4:
Other Business Activities
Ms. Hurlburt is the owner of Summit Wealth Realty LLC, the entity that operates the Vermont office for Summit
Wealth Group LLC.
Item 5:
Additional Compensation
Other than salary, annual bonuses, or regular bonuses, Ms. Hurlburt does not receive any economic benefit
from any person, company, or organization, in exchange for providing clients advisory services through SWG.
Item 6:
Supervision
Ms. Hurlburt is a principal of the firm, and is supervised by Erik Randall, the firm’s Chief Compliance Officer. In
addition, all employees of SWG are required to follow the supervisory guidelines and procedures manual which
is designed to ensure compliance with securities laws in the states where SWG is registered.
9
ITEM ONE: COVER PAGE
FORM ADV PART 2B BROCHURE SUPPLEMENT:
ERIK M. POTTS
SUMMIT WEALTH GROUP, LLC
205 Billings Farm Road, Suite 2A | White River Junction, VT 05001
20B Hampton Road | Exeter, NH 03833
(802) 295-5300 | www.summitwg.com
Erik Randall, CCO
Version: January 31, 2025
This Brochure Supplement provides information about Erik M. Potts that supplements the Summit Wealth
Group, LLC Brochure. You should have received a copy of that Brochure. Please contact Erik Randall at the
number above if you did not receive Summit Wealth Group, LLC Brochure or if you have any questions about
the contents of this supplement. Registration does not imply any certain level of skill or training. Additional
information about Erik M. Potts is available on the SEC’s website at www.adviserinfo.sec.gov.
10
Item 2:
Educational Background and Business Experience
Erik M. Potts
Born: 1980
EDUCATION:
Bachelor of Science in Finance from Bentley University in 2003
BUSINESS EXPERIENCE:
Summit Wealth Group, LLC
Principal, 01/2021 – present
Purshe Kaplan Sterling Investments, Inc.
Registered Representative, 2020 - present
Panorama Wealth Strategies, LLC
Principal & Chief Compliance Officer, 08/2014 to 12/2020
Cambridge Investment Research Advisors, Inc.
Investment Advisor Representative, 08/2014 to 2020
Cambridge Investment Research, Inc.
Registered Representative, 08/2014 to 2020
New England Securities Corporation
Registered Representative, 02/2003 to 08/2014
PROFESSIONAL DESIGNATIONS:
CERTIFIED FINANCIAL PLANNER® professional
Individuals who are certified for financial planning services in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”). Therefore, may refer to themselves as a CERTIFIED FINANCIAL
PLANNER® professional or a CFP® professional, and may use these and the other certification marks (the “CFP
Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning,
Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law
or regulation requires financial planners to hold the CFP® certification. You may find more information about
the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® professional, an individual must fulfill the following requirements:
11
•
•
•
•
Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The
coursework covers the financial planning subject areas CFP Board has determined are necessary for the
competent and professional delivery of financial planning services, as well as a comprehensive financial
plan development capstone course. A candidate may satisfy some of the coursework requirement
through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher
requirement in 2007 and the financial planning development capstone course requirement in March
2012. Therefore, a CFP® professional who first became certified before those dates may not have earned
a bachelor’s or higher degree or completed a financial planning development capstone course.
Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
Experience – Complete 6,000 hours of professional experience related to the personal financial planning
process, or 4,000 hours of apprenticeship experience that meets additional requirements.
Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals
Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct
(“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board Certification Marks:
•
•
Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP
Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP®
professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional's services. A client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the client.
Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Retirement Income Certified Professional
The Retirement Income Certified Professional (RICP®) designation is granted by The American College and
requires three college-level courses with anticipated total study and preparation time of 150 hours.
Prerequisite of three years of fulltime, relevant business experience are required. The three courses required
are: Retirement Income Process, Strategies & Solutions; Sources of Retirement Income; and Managing the
Retirement Income Plan. Three closed-book, course specific, two-hour proctored exams must be passed. A
total of 15 hours of continuing education every two years through The American College's PACE recertification
program are required. Designees must adhere to The American College's Code of Ethics. Designation may be
removed for unethical conduct through the Certification Committee of The American College's Board of
Trustees.
12
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Mr. Potts.
Item 4:
Other Business Activities
To permit SWG clients to have access to as many investment solutions as possible, certain professionals of
SWG are registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), a FINRA member
broker-dealer. The relationship with PKS allows these professionals to provide additional products to clients’
portfolios that would not otherwise be available. Because PKS supervises the activities of these professionals
as registered representatives of PKS, the relationship may be deemed material. However, PKS is not affiliated
with SWG or considered a related party. PKS does not make investment decisions for client accounts.
Registered representative status enables these professionals to receive customary commissions for the sales
of various securities, including those he recommends to clients. Commissions charged for these products will
not offset management fees owed to SWG.
Receipt of commissions for investment products that are recommended to clients gives rise to a conflict of
interest for the representative, in that the individual who will receive the commissions is also the individual
that is recommending that the client purchase a given product. This conflict is disclosed to clients verbally and
in this brochure. Clients are advised that they may choose to implement any investment recommendation
through another broker-dealer that is not affiliated with SWG. SWG attempts to mitigate this conflict by
requiring that all investment recommendations have a sound basis for the recommendation, and by requiring
employees to acknowledge their fiduciary responsibility toward each client.
Mr. Potts is separately licensed as an independent insurance agent for purposes of servicing existing clients
that have insurance products. SWG does not intend to sell new insurance products, but has the ability to do
so if warranted. As such, Mr. Potts may conduct insurance product transactions for SWG clients in his capacity
as licensed insurance agent, and will receive customary commissions for these transactions in addition to any
compensation received from advisory services. Commissions from the sale of insurance products will not be
used to offset or as a credit against advisory fees. Mr. Potts therefore has an incentive to recommend
insurance products based on the compensation to be received. The receipt of additional fees for insurance
commissions is therefore a conflict of interest, and clients should be aware of this conflict when considering
whether to engage SWG or utilize Mr. Potts to implement any insurance recommendations. SWG attempts to
mitigate this conflict of interest by disclosing the conflict to clients, and informing the clients that they are
always free to purchase insurance products through other agents that are not affiliated with SWG, or to
determine not to purchase the insurance product at all. SWG also attempts to mitigate the conflict of interest
by requiring employees to acknowledge in the firm’s Code of Ethics, their individual fiduciary duty to the clients
of SWG, which requires that employees put the interests of clients ahead of their own.
In addition, Mr. Potts has the following outside business activities. We do not believe any of these activities is
significant to advisory clients or the advisory business:
• Mr. Potts owns a number of real estate properties and manages them: Hangar 14 LLC, Skyfall LLC, and
13
20B Hampton Road LLC. We do not believe these real estate properties or the management thereof
present a material conflict of interest with advisory clients. In addition, Mr. Potts is the owner of Apex
Aviation LLC, an entity which owns a recreational aircraft. The amount of time spent on these holdings
is not significant.
• Mr. Potts occasionally races cars as a hobby. We include disclosure of this item because Mr. Potts
occasionally receives discounted auto parts in exchange for displaying company logos on his race car.
Item 5:
Additional Compensation
Please see response to Item 4, above.
Item 6:
Supervision
Mr. Potts is a principal of the firm and is supervised by Erik Randall, the firm’s Chief Compliance Officer.
Additionally, all employees of SWG are required to follow the supervisory guidelines and procedures manual
which is designed to ensure compliance with securities laws in the states where SWG is registered.
14
ITEM ONE: COVER PAGE
FORM ADV PART 2B BROCHURE SUPPLEMENT:
HEATHER S. MEEKS
SUMMIT WEALTH GROUP, LLC
205 Billings Farm Road, Suite 2A | White River Junction, VT 05001
20B Hampton Road | Exeter, NH 03833
(802) 295-5300 | www.summitwg.com
Erik Randall, CCO
Version: January 31, 2025
This Brochure Supplement provides information about Heather S. Meeks that supplements the Summit Wealth
Group, LLC Brochure. You should have received a copy of that Brochure. Please contact Erik Randall at the
number above if you did not receive Summit Wealth Group, LLC Brochure or if you have any questions about
the contents of this supplement. Registration does not imply any certain level of skill or training. Additional
information about Heather S. Meeks is available on the SEC’s website at www.adviserinfo.sec.gov.
15
Item 2:
Educational Background and Business Experience
Heather S. Meeks
Born: 1968
EDUCATION:
Southern New Hampshire University, MBA – Business Administration, 1999
Bentley University, BS – Finance, 1990
BUSINESS EXPERIENCE:
Summit Wealth Group, LLC
Lead Advisor, 01/2016 – present
Cambridge Investment Research Advisors, Inc.
Investment Advisor Representative, 06/2008- 01/2016
Cambridge Investment Research, Inc.
Registered Representative, 06/2008- 01/2016
PROFESSIONAL DESIGNATIONS:
CERTIFIED FINANCIAL PLANNER® professional
Individuals who are certified for financial planning services in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”). Therefore, may refer to themselves as a CERTIFIED FINANCIAL
PLANNER® professional or a CFP® professional, and may use these and the other certification marks (the “CFP
Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning,
Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law
or regulation requires financial planners to hold the CFP® certification. You may find more information about
the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® professional, an individual must fulfill the following requirements:
•
Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The
coursework covers the financial planning subject areas CFP Board has determined are necessary for the
competent and professional delivery of financial planning services, as well as a comprehensive financial
plan development capstone course. A candidate may satisfy some of the coursework requirement
through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher
requirement in 2007 and the financial planning development capstone course requirement in March
16
•
•
•
2012. Therefore, a CFP® professional who first became certified before those dates may not have earned
a bachelor’s or higher degree or completed a financial planning development capstone course.
Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
Experience – Complete 6,000 hours of professional experience related to the personal financial planning
process, or 4,000 hours of apprenticeship experience that meets additional requirements.
Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals
Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct
(“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board Certification Marks:
•
•
Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP
Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP®
professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional's services. A client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the client.
Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Ms. Meeks.
Item 4:
Other Business Activities
Ms. Meeks is currently a Trustee of the Trust Funds for the Town of Cornish, NH. Trustees of Trust Funds are
the custodian of the town’s perpetual care funds, charitable trusts, and capital reserve/expendable trust funds.
Trustees of Trust Funds make the decisions regarding expenditure from these funds based on the wishes of
the donor in the case of privately donated funds and release capital reserve funds and expendable trust funds
to the appropriate government officials upon request. Trustees of Trust Funds make the decisions on how
these funds are to be invested based on the investment policy adopted by the Trustees. Ms. Meeks is not
compensated for her role as Trustee, and spends approximately 3 to 5% of her time on this activity.
Item 5:
Additional Compensation
Other than salary, annual bonuses, or regular bonuses, Ms. Meeks does not receive any economic benefit from
any person, company, or organization, in exchange for providing clients advisory services through SWG.
17
Item 6:
Supervision
Ms. Meeks is supervised by the Firm’s Principal and Chief Compliance Officer, Erik Randall. Additionally, all
employees of SWG are required to follow the supervisory guidelines and procedures manual which is designed
to ensure compliance with securities laws in the states where SWG is registered.
18
ITEM ONE: COVER PAGE
FORM ADV PART 2B BROCHURE SUPPLEMENT:
ERIK H. RANDALL
SUMMIT WEALTH GROUP, LLC
205 Billings Farm Road, Suite 2A | White River Junction, VT 05001
20B Hampton Road | Exeter, NH 03833
(802) 295-5300 | www.summitwg.com
Erik Randall, CCO
Version: January 31, 2025
This Brochure Supplement provides information about Erik H. Randall that supplements the Summit Wealth
Group, LLC Brochure. You should have received a copy of that Brochure. Please contact Erik Randall at the
number above if you did not receive Summit Wealth Group, LLC Brochure or if you have any questions about
the contents of this supplement. Registration does not imply any certain level of skill or training. Additional
information about Erik H. Randall is available on the SEC’s website at www.adviserinfo.sec.gov.
19
Item 2:
Educational Background and Business Experience
Erik H. Randall
Born: 1983
EDUCATION:
Franklin Pierce College, BA – Accounting/Finance, 2010
BUSINESS EXPERIENCE:
Summit Wealth Group, LLC
Lead Advisor and Chief Operations Officer, 05/2011 – present
Chief Compliance Officer, 01/2025 - present
Cambridge Investment Research Advisors, Inc.
Investment Advisor Representative, 03/2015- 01/2016
Cambridge Investment Research, Inc.
Registered Representative, 06/2014- 01/2016
PROFESSIONAL DESIGNATIONS:
CERTIFIED FINANCIAL PLANNER® professional
Individuals who are certified for financial planning services in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”). Therefore, may refer to themselves as a CERTIFIED FINANCIAL
PLANNER® professional or a CFP® professional, and may use these and the other certification marks (the “CFP
Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning,
Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law
or regulation requires financial planners to hold the CFP® certification. You may find more information about
the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® professional, an individual must fulfill the following requirements:
•
Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The
coursework covers the financial planning subject areas CFP Board has determined are necessary for the
competent and professional delivery of financial planning services, as well as a comprehensive financial
plan development capstone course. A candidate may satisfy some of the coursework requirement
through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher
requirement in 2007 and the financial planning development capstone course requirement in March
20
•
•
•
2012. Therefore, a CFP® professional who first became certified before those dates may not have earned
a bachelor’s or higher degree or completed a financial planning development capstone course.
Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
Experience – Complete 6,000 hours of professional experience related to the personal financial planning
process, or 4,000 hours of apprenticeship experience that meets additional requirements.
Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals
Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct
(“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to
remain certified and maintain the right to continue to use the CFP Board Certification Marks:
•
•
Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP
Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP®
professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional's services. A client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the client.
Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Mr. Randall.
Item 4:
Other Business Activities
Registered investment advisers are required to disclose all material facts regarding any investment related
outside business activity. No information is applicable to this Item for Mr. Randall.
Item 5:
Additional Compensation
Other than salary, annual bonuses, or regular bonuses, Mr. Randall does not receive any economic benefit
from any person, company, or organization, in exchange for providing clients advisory services through SWG.
21
Item 6:
Supervision
While Mr. Randall is the Firm’s Chief Compliance Officer, he is supervised by the other principals of the Firm.
Additionally, all employees of SWG are required to follow the supervisory guidelines and procedures manual
which is designed to ensure compliance with securities laws in the states where SWG is registered.
22
ITEM ONE: COVER PAGE
FORM ADV PART 2B BROCHURE SUPPLEMENT:
KATHERINE ADAMS
SUMMIT WEALTH GROUP, LLC
205 Billings Farm Road, Suite 2A | White River Junction, VT 05001
20B Hampton Road | Exeter, NH 03833
(802) 295-5300 | www.summitwg.com
Erik Randall, CCO
Version: January 31, 2025
This Brochure Supplement provides information about Katherine Adams that supplements the Summit Wealth
Group, LLC Brochure. You should have received a copy of that Brochure. Please contact Erik Randall at the
number above if you did not receive Summit Wealth Group, LLC Brochure or if you have any questions about
the contents of this supplement. Registration does not imply any certain level of skill or training. Additional
information about Katherine Adams is available on the SEC’s website at www.adviserinfo.sec.gov.
23
Item 2:
Educational Background and Business Experience
Katherine Adams
Born: 1965
EDUCATION:
Brown University, BA – Linguistics, 1987
BUSINESS EXPERIENCE:
Summit Wealth Group, LLC
Client Relationship Manager, 01/2016 – present
Cambridge Investment Research Advisors, Inc.
Investment Advisor Representative, 09/2012- 01/2016
Cambridge Investment Research, Inc.
Registered Representative, 09/2012- 01/2016
Morgan Stanley Smith Barney,
Mass Transfer, 04/2007 – 10/2011
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Ms. Adams.
Item 4:
Other Business Activities
Registered investment advisers are required to disclose all material facts regarding any investment related
outside business activity. No information is applicable to this Item for Ms. Adams.
Item 5:
Additional Compensation
Other than salary, annual bonuses, or regular bonuses, Ms. Adams does not receive any economic benefit from
any person, company, or organization, in exchange for providing clients advisory services through SWG.
Item 6:
Supervision
Ms. Adams is supervised by the Firm’s Chief Compliance Officer, Erik Randall. Additionally, all employees of
SWG are required to follow the supervisory guidelines and procedures manual which is designed to ensure
compliance with securities laws in the states where SWG is registered.
24
ITEM ONE: COVER PAGE
FORM ADV PART 2B BROCHURE SUPPLEMENT:
ANDREW W. SCHWARZ
SUMMIT WEALTH GROUP, LLC
205 Billings Farm Road, Suite 2A | White River Junction, VT 05001
20B Hampton Road | Exeter, NH 03833
(802) 295-5300 | www.summitwg.com
Erik Randall, CCO
Version: January 31, 2025
This Brochure Supplement provides information about Andrew W. Schwarz that supplements the Summit
Wealth Group, LLC Brochure. You should have received a copy of that Brochure. Please contact Erik Randall at
the number above if you did not receive Summit Wealth Group, LLC Brochure or if you have any questions
about the contents of this supplement. Registration does not imply any certain level of skill or training.
Additional information about Andrew W. Schwarz is available on the SEC’s website at www.adviserinfo.sec.gov.
25
Item 2:
Educational Background and Business Experience
Andrew W. Schwarz
Born: 1991
EDUCATION:
Hartwick College, BA – Double Major: Economics & Business Administration, 2013
BUSINESS EXPERIENCE:
Summit Wealth Group, LLC
Portfolio Manager, 07/2012 – present
Cambridge Investment Research Advisors, Inc.
Investment Advisor Representative, 03/2015- 01/2016
Cambridge Investment Research, Inc.
Registered Representative, 05/2014- 01/2016
PROFESSIONAL DESIGNATIONS:
Chartered Financial Analyst
The Chartered Financial Analyst (CFA) designation is a globally respected, graduate-level investment credential
established in 1962 and awarded by the CFA Institute, the largest global association of investment
professionals.
To earn the CFA designation, candidates must (1) pass three sequential, six-hour examinations, (2) have at
least four years of qualified professional investment experience, (3) join the CFA Institute as members, and (4)
commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards
of Professional Conduct.
High Ethical Standards - The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced
through an active professional conduct program, requires CFA charter holders to:
•
•
•
•
•
Place their clients' interests ahead of their own
Maintain independence and objectivity
Act with integrity
Maintain and improve their professional competence
Disclose conflicts of interest and legal matters
Global Recognition - Passing the three CFA exams is a difficult feat that requires extensive study (successful
candidates report spending an average of 300 hours of study at each level). Earning the CFA charter
demonstrates mastery of many of the advanced skills needed for investment analysis and decision-making in
26
today's quickly evolving global financial industry. As a result, employers and clients are increasingly seeking
CFA charter holders, often making the charter a prerequisite for employment.
Additionally, regulatory bodies in 19 countries recognize the CFA charter as a proxy for meeting certain
licensing requirements. More than 125 colleges and universities around the world have incorporated a
majority of the CFA Program curriculum into their own finance courses.
Comprehensive and Current Knowledge - The CFA Program curriculum provides a comprehensive framework
of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every
day in the investment profession. The three levels of the CFA Program test proficiency in a wide range of
fundamental and advanced investment topics, including ethical and professional standards, fixed-income and
equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio
management, and wealth planning.
The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates
learn the most relevant and practical new tools, ideas, and investment management skills to reflect the
dynamic and complex nature of the profession.
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Mr. Schwarz.
Item 4:
Other Business Activities
Registered investment advisers are required to disclose all material facts regarding any investment related
outside business activity. No information is applicable to this Item for Mr. Schwarz.
Item 5:
Additional Compensation
Other than salary, annual bonuses, or regular bonuses, Mr. Schwarz does not receive any economic benefit
from any person, company, or organization, in exchange for providing clients advisory services through SWG.
Item 6:
Supervision
Mr. Schwarz is supervised by the Firm’s Chief Compliance Officer, Erik Randall. Additionally, all employees of
SWG are required to follow the supervisory guidelines and procedures manual which is designed to ensure
compliance with securities laws in the states where SWG is registered.
27
ITEM ONE: COVER PAGE
FORM ADV PART 2B BROCHURE SUPPLEMENT:
SARAH D. BROOKES-GOVERNO
SUMMIT WEALTH GROUP, LLC
205 Billings Farm Road, Suite 2A | White River Junction, VT 05001
20B Hampton Road | Exeter, NH 03833
(802) 295-5300 | www.summitwg.com
Erik Randall, CCO
Version: January 31, 2025
This Brochure Supplement provides information about Sarah D. Brookes-Governo that supplements the
Summit Wealth Group, LLC Brochure. You should have received a copy of that Brochure. Please contact Erik
Randall at the number above if you did not receive Summit Wealth Group, LLC Brochure or if you have any
questions about the contents of this supplement. Registration does not imply any certain level of skill or
training. Additional information about Sarah D. Brookes-Governo is available on the SEC’s website at
www.adviserinfo.sec.gov.
28
Item 2:
Educational Background and Business Experience
Sarah D. Brookes-Governo
Born: 1967
EDUCATION:
Temple University, BA – Political Science, 1991
Lebanon College, AAS – Accounting, 2006
BUSINESS EXPERIENCE:
Summit Wealth Group, LLC
Client Relationship Manager, 01/2016 – present
Cambridge Investment Research Advisors, Inc.
Client Relationship Manager, 09/2015- 01/2016
NBFS Inc.
Senior Tax Advisor, 09/2010 – 09/2015
Morgan Stanley
Financial Advisor, 07/2006 – 09/2008
PROFESSIONAL DESIGNATIONS:
ENROLLED AGENT (EA)
An Enrolled Agent (EA) is a federally‐authorized tax practitioner who has technical expertise in the field of
taxation and who is empowered by the U.S. Department of the Treasury to represent taxpayers before all
administrative levels of the Internal Revenue Service for audits, collections, and appeals.
“Enrolled” means to be licensed to practice by the federal government, and “Agent” means authorized to
appear in the place of the taxpayer at the IRS. Only Enrolled Agents, attorneys, and CPAs may represent any
taxpayer before the IRS. The Enrolled Agent profession dates back to 1884 when, after questionable claims
had been presented for Civil War losses, Congress acted to regulate persons who represented citizens in their
dealings with the U.S. Treasury Department. The license is earned in one of two ways: by passing a
comprehensive examination which covers all aspects of the tax code, or having worked at the IRS for five years
in a position which regularly interpreted and applied the tax code and its regulations. All candidates are
subjected to a rigorous background check conducted by the IRS.
Enrolled agents advise, represent, and prepare tax returns for individuals, partnerships, corporations, estates,
trusts, and any entities with tax-reporting requirements. Enrolled agents’ expertise in the continually changing
field of taxation enables them to effectively represent taxpayers at all administrative levels within the IRS.
The IRS Restructuring and Reform Act of 1998 allow federally authorized practitioners (those bound by the
Department of Treasury’s Circular 230 regulations) a limited client privilege. This privilege allows
29
confidentiality between the taxpayer and the enrolled agent under certain conditions. The privilege applies to
situations in which the taxpayer is being represented in cases involving audits and collection matters. It is not
applicable to the preparation and filing of a tax return. This privilege does not apply to state tax matters,
although a number of states have an accountant-client privilege.
In addition to the stringent testing and application process, the IRS requires Enrolled Agents to complete 72
hours of continuing professional education, reported every three years, to maintain their Enrolled Agent
status. Because of the knowledge necessary to become an Enrolled Agent and the requirements to maintain
the license, there are only about 46,000 practicing Enrolled Agents. Unlike attorneys and CPAs, who may or
may not choose to specialize in taxes, all Enrolled Agents specialize in taxation. Enrolled Agents are required
to abide by the provisions of the Department of Treasury’s Circular 230, which provides the regulations
governing the practice of Enrolled Agents before the IRS.
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Ms. Brookes-Governo.
Item 4:
Other Business Activities
Ms. Brookes-Governo does not have any outside business activities.
Item 5:
Additional Compensation
Other than salary, annual bonuses, or regular bonuses, Ms. Brookes-Governo does not receive any economic
benefit from any person, company, or organization, in exchange for providing clients advisory services through
SWG.
Item 6:
Supervision
Ms. Brookes-Governo is supervised by the Firm’s Chief Compliance Officer, Erik Randall. Additionally, all
employees of SWG are required to follow the supervisory guidelines and procedures manual which is designed
to ensure compliance with securities laws in the states where SWG is registered.
30
SUMMIT WEALTH GROUP
PRIVACY NOTICE
Categories of Personal Information We Collect
We have collected some or all of the following categories of personal information from individuals
within the last twelve (12) months:
▪
Identifiers, such as name, contact details and address (including physical address, email
address and Internet Protocol address), and other identification (including social security
number, passport number and drivers’ license or state identification card number);
▪ Other customer records, such as telephone number, signature, bank account number,
other financial information (including accounts and transactions with other institutions
and anti-money laundering information), and verification documentation and information
regarding clients’ status under various laws and regulations (including social security
number, tax status, income and assets);
▪ Protected classification characteristics under state or federal law, such as date of birth,
citizenship and birthplace;
▪
▪ Commercial information, such as account data and other information contained in any
document provided by clients to authorized service providers (whether directly or
indirectly), risk tolerance, transaction history, investment experience and investment
activity; and
Internet or other electronic network activity information, such as information regarding
your use of our website and client portal (e.g., cookies, browsing history and/or search
history), as well as information you provide to us when you correspond with us in relation
to inquiries.
Within the last twelve (12) months, we have shared each of the categories of personal information
collected with affiliates and third-party service providers, and we collect personal information from
the sources set forth above.
Purposes for Collecting Personal Information
We may collect or share the personal information we collect about you for one or more of the
following business or commercial purposes:
▪ performing services to you, including but not limited to:
•
the administrative processes (and related communication) in preparing for
account opening and closing and the processing of transactions;
• ongoing communication with you, your representatives, advisors and agents;
• ongoing operations, administrative, accounting, reporting, account maintenance
and other processes and communication required to invest, reinvest and
otherwise monitor your assets;
• keeping you informed about our business;
▪ auditing and verifications related to client interactions, including but not limited to,
verifying the quality and effectiveness of services and compliance;
▪ detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal
activity; and
▪ complying with U.S., state, local and non-U.S. laws, rules and regulations.
WE DO NOT SELL ANY OF THE PERSONAL INFORMATION WE COLLECT ABOUT YOU TO
THIRD PARTIES.
Deletion Rights
You have the right to request that we delete any of your personal information that we retain,
subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local
and non-U.S. laws, rules and regulations.
Disclosure and Access Rights
You have the right to request that we disclose to you certain information regarding our collection,
use, disclosure and sale of personal information specific to you over the last twelve (12) months.
Such information includes:
▪ The categories of personal information we collected about you;
▪ The categories of sources from which the personal information is collected;
▪ Our business or commercial purpose for collecting such personal information;
▪ Categories of third parties with whom we share the personal information;
▪ The specific pieces of personal information we have collected about you; and
▪ Whether we disclosed your personal information to a third party, and if so, the categories
of personal information that each recipient obtained.
No Discrimination
We will not discriminate against you for exercising your rights, including by denying service,
suggesting that you will receive, or charging, different rates for services or suggesting that you
will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights
To exercise any of your rights under applicable privacy laws, or to access this notice in an
alternative format, please submit a request using any of the methods set forth below.
telephone number by email
to a
Via email: ERandall@summitwg.com
Telephone: please submit your request and
ERandall@summitwg.com and we will call you between 9 a.m. and 6 p.m. Eastern Time.
We will contact you to confirm receipt of your request and request any additional information
necessary to verify your request. We verify requests by matching information provided in
connection with your request to information contained in our records. Depending on the sensitivity
of the request and the varying levels of risk in responding to such requests (for example, the risk
of responding to fraudulent or malicious requests), we may request additional information in order
to verify your request. You may designate an authorized agent to make a request on your behalf,
provided that you provide a signed agreement verifying such authorized agent’s authority to make
requests on your behalf, and we may verify such authorized person’s identity using the procedures
above.
*Some state laws give residents additional rights to limit sharing. Under these laws, we may not
be able to share information of minors who are of a certain age. In some states, this age is 13
years old. In order to share this information, we must first written permission (“opting-in”). If we
do not receive permission to share personal information, then we are prohibited from sharing it or
processing it for targeted advertising:
I give you permission to share my personal information:
Signature of Client(s): _____________________________
Printed Name: ___________________________________
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt
of such request. We will inform you in writing if we cannot meet that timeline. Please contact Erik
Randall, the Chief Compliance Officer of Summit Wealth Group, at ERandall@summitwg.com
with any questions about this Privacy Notice.
PRIVACY NOTICE SUPPLEMENT: CALIFORNIA RESIDENTS
California law requires us to disclose that you may request to be placed on our “do not call” list at
any time by calling us at 802-295-5300. To obtain further information, contact The Office of the
California Attorney General at P.O. Box 944255, Sacramento, CA 94244; phone (916) 210-6276.
PRIVACY NOTICE SUPPLEMENT: COLORADO RESIDENTS
Colorado law requires us to disclose that you may request to be placed on our “do not call” list at
any time by calling us at 802-295-5300. To obtain further information, contact The Office of the
Attorney General, Colorado Department of Law at 1300 Broadway, 10th Floor, Denver, CO 80203;
phone (720) 508-6000.
PRIVACY NOTICE SUPPLEMENT: CONNECTICUT RESIDENTS
Connecticut law requires us to disclose that you may request to be placed on our “do not call” list at
any time by calling us at 802-295-5300. To obtain further information, contact The Office of the
Attorney General, 165 Capitol Avenue, Hartford, CT 06106; phone (860) 808-5318; email
Attorney.General@ct.gov.
PRIVACY NOTICE SUPPLEMENT: NEVADA RESIDENTS
Nevada law requires us to disclose that you may request to be placed on our “do not call” list at any
time by calling us at 802-295-5300. To obtain further information, contact The Bureau of Consumer
Protection, Office of the Nevada Attorney General at 555 E. Washington Ave., Suite 3900, Las
Vegas, NV 88101; phone (888) 434-9989; email BCPINFO@ag.state.nv.us.
PRIVACY NOTICE SUPPLEMENT: UTAH RESIDENTS
Utah law requires us to disclose that you may request to be placed on our “do not call” list at any
time by calling us at 802-295-5300. To obtain further information, contact The Office of the Attorney
General, P.O. Box 142320, Salt Lake City, UT 84114; phone (801) 366-0260; email
uag@agutah.gov.
PRIVACY NOTICE SUPPLEMENT: VIRGINIA RESIDENTS
Virginia law requires us to disclose that you may request to be placed on our “do not call” list at any
time by calling us at 802-295-5300. To obtain further information, contact The Office of the Attorney
General, 202 North Ninth Street, Richmond, VA 23219; phone (804) 786-2071.