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Summit Wealth Group LLC
Form ADV Part 2A – Disclosure Brochure
Effective: July 21, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of the Advisor (“Summit Wealth Group LLC” or the “Advisor”). If you have any questions about the
content of this Disclosure Brochure, please contact the Advisor at (719) 633-4033.
The Advisor is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training.
This Disclosure Brochure provides information about the Advisor to assist you in determining whether to retain
the Advisor.
Additional information about the Advisor and its advisory persons is available on SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335242.
Summit Wealth Group LLC
13710 Struthers Road, Suite 115, Colorado Springs, CO 80921
Phone: (719) 633-4033 | Website: www.summitwealthgroup.com
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Item 2. Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of the Advisor. For convenience, the Advisor has combined these documents into a single disclosure
document.
The Advisor believes that communication and transparency are the foundation of its relationship with clients
and will continually strive to provide you with complete and accurate information at all times. The Advisor
encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you
may have with the Advisor.
Material Changes
The following material changes have been made since the last filing of the adviser’s disclosure brochure:
• The Advisors’ assets under management have been updated.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335242.
You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (719) 633-
4033.
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Item 3. Table of Contents
Item 2. Material Changes .......................................................................................................................................... 2
Item 3. Table of Contents .......................................................................................................................................... 3
Item 4. Advisory Business ......................................................................................................................................... 4
Item 5. Fees and Compensation................................................................................................................................ 6
Item 6. Performance-Based Fees and Side-by-Side Management ........................................................................... 7
Item 7. Types of Clients ............................................................................................................................................. 7
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ...................................................................... 7
Item 9. Disciplinary Information ................................................................................................................................. 9
Item 10. Other Financial Industry Activities and Affiliations ........................................................................................ 9
Item 11. Code of Ethics ............................................................................................................................................ 10
Item 12. Brokerage Practices ................................................................................................................................... 10
Item 13. Review of Accounts .................................................................................................................................... 11
Item 14. Client Referrals and Other Compensation .................................................................................................. 11
Item 15. Custody ....................................................................................................................................................... 12
Item 16. Investment Discretion ................................................................................................................................. 12
Item 17. Voting Client Securities ............................................................................................................................... 13
Item 18. Financial Information .................................................................................................................................. 13
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Item 4. Advisory Business
Summit Wealth Group LLC (“Summit Wealth” or “the Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as an LLC under the laws of the State of
Colorado. Summit Wealth was founded in February 2025 and became a registered investment advisor in April
2025. Summit Wealth is owned and operated by Summit Wealth Group, Inc.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Summit Wealth. For more information regarding this Disclosure Brochure, please contact
Christine Heroux, Chief Compliance Officer, at (859) 309-8274.
Investment Management Services
Summit Wealth offers wealth management services including investment management and financial planning
services to individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, and
retirement plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the
applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards
each Client and seeks to mitigate potential conflicts of interest. Summit Wealth’s fiduciary commitment is further
described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 –
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
The Advisor provides wealth management services specific to the needs of each individual client. Prior to
formulating any investment allocation recommendation, we will work with our clients to ascertain each client’s
financial profile, demographical information, financial goals, liquidity needs, time horizon and willingness and ability
to assume risk, as well as any special considerations relevant to the formulation of the client’s investment program.
The advisors will then determine an appropriate target investment allocation for each client. We may use third-party
managers to provide clients with certain strategies or asset allocations, based upon the information you provide us
with.
Client investment portfolios generally include a mix of individual equity securities, mutual funds, individual bonds
and exchange traded funds. The decision of which target allocation, and which type of investments are utilized will
be made in accordance with the client's stated investment objective and risk/volatility parameters. Where
appropriate, clients may also engage the Advisor to manage and/or advise on certain investment products that are
not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in
employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). The Advisor will direct or make
recommendations on a non-discretionary basis for the allocation of client assets among the various investment
options available within the product. These assets are generally maintained at the underwriting insurance company
or custodian for the plan trustee or administrator and clients retain responsibility for effecting trades in these
accounts.
Clients may, at any time, request restrictions on or customizations to their accounts. However, we reserve the right
not to accept and/or terminate the management of a client account if we feel that the customizations or restrictions
imposed by the client, in our opinion, prevent us from managing the account in a manner that is consistent with the
client’s stated investment objectives.
In addition to the services mentioned above, the Advisor may provide its clients with a broad range of
comprehensive financial planning services. Our Advisors review a client’s financial situation which includes a
review of all assets, liabilities, estate, tax and insurance needs. We will conduct an analysis of cash flow, risk
tolerance, investment objectives and other evaluation tools to develop a proposed asset allocation.
Clients are advised to promptly notify the Advisor if there are changes in their financial situation or investment
objectives or if they wish to impose any reasonable restrictions upon the Advisor’s management services.
Financial Planning Services
The Advisor starts with an extensive review of a client's financial situation which includes assets and liabilities as
well as estate, tax, and insurance needs. The Firm then employs a risk tolerance and risk capacity-focused
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simulation to get a detailed cash flow analysis and proposed asset allocation. Financial planning services are
typically offered independently of our investment management services. Financial plans include, but are not limited
to:
•
investment planning
•
life insurance and annuities
•
tax concerns
•
retirement planning
•
college planning
• debt/credit planning
The Advisor may recommend clients engage the firm for additional related services as part of the financial plan, or
we may recommend other professionals to implement recommendations made by the Advisor. Clients are under
no obligation to act upon any recommendations made by the Advisor under a financial planning engagement or to
engage the services of a third-party professional. Clients retain the absolute right to decide whether to act on such
recommendations, and if they choose to act on such recommendations, whether to engage the Firm or such
professional for such services or to engage another investment adviser or professional of their choosing, which may
charge less (or more) for such services. Should a client choose to implement the recommendations contained in
the plan, the Advisor suggests the client work closely with his/her attorney, accountant and/or insurance agent.
Implementation of financial plan recommendations is entirely at the client's discretion. Financial planning
recommendations are of a generic nature and are not limited to any specific product or service offered by a broker
dealer or insurance company. The Advisor will act solely in its capacity as a registered investment advisor and does
not provide any legal, accounting or tax advice. Client should seek the counsel of a qualified accountant and/or
attorney when necessary. The Advisor may assist clients with tax harvesting, and we will work with a client’s tax
specialist to answer any questions related to the client’s portfolio account.
Retirement Plan Advisory Services
Summit Wealth provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the
Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor.
Services generally include:
Investment Oversight
• Plan Participant Enrollment and Education Tracking
•
• Ongoing Investment Recommendation and Assistance
These services are provided by Summit Wealth serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the
Plan Sponsor is provided with a written description of Summit Wealth’s fiduciary status, the specific services to be
rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Recommending Rollovers and Transfers
As part of our investment advisory services to you, we may recommend that you withdraw the assets from your
employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage
on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest
because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for
the purpose of generating fee-based compensation rather than solely based on your needs. You are under no
obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are
under no obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also, current
employees can sometimes move assets out of their company plan before they retire or change jobs. In determining
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whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider
the costs and benefits of: Leaving the funds in your employer's (former employer's) plan; 2) moving the funds to a
new employer's retirement plan; 3) cashing out and taking a taxable distribution from the plan; and/or 4) rolling the
funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making
a change we encourage you to speak with your CPA and/or tax attorney. Our recommendations may include any
of them, depending on what we feel is in your best interest.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you
regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning
of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which
are laws governing retirement accounts. As a fiduciary, we are required to document the reason(s) for why the
recommendation we made is in your best interest.
Assets Under Management
As of May 16, 2025, Summit Wealth has a total of $1,353,760,295 in discretionary assets under management.
Item 5. Fees and Compensation
In addition to the information provided in Item 4 – Advisory Business, this section provides additional details
regarding our firm’s services along with descriptions of each service’s fees and compensation arrangements. It
should be noted that lower fees for comparable service may be available from other sources. The exact fees
and other terms will be outlined in the agreement between you and the Advisor.
Investment Management Fee (also referred to as “Advisory Fee”)
Fees charged for our investment management services are charged based on a percentage of assets under
management, billed quarterly in advance, calculated based on the previous quarter end. Fees are prorated
(based on the number of days service is provided during the initial billing period) when your account is opened
at any time other than the beginning of the billing period. If investment management services commence in the
middle of a billing period, the prorated fee for the initial billing period is billed in arrears at the same time as the
next full billing period’s fee is billed.
The asset management services continue in effect until terminated. You may terminate the services by providing
the Advisor with notice. The Advisor may terminate the services by providing you with written notice effective
30 days after you receive the written notice. Any prepaid, unearned fees will be promptly refunded by the Advisor
to you. Fee refunds will be determined on a pro rata basis using the number of days services are actually
provided during the final period.
Fees are negotiable based on the investment adviser representative providing the services, the type of client,
the complexity of the client's situation, the composition of the client's account (i.e., equities versus mutual funds),
the potential for additional account deposits, the relationship of the client with the investment adviser
representative, and the total amount of assets under management for the client.
To have fees deducted from your account, you must authorize the qualified custodian(s) of your account to
deduct fees from your account and pay such fees directly to Summit Wealth. You should review your account
statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are
being deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted.
Clients may incur certain fees or charges imposed by third parties in connection with investments made on
behalf of the Client’s account[s]. Summit Wealth includes Covered Costs as part of its overall wealth
management fee through the Summit Wealth Wrap Fee Program. Securities transaction fees for Client-directed
trades may be charged back to the Client.
In addition, all fees paid to Summit Wealth for wealth management services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees
for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting),
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and a possible distribution fee. A Client may be able to invest in these products directly, without the services of
Summit Wealth, but would not receive the services provided by Summit Wealth which are designed, among
other things, to assist the Client in determining which products or services are most appropriate for each Client’s
financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s]
and the fees charged by Summit Wealth to fully understand the total fees to be paid.
Financial Planning Fees
Fees charged for our financial planning services are negotiable based upon the type of client, the services
requested, the investment adviser representative providing advice, the complexity of the client's situation, the
composition of the client's account, other advisory services provided and the relationship of the client and the
investment adviser representative.
The fees for financial planning and/or consulting services are billed on a project basis. A mutually agreed upon fixed
fee is charged for financial planning services under this arrangement which will be outlined in your financial planning
agreement. There is no minimum fee required for financial planning or consulting services.
The Advisor may request a retainer to initiate financial planning and consulting services. However, we will not
request the prepayment of fees more than $1,200 in advisory fees more than six months in advance.
For financial planning services performed by the Advisor under a fixed fee arrangement, you will pay the Advisor a
pro-rated fixed fee equivalent to the percentage of work completed as determined by the Advisor. In the event there
is a remaining balance of any fees paid in advance after the deduction of fees from the final invoice, those remaining
proceeds will be refunded to you.
Item 6. Performance-Based Fees and Side-by-Side Management
The Advisor does not provide any services for performance-based fees. Performance-based fees are those based
on a share of capital gains on or capital appreciation of the assets of a client.
Item 7. Types of Clients
Summit Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations, businesses, and retirement plans. Summit Wealth generally does not impose a
minimum relationship size.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Summit Wealth employs several analysis methods in developing investment strategies for its Clients. Research
and analysis from Summit Wealth are derived from numerous sources, including financial media companies,
third-party research materials, Internet sources, and review of company activities, including annual reports,
prospectuses, press releases and research prepared by others.
Technical Analysis: Involves studying past price patterns, trends and interrelationships in the financial
markets to assess risk-adjusted performance and predict the direction of both the overall market and
specific securities.
Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect
anomalies or predict future price movements. Current prices of securities may reflect all information known about
the security and day-to-day changes in market prices of securities may follow random patterns and may not be
predictable with any reliable degree of accuracy.
Fundamental Analysis: Involves analyzing individual companies and their industry groups, such as a
company's financial statements, details regarding the company's product line, the experience and expertise of
the company's management, and the outlook for the company and its industry. The resulting data is used to
measure the true value of the company's stock compared to the current market value.
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Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not
provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust
rapidly to new information, utilizing fundamental analysis may not result in favorable performance.
Cyclical Analysis: A type of technical analysis that involves evaluating recurring price patterns and trends.
Economic/business cycles may not be predictable and may have many fluctuations between long-term
expansions and contractions.
Risk: The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of
cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of
securities that would be affected by these changing trends.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully identify market
tops or bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
Our investment strategies and advice may vary depending upon each client's specific financial situation. As
such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time
horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines
may affect the composition of your portfolio. It is important that you notify us immediately with respect to
any material changes to your financial circumstances, including for example, a change in your current or
expected income level, tax circumstances, or employment status.
Margin Transactions: A securities transaction in which an investor borrows money to purchase a security,
in which case the security serves as collateral on the loan.
Risk: If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into
the account or sell a portion of the stock to maintain the margin requirements of the account. This is known as a
"margin call." An investor's overall risk includes the amount of money invested plus the amount that was loaned
to them.
Alternatives: A financial asset that does not fall into one of the conventional investment categories. Alternative
investments can include private equity or venture capital, hedge funds, managed futures, art and antiques,
commodities, and derivatives contracts. Real estate is also often classified as an alternative investment.
Risk: Alternatives are less liquid than many other investments, with some private funds and real estate
investments having set periods in which the assets invested cannot be redeemed and that investment cannot be
sold. There is also a higher risk of loss of principal with alternative assets, in part due to the illiquidity of these
types of investments.
Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which invests in real
estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can
be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to
declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations,
so cash flow has to be strong or the REIT must either dip into reserves, borrow to pay dividends, or distribute
them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must
refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are
demanding, and getting, harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary
stock offerings to repay debt, which will lead to additional dilution of the stockholders. Fluctuations in the real
estate market can affect the REIT's value and dividends.
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Private Placements: A private placement (non-public offering) is an illiquid security sold to qualified investors
and are not publicly traded nor registered with the Securities and Exchange Commission.
Risk: Private placements generally carry a higher degree of risk due to illiquidity. Most securities that are
acquired in a private placement will be restricted securities and must be held for an extended amount of time
and therefore cannot be sold easily. The range of risks is dependent on the nature of the partnership and are
disclosed in the offering documents.
Other Risk Considerations
When evaluating risk, financial loss may be viewed differently by each client and may depend on many different
risks, each of which may affect the probability and magnitude of any potential losses. The following risks may
not be all-inclusive but should be considered carefully by a prospective client before retaining our services.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility
or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at
all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed
income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an
issuer's securities held by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in
inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the
purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher
interest rates which may cause the value of many types of fixed income investments to decline.
Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen
event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold
for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity Risk is
the risk of outliving your savings. This risk is particularly relevant for people who are retired or are nearing
retirement.
Item 9. Disciplinary Information
The Advisor is required to disclose the facts of any legal or disciplinary events that are material to a client’s
evaluation of its advisory business or the integrity of management. The Advisor does not have any required
disclosures to this Item.
Item 10. Other Financial Industry Activities and Affiliations
Broker Dealer Affiliation
Some of our advisory representatives are also registered representatives and investment adviser representatives
of Purshe Kaplan Sterling Investments (“PKS”) a registered broker/dealer, member FINRA/SIPC, and registered
investment adviser. If you choose to implement your financial plan through PKS, commissions may be earned by
your advisory representative in addition to any fees paid for advisory services. In addition, where applicable, the
advisory representative is entitled to a portion of the internal expense fees (such as 12b-1 fees) charged by
mutual funds.
licensed
insurance professionals.
Implementations of
Insurance Agency Affiliations
Certain Advisory Persons are also
insurance
recommendations are separate and apart from an Advisory Person’s role with Summit Wealth. As an insurance
professional, an Advisory Person may receive customary commissions and other related revenues from the
various insurance companies whose products are sold. Advisory Persons are not required to offer the products
of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory
fees. This may cause a conflict of interest in recommending certain products of the insurance companies. Clients
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are under no obligation to implement any recommendations made by Advisory Persons or the Advisor.
Use of Independent Managers
The Advisor may implement all or a portion of a Client’s investment portfolio with one or more Independent
Managers. The Advisor does not receive any compensation, nor does this present a material conflict of interest.
The Advisor will only earn its wealth management fee as described in Item 5.A.
Item 11. Code of Ethics
The Advisor is committed to providing investment advice with the utmost professionalism and integrity. Our firm
strives to identify, manage and/or mitigate conflicts of interest and has adopted policies, procedures and oversight
mechanisms to address conflicts of interest. We have adopted a Code of Ethics that emphasizes our fiduciary
obligation to put client interests first and is designed to ensure personal securities transactions, activities, and
interests of employees will not interfere with the responsibilities to make decisions in the best interest of clients. All
supervised persons must acknowledge and comply with our Code of Ethics.
Employee Personal Trading
The Advisor and persons associated with The Advisor (“Associated Persons”) are permitted to buy or sell
securities that it also recommends to clients consistent with The Advisor’s policies and procedures. The Advisor
has adopted a code of ethics that sets forth the standards of conduct expected of its associated persons and
requires compliance with applicable securities laws (“Code of Ethics”). The Advisor’s Code of Ethics contains
written policies reasonably designed to prevent the unlawful use of material non-public information by the
Advisor or any of its associated persons. The Code of Ethics also requires that certain of the Advisor’s personnel
(called “Access Persons”) report their personal securities holdings and transactions and obtain pre-approval of
certain investments such as initial public offerings and limited offerings.
The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the
employees of the Advisor will not interfere with (i) making decisions in the best interest of advisory clients and (ii)
implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under
the Code of Ethics, certain classes of securities have been designated as exempt transactions, based upon a
determination that these would materially not interfere with the best interest of the Advisor’s clients. Nonetheless,
because the Code of Ethics would permit employees to invest in the same securities as clients, there is a possibility
that employees might benefit from market activity by a client in a security held by an employee. Employee trading
is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between the
Advisor and its clients. Certain affiliated accounts may trade in the same securities with client accounts on an
aggregated basis when consistent with the Advisor’s obligation of best execution. In such circumstances, the
affiliated and client accounts will share commission costs equally and receive securities at a total average price.
The Advisor’s will retain records of the trade order (specifying each participating account) and its allocation, which
will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the
initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the
order.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money
market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase
agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares
issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested
exclusively in one or more mutual funds.
This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets
to permit transactions by Access Persons to be completed without any appreciable impact on the markets of
such securities. Therefore, under certain limited circumstances, exceptions may be made to the policies stated
above. Clients and prospective clients may contact the Advisor to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
The Advisor may recommend the brokerage and custodial services of SEI Investments Management Corp.
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(“SEI”). SEI is a registered broker-dealer that charges brokerage commissions or transaction fees for effecting
securities transactions. The Advisor recommends the services of SEI based on a number of factors including
financial strength, reputation, execution, pricing, responsiveness, fees, research, and other services.
The Advisor may recommend the brokerage and custodial services of Fidelity Brokerage Services, LLC.
(“Fidelity”). Fidelity is a registered broker-dealer that charges brokerage commissions or transaction fees for
effecting securities transactions. The Advisor recommends the services of Fidelity based on a number of factors
including financial strength, reputation, execution, pricing, responsiveness, fees, research, and other services.
Directed Brokerage
You may direct us, in writing, to use a particular custodian/broker-dealer to execute some or all the transactions
for your account. In this case, you are responsible for negotiating the terms and arrangements for the account
with the custodian/broker-dealer. We will not be able to negotiate commissions, obtain volume discounts or best
execution pricing. In addition, under these circumstances, a difference in commission charges may exist
between the commissions charged to clients who direct us to use a particular custodian/ broker-dealer and
clients who do not direct us to use a particular custodian/broker-dealer.
Aggregation of Orders
Certain trades may be aggregated, (i.e. blocked or bunched). The blocking of trades permits the trading of
aggregate blocks of securities composed of assets from multiple client accounts where transaction costs are shared
equally and on a pro-rated basis between all accounts included in the block. Block trading allows us to execute
equity or fixed income trades in a timely, equitable manner and to reduce overall commission charges to clients.
Clients who do not provide the Advisor with discretion will not participate in block trades, and their trades in similar
securities will be placed with brokers after trades for discretionary accounts. Accounts owned by supervised persons
of our firm may participate in block trading with your accounts; however, these individuals will not be given
preferential treatment of any kind.
Item 13. Review of Accounts
The Advisor monitors clients’ portfolios as part of an ongoing process while regular account reviews are conducted
on at least an annual basis for clients. For those clients to whom the Advisor provides financial planning and/or
consulting services, reviews are conducted on an “as needed” basis. All investment advisory clients are
encouraged to discuss their needs, goals, and objectives with the Advisor and to keep the Advisor informed of any
changes thereto. The Advisor contacts ongoing investment advisory clients at least annually to review its previous
services and/or recommendations and to discuss the impact of any changes in the client’s financial situation
and/or investment objectives.
Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary
account statements directly from the broker-dealer or custodian for the client accounts. Clients should compare
the account statements they receive from their custodian with those they receive from the Advisor. Those clients to
whom the Advisor provides financial planning and/or consulting services will receive reports from the Advisor
summarizing its analysis and conclusions upon request and as otherwise agreed to in writing by the Advisor.
Item 14. Client Referrals and Other Compensation
The Advisor is required to disclose any relationship or arrangement where it receives an economic benefit from a
third party (non-client) for providing advisory services. In addition, The Advisor is required to disclose any direct
or indirect compensation that it provides to any person who is not a supervised person for client referrals.
We may enter into written agreements with certain unaffiliated investment advisers, financial institutions and other
professionals (such as CPAs, attorneys, etc.) to compensate them for referring clients to us. We will pay these
individuals (referred to as “solicitors”) a percentage of the advisory fee that you pay us if it is determined that you
have become a client of ours as a result of their direct or indirect efforts.
The payments we make to a solicitor will not result in an increase in the amount of the advisory fee that the referred
client will pay.
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Our solicitation or referral arrangements will comply with applicable laws that govern:
the nature of the services provided
the fees to be paid
•
•
• disclosure of solicitor arrangements to clients
•
client consents, as required
The Advisor receives compensation from SEI and Fidelity, the broker-dealer used for your account, and your
account custodian in the form of access to electronic systems that assist us in the management of client accounts,
as well as research, software and other technology that provide access to client account data (such as trade
confirmations and account statements), pricing information and other market data, facilitate trade execution (and
allocation of aggregated trade orders for multiple client accounts), and client reporting capabilities. Trade-PMR
provided our firm with nominal funding to assist with startup expenses establishing our business entity. Your account
custodian also offers the Advisor discounts for products and services offered by vendors and third-party service
providers, such as software and technology solutions. These economic benefits create a conflict of interest in that
it gives our firm an incentive to recommend one broker-dealer or custodian over another that does not provide
similar electronic systems, support or services. We address this conflict of interest by disclosing to our clients the
types of compensation that our firm receives so clients can consider this when evaluating our firm. It is important
that you consider the fees, level of service and investment strategies, among other factors, when selecting an
investment manager.
Item 15. Custody
When you establish a relationship with our firm for investment management services, your assets will be maintained
by a bank, broker-dealer, mutual fund transfer agent or other such institution deemed a ‘qualified custodian’ by the
SEC. We rely on the custodian to price and value assets, execute and clear transactions, maintain custody of assets
in your account and perform other custodial functions. The Advisor does not maintain physical possession of any
client account assets. Clients’ assets must be held by a bank, broker dealer, mutual fund transfer agent or other
such institution deemed a qualified custodian. We utilize SEI and Fidelity as qualified custodians for client accounts.
Nevertheless, the Advisor is deemed to have custody, pursuant to Rule 206(4)-2 of the Investment Advisers Act of
1940, as amended, due to its authority over certain accounts deduct advisory fees from Client accounts and to
distribute assets subject to a third-party standing letter of authorization. The firm relies on the seven requirements
outlined in the SEC’s No-Action Letter to the Investment Advisers Associated, dated February 21, 2017, which
provides relief from an annual surprise custody examination by an independent public accountant.
You will receive monthly and/or quarterly account statements directly from the qualified custodian. The Advisor may
also provide you with written quarterly performance reports for your account. We urge you to carefully review your
account statements and compare the account balances with the balances reflected on any performance report you
may receive from our firm for accuracy. Balances on our reports may vary slightly from custodial statements due to
differences in accounting procedures, reporting dates, valuation methodologies of certain securities or other
operational factors. You should promptly notify us if you do not receive account statements from your custodian at
least quarterly or if you believe the information on your account statements is inaccurate.
Item 16. Investment Discretion
The Advisor generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may
be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and
agreed to by the Advisor. Discretionary authority will only be authorized upon full disclosure to the Client. The
granting of such authority will be evidenced by the Client’s execution of a wealth management agreement
containing all applicable limitations to such authority. All discretionary trades made by the Advisor will be in
accordance with each Client’s investment objectives and goals.
Typically, under third-party investment management arrangements, the third-party investment manager exercises
discretion in the management of your account. All securities transactions are selected and executed by that
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manager. We do not manage or obtain discretionary authority over the assets in those accounts. You may, however,
grant us the discretionary authority to hire and fire such third-party managers on your behalf.
Item 17. Voting Client Securities
Summit Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the
Client retains the sole responsibility for proxy decisions and voting.
Item 18. Financial Information
Neither Summit Wealth, nor its management, have any adverse financial situations that would reasonably impair
the ability of Summit Wealth to meet all obligations to its Clients. Neither Summit Wealth, nor any of its Advisory
Persons, have been subject to a bankruptcy or financial compromise. Summit Wealth is not required to deliver a
balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more
for services to be performed six months or more in the future.
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Summit Wealth Advisors LLC
Form ADV Part 2A – Appendix 1 Wrap Fee Program Brochure
Effective: July 21, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of the Advisor (“Summit Wealth Group LLC” or the “Advisor”). If you have any questions about the
content of this Disclosure Brochure, please contact the Advisor at (719) 633-4033.
The Advisor is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training.
This Disclosure Brochure provides information about the Advisor to assist you in determining whether to retain
the Advisor.
Additional information about the Advisor and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 335242.
Summit Wealth Advisors LLC
13710 Struthers Road, Suite 115, Colorado Springs, CO 80921
Phone: (719) 633-4033 | Website: www.summitwealthgroup.com
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Item 2. Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes
materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is
required to notify you and provide you with a description of the material changes.
The following material changes have been made since the last filing of the adviser’s disclosure brochure:
• None.
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Item 3. Table of Contents
Item 2 Material Changes ............................................................................................................................ 15
Item 3 Table of Contents ............................................................................................................................ 16
Item 4 Services, Fees, and Compensation ................................................................................................ 17
Item 5 Account Requirements and Types of Clients .................................................................................. 18
Item 6 Portfolio Manager Selection and Evaluation ................................................................................... 18
Item 7 Client Information Provided to Portfolio Managers .......................................................................... 19
Item 8 Client Contact with Portfolio Managers ........................................................................................... 19
Item 9 Requirements for State-Registered Advisers .................................................................................. 19
Item 10 Additional Information .................................................................................................................... 19
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Item 4. Services, Fees, and Compensation
Services
Summit Wealth Group, LLC (“Summit Wealth” or the “Advisor”) provides customized wealth management services
for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the Summit Wealth Disclosure
Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure
Brochure to provide full details of the business practices and fees when selecting Summit Wealth as your
investment advisor.
As part of the wealth management fees noted in Item 5 of the Disclosure Brochure, Summit Wealth includes
securities transaction fees (herein “Covered Costs”) as part of the overall wealth management fee. Securities
regulations often refer to this combined fee structure as a “Wrap Fee Program”.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination
of Covered Costs into a single “bundled” wealth management fee. This Wrap Fee Program Brochure references
back to the Summit Wealth Disclosure Brochure in which this Wrap Fee Program Brochure serves as an
Appendix. Please see Item 4 of the Disclosure Brochure for details on Summit Wealth’s investment philosophy
and related services
Program Costs
We charge an annual "wrap-fee" for participation in the Program depending upon the market value of your assets
under our management. You are not charged separate fees for the different components of the services provided
by the Program. Our firm pays all trade expenses of trades placed on your behalf. Our Program fee includes the
fee we pay to any portfolio manager for their management of your account and your brokers transaction or
execution costs. Assets in each of your account(s) are included in the fee assessment unless specifically
identified in writing for exclusion. In special circumstances, and in our sole discretion, we may negotiate a lesser
management fee based upon certain criteria (i.e., anticipated future earning capacity, dollar amount of assets to
be managed, related accounts, account composition, pre-existing client relationship, account retention, etc.).
Fees
Our annual portfolio management fee is billed and payable quarterly in advance and is based on the account
balance at the end of the previous quarter.
If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our
fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of
days in the month for which you are a client. Our advisory fee is negotiable, depending on individual client
circumstances.
As a client, you should be aware that the wrap fee charged by our firm may be higher (or lower) than those
charged by others in the industry, and that it may be possible to obtain the same or similar services from other
firms at lower (or higher) rates. A client may be able to obtain some or all of the types of services available
through our firm's wrap fee program on an individual basis through other firms and, depending on the
circumstances, the aggregate of any separately paid fees may be lower or higher than the annual fees shown
above.
We will deduct our fee directly from your account through the qualified custodian holding your funds and
securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the
fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you
at least quarterly. These account statements will show all disbursements from your account. You should review all
statements for accuracy.
Compensation
Summit Wealth is the sponsor and portfolio manager of this Wrap Fee Program. Summit Wealth receives wealth
management fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs
associated with the management of the Client’s account[s].
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Item 5. Account Requirements and Types of Clients
Summit Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations and businesses.
In general, we do not require a minimum dollar amount to open and maintain an advisory account; however, we
have the right to terminate your account if it falls below a minimum size which, in our sole opinion, is too small to
manage effectively. We, at our sole discretion, may establish a minimum portfolio asset value size requirement for
participation in our Wrap Program.
We may also combine account values for you and your minor children, joint accounts with your spouse, and other
types of related accounts to meet the stated minimum.
Item 6. Portfolio Manager Selection and Evaluation
Summit Wealth serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Performance-Based Fees and Side-by-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance- based fees
are fees that are based on a share of capital gains or capital appreciation of a client's account. Side-by-side
management refers to the practice of managing accounts that are charged performance-based fees while at the
same time managing accounts that are not charged performance- based fees. Our fees are calculated as
described above and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the
funds in your advisory account.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee
that our services or methods of analysis can or will predict future results, successfully identify market tops or
bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
When evaluating risk, financial loss may be viewed differently by each client and may depend on many different
risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not
be all-inclusive but should be considered carefully by a prospective client before retaining our services.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or
lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed
income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an
issuer's securities held by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in
inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the
purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher
interest rates which may cause the value of many types of fixed income investments to decline.
Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event,
for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the
long term. If you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of
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outliving your savings. This risk is particularly relevant for people who are retired or are nearing retirement.
We recommend various types of securities and we do not primarily recommend one particular type of security
over another since each client has different needs and different tolerance for risk. Each type of security has its
own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every
type of investment. Even within the same type of investment, risks can vary widely. However, in very general
terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the
investment. A description of the types of securities we may recommend to you and some of their inherent risks
are provided below.
Proxy Voting
The Advisor will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable
securities, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we
were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless
you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic
solicitations to vote proxies.
Item 7. Client Information Provided to Portfolio Managers
In order to provide the Program services, we will share your private information with your account custodian. We
may also provide your private information to mutual fund companies and/or private managers as needed. We will
only share the information necessary in order to carry out our obligations to you in servicing your account. We
share your personal account data in accordance with our privacy policy as described below.
Item 8. Client Contact with Portfolio Managers
Without restriction, you should contact our firm or your advisory representative directly with any questions
regarding your Program account. You should contact your advisory representative with respect to changes in your
investment objectives, risk tolerance, or requested restrictions placed on the management of your Program
assets.
Item 9. Requirements for State-Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this item.
Item 10. Additional Information
Disciplinary Information and Other Financial Industry Activities and Affiliations
We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of
our advisory business or the integrity of our management. We do not have any required disclosures under this
item.
Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics
includes guidelines for professional standards of conduct for persons associated with our firm. Our goal is to
protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good
faith, and fair dealing with you. All persons associated with our firm are expected to adhere strictly to these
guidelines. Persons associated with our firm are also required to report any violations of our Code of Ethics.
Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination
of material, non-public information about you or your account holdings by persons associated with our firm. More
information on the Summit Wealth Code of Ethics can be found under Item 11 in the Disclosure Brochure
(included with this Wrap Fee Program Brochure).
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Review of Accounts
Client accounts are monitored on a regular and continuous basis by Advisory Persons of Summit Wealth under
the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided
in Item 13 of the Form ADV Part 2A – Disclosure Brochure.
Other Compensation
We receive economic benefits from a non-client for providing investment advice or other advisory services to you.
Through our participation in certain programs or use of a custodian we are entitled to receive economic benefits.
As part of our fiduciary duty, we endeavor at all times to put the interests of our clients first. Clients should be
aware, however, that the receipt of economic benefits by our firm from a non-client in and of themselves creates a
potential conflict of interest and may influence our choice in providing services to your account. This arrangement
does not cause our clients to pay any additional transaction fees beyond those that are traditionally charged by
our firm and/or other service providers.
Refer to the Services, Fees, and Compensation section above for disclosures on research and other benefits we
may receive resulting from our relationship with your account custodian.
Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee
Program Brochure) for details on additional compensation that may be received by Summit Wealth or its Advisory
Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure)
provides details on any outside business activities and the associated compensation.
Client Referrals from Solicitors
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Financial Information
Neither Summit Wealth, nor its management, have any adverse financial situations that would reasonably impair
the ability of Summit Wealth to meet all obligations to its Clients. Neither Summit Wealth, nor any of its Advisory
Persons, have been subject to a bankruptcy or financial compromise. Summit Wealth is not required to deliver a
balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more
for services to be performed six months or more in the future.
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Summit Wealth Group, LLC Privacy Notice
Effective Date: July 21, 2025
Our Commitment to You
Summit Wealth Advisors, LLC (“Summit Wealth” or the “Adviser”) is committed to safeguarding the use of
personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment
Adviser, as described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. Summit Wealth (also referred to as
"we", "our" and "us”) protects the security and confidentiality of the personal information we have and
implements controls to ensure that such information is used for proper business purposes in connection with the
management or servicing of our relationship with you.
Summit Wealth does not sell your non-public personal information to anyone. Nor do we provide such
information to others except for reasonable business purposes in connection with the servicing and management
of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Social security or taxpayer identification number Assets and liabilities
Name, address, and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What information do we collect from other sources?
Custody, brokerage, and advisory agreements
Account applications and forms
Other advisory agreements and legal documents
Transactional information with us or others
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural,
and electronic security measures. These include such safeguards as secure passwords, encrypted file storage
and a secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information. We require third parties that assist in providing our services to you to
protect the personal information they receive from us.
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
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Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties as necessary for us to provide agreed upon services to you,
including but not limited to: processing transactions; general account
maintenance; responding to regulators or legal investigations; and credit
reporting.
No
Not Shared
Marketing Purposes
Summit Wealth does not disclose personal information with non-affiliated
third parties to offer you services. Certain laws may give us the right to
share your personal information with financial institutions where you are a
customer and where Summit Wealth or the client has a formal agreement
with the financial institution. We will only share information for the
purpose of servicing your accounts, not for marketing purposes.
Yes
Yes
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
No
Not Shared
Information About Former Clients
Summit Wealth does not disclose non-public personal information to non-
affiliated third parties with respect to persons who are no longer our
Clients.
Changes to our Privacy Policy
We will send you a copy of this Privacy Notice annually for as long as you maintain an ongoing relationship with
us. Periodically we may revise this Notice and will provide you with a revised version if the changes materially
alter the previous Privacy Notice. We will not, however, revise our policies to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (719) 633-4033.
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