Overview
- Headquarters
- Bellevue, WA
- Total Firm Assets
- $5.8 billion
- Average High-Net-Worth Client Portfolio Size
- $5.1 million
Fee Structure
Primary Fee Schedule (THREADLINE WEALTH DISCLOSURE BROCHURE MAY 2026)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.25% |
| $1,000,001 | $2,000,000 | 1.00% |
| $2,000,001 | $5,000,000 | 0.75% |
| $5,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $45,000 | 0.90% |
| $10 million | $70,000 | 0.70% |
| $50 million | $170,000 | 0.34% |
| $100 million | $295,000 | 0.30% |
Clients
- High-Net-Worth Share of Firm Assets
- 89.13%
- Number of High-Net-Worth Clients
- 1,002
- Total Client Accounts
- 4,790
- Discretionary Accounts
- 3,867
- Non-Discretionary Accounts
- 923
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 108917
Additional Brochure: THREADLINE WEALTH DISCLOSURE BROCHURE MAY 2026 (2026-05-28)
View Document Text
Threadline Wealth
Form ADV Part 2A Disclosure Brochure
Privacy Policy
May 2026
Main Office:
Moss Adams Wealth Advisors LLC d/b/a Threadline Wealth
10900 NE 8th Street, Suite 305
Bellevue, WA 98004
425-650-9500
compliance@threadlinewealth.com
This brochure provides information about the qualifications and business practices of Moss Adams Wealth
Advisors LLC d/b/a Threadline Wealth. If you have any questions about the content of this brochure, please
contact us at compliance@threadlinewealth.com or 425-650-9500. 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.
Item 2: Material Changes
This brochure dated May 2026 includes material updates since the firm’s last annual amendment,
including updates associated with the firm’s transition to Threadline Wealth branding and related revisions
to advisory disclosures, services, affiliations, and operational practices. Material updates include, among
other things:
• Updated firm branding and disclosure references to “Moss Adams Wealth Advisors LLC d/b/a
Threadline Wealth”
• Revisions to advisory service descriptions, including expanded disclosure regarding private and
alternative investments, third-party investment managers, tax-aware/direct indexing strategies,
and customized investment strategies
• Updates to investment risk disclosures, including additional discussion regarding interval funds,
private investments, market disruption risks, ESG-related investing considerations, tax-
management strategies, and borrowing/margin risks
• Updates regarding the firm’s ownership structure and affiliated relationships
• Revised disclosure regarding insurance consulting and policy management arrangements
• Updates to brokerage, custody, and operational disclosures, including clarification regarding
standing letters of authorization (“SLOAs”) and custody-related practices
• General updates, clarifications, and modernization of the firm’s advisory, compliance, and
disclosure language
Clients may request a full copy of the latest version of this brochure at any time by contacting their
advisor or Gidget Furness, Chief Compliance Officer, at compliance@threadlinewealth.com.
Additional information about Moss Adams Wealth Advisors LLC d/b/a Threadline Wealth is available on
the SEC’s website at www.adviserinfo.sec.gov. Registration with the SEC does not imply a certain level of
skill or training.
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Item 3: Table of Contents
Item 2: Material Changes .............................................................................................................................. 1
Item 3: Table of Contents .............................................................................................................................. 2
Item 4: Advisory Business ............................................................................................................................. 3
Item 5: Fees and Compensation ................................................................................................................... 7
Item 6: Performance Fees and Side-by-Side Management .......................................................................... 9
Item 7: Types of Clients ................................................................................................................................. 9
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 9
Item 9: Disciplinary Information ................................................................................................................... 13
Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 13
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 ................................................................................................................. 19
Item 18: Financial Information ..................................................................................................................... 20
Privacy Policy .................................................................................................................................... attached
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Item 4: Advisory Business
Introduction
Moss Adams Wealth Advisors LLC, doing business as Threadline Wealth (“Threadline Wealth”), provides
wealth management, investment advisory, financial planning, and consulting services to individuals,
families, business owners, trusts, foundations, and other clients.
Threadline Wealth is headquartered in Bellevue, WA.
The firm provides a variety of advisory services, including:
Investment Advisory Services
•
• Financial Planning
•
Investment Consulting Services
As of December 31, 2025, Threadline Wealth managed a total of $5,773,272,462 in client assets. This
represents $4,414,173,174 in discretionary client assets and $1,359,099,288 in non-discretionary client
assets.
Investment Advisory Services
Threadline Wealth provides comprehensive wealth management and investment advisory services on a
fee basis. Advisory services may include discretionary investment management, financial planning,
investment consulting, and ongoing coordination related to a client’s financial circumstances and
objectives.
Before services are provided, clients enter into a written Investment Advisory Agreement that describes
the scope of services, fee arrangements, termination provisions, and other terms of the advisory
relationship.
As part of the advisory process, Threadline Wealth gathers information regarding a client’s financial
situation, investment objectives, risk tolerance, liquidity needs, time horizon, and other relevant
considerations. Based on this information and ongoing discussions with the client, Threadline Wealth
develops investment recommendations and, where appropriate, an Investment Policy Statement (“IPS”)
or Investment Objectives Statement (“IOS”) to guide portfolio management decisions.
Threadline Wealth generally manages client portfolios on a discretionary basis, which authorizes the firm
to purchase and sell securities and implement investment decisions without obtaining prior client approval
for each transaction, subject to the terms of the applicable advisory agreement and any agreed
investment restrictions.
Depending on client needs and objectives, portfolios may include mutual funds, exchange-traded funds
(“ETFs”), fixed income securities, separately managed accounts (“SMAs”) and third-party investment
managers, cash and cash equivalents, individual equities, and, for eligible clients, private funds and other
alternative investments.
Private and Alternative Investment Funds
For certain eligible clients, Threadline Wealth may recommend private funds and other alternative
investments when the firm believes such investments are appropriate based on the client’s investment
objectives, financial circumstances, risk tolerance, liquidity needs, and overall portfolio strategy.
Threadline Wealth’s services with respect to private and alternative investments include investment due
diligence, manager evaluation, investment selection, ongoing monitoring, and reporting coordination, as
applicable. Clients who elect to invest in private funds or alternative investments enter into separate
subscription agreements and related offering documents directly with the applicable investment sponsor
or fund manager.
Investments in private and alternative investments are limited to clients who satisfy applicable investor
eligibility standards under federal securities laws and the applicable fund offering documents, including
accredited investor, qualified client, or qualified purchaser standards, as applicable.
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Private and alternative investments involve substantial risks, including limited liquidity, long investment
holding periods, limited transparency, higher fees and expenses, valuation uncertainty, manager risk, and
the potential loss of principal. Many private investments also require significant minimum investment
commitments and are therefore appropriate only for clients who can tolerate illiquidity and maintain
appropriate diversification.
Assets invested in private or alternative investments are included in the calculation of Threadline Wealth’s
advisory fees unless otherwise disclosed. Threadline Wealth does not receive commissions or
transaction-based compensation from private fund sponsors or managers in connection with
recommending such investments.
Threadline Wealth does not control or direct the underlying investment decisions made by private fund
managers. Clients should carefully review all offering materials, subscription documents, and related
disclosures before investing.
Additional risks associated with private and alternative investments are discussed in the Investment Risks
section of this Brochure.
Third Party Investment Managers and Separately Managed Accounts
Where appropriate, Threadline Wealth may recommend or utilize third-party investment managers,
including separately managed account (“SMA”) programs, to manage a portion of a client’s portfolio.
When a third-party investment manager is utilized, the manager maintains day-to-day discretionary
authority over the designated assets and is responsible for implementing investment decisions within the
applicable strategy or program.
Threadline Wealth remains responsible for ongoing advisory services to the client, which may include
manager selection, investment due diligence, portfolio construction, asset allocation, performance review,
monitoring of client investment objectives, and periodic review of the appropriateness of the manager or
strategy.
Third-party investment managers charge separate fees in addition to the advisory fees charged by
Threadline Wealth. Clients should carefully review all applicable disclosure documents, agreements, and
program materials for important information regarding services, fees, investment strategies, risks, trading
practices, and other program terms.
Third-party managers retain discretion to determine the securities purchased and sold within the
applicable strategy, subject to the terms of the program and any reasonable client-imposed restrictions
accepted by the manager.
Additional Customized Investment Advisory Services
For certain clients, Threadline Wealth may provide customized investment strategies designed to address
specific portfolio objectives, risk management considerations, income needs, or concentrated stock
positions. These strategies may include covered call writing programs, concentrated position hedging
strategies, collar strategies, or other options-based investment approaches.
These strategies are utilitzed only when appropriate based on the client’s financial circumstances,
investment objectives, risk tolerance, tax considerations, liquidity needs, and existing holdings. Options
and hedging strategies involve unique risks and may limit upside appreciation, reduce liquidity, generate
taxable events, increase transaction costs, or fail to achieve the intended investment objective.
Clients should carefully consider the risks and limitations associated with these strategies before
implementation.
Financial Planning
Threadline Wealth provides financial planning and consulting services to individuals, families, business
owners, trusts, and, in certain cases, businesses and other organizations. Financial planning services are
designed to assist clients in evaluating financial goals, priorities, and decision-making across a variety of
financial matters.
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Depending on client needs and the scope of the engagement, planning services may include:
• Estate and legacy planning considerations
• Review of current financial circumstances, assets, liabilities, and investment holdings
• Cash flow, liquidity, and retirement planning
•
Insurance and risk management analysis
•
Investment allocation and portfolio strategy considerations
• Education planning, charitable planning, business planning, and other financial-related matters
Clients may engage Threadline Wealth for standalone financial planning services on either a one-time or
ongoing basis. Financial planning engagements are governed by a written agreement that outlines the
scope of services, fees, and other terms of the engagement.
Financial planning recommendations and projections are based on information provided by the client,
assumptions regarding future events, and current economic, tax, and market conditions. Actual results
may differ materially from projections or assumptions used in the planning process due to changes in
circumstances, market conditions, tax laws, investment performance, or other factors.
Financial plans and related analyses are provided for planning and informational purposes only and
should not be construed as guarantees regarding future outcomes, investment performance, or the
success of any particular strategy or recommendation.
Clients are under no obligation to implement any recommendation made by Threadline Wealth or to
engage Threadline Wealth or any other professional to implement planning recommendations.
Threadline Wealth does not provide legal services, accounting services, or insurance brokerage services,
and clients are encouraged to consult with qualified legal, tax, insurance, or other professionals, as
appropriate.
Investment Consulting Services
Threadline Wealth may provide investment consulting services to individuals, families, businesses,
retirement plans, foundations, endowments, and other organizations. In an investment consulting
engagement, Threadline Wealth acts as an adviser and facilitator to support the client’s investment
management process rather than directly manage investment assets on a discretionary basis.
The scope of consulting services is determined by the terms of the applicable written agreement and may
include:
• Review of investment objectives, financial circumstances, risk tolerance, liquidity needs, and
overall investment strategy
• Development and review of investment objectives, governance guidelines, Investment Policy
•
Statements (“IPS”), Investment Objectives Statements (“IOS”), asset allocation strategies, and
portfolio structure
Investment manager due diligence, selection, monitoring, replacement recommendations, and
performance evaluation
• Review of custodial platforms, investment expenses, concentrated positions, restricted assets,
and related portfolio considerations
• Consolidated reporting, portfolio analysis, and fiduciary or investment governance consulting for
institutional clients, including foundations, endowments, and retirement plans
Investment consulting recommendations are based on information provided by the client and
assumptions regarding future events, market conditions, and other factors. Actual results may differ
materially from projections, assumptions, or recommendations discussed during the consulting process.
Unless otherwise specifically agreed in writing, Threadline Wealth does not provide ongoing discretionary
management, continuous portfolio monitoring, implementation services, or trading authority under
standalone consulting engagements. Clients and their selected advisers, trustees, committees, or other
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representatives remain responsible for all investment implementation decisions and ongoing
management of assets.
Threadline Wealth’s consulting services are advisory in nature and are not intended to serve as legal,
accounting, tax preparation, insurance brokerage, or trustee services. Clients are encouraged to consult
with qualified professionals regarding legal, tax, accounting, insurance, or other specialized matters, as
appropriate.
Clients are under no obligation to implement any recommendation or engage any professional
recommended by Threadline Wealth.
Rollovers from Retirement Plans; Fiduciary Status for Retirement Investors
A client or prospective client leaving an employer generally has several options regarding assets held in
an employer-sponsored retirement plan, including:
1. Leaving assets in the former employer’s plan, if permitted;
2. Rolling assets into a new employer’s retirement plan, if available and permitted;
3. Rolling assets into an Individual Retirement Account (“IRA”); or
4. Taking a distribution from the account, which may result in taxes and penalties.
When recommending that a client roll over or transfer retirement assets to an account managed by
Threadline Wealth, the firm has a conflict of interest because Threadline Wealth generally receives
additional compensation when assets are transferred into accounts managed by the firm.
Threadline Wealth addresses this conflict by recommending rollovers or transfers only when the firm
reasonably believes the recommendation is in the client’s best interest based on the client’s financial
circumstances and investment needs. In evaluating rollover recommendations, Threadline Wealth may
consider factors including investment options, fees and expenses, services available under the existing
plan and the proposed arrangement, distribution options, creditor protections, required minimum
distribution considerations, and other relevant factors. Threadline Wealth maintains policies and
procedures designed to document and review rollover recommendations for consistency with applicable
fiduciary obligations.
To the extent required under applicable law, Threadline Wealth acts as a fiduciary within the meaning of
ERISA and/or Section 4975 of the Internal Revenue Code with respect to investment advice provided to
retirement investors.
Additional information regarding conflicts associated with rollover recommendations is described
elsewhere in this Brochure.
Health Savings Accounts (HSAs)
For certain clients, Threadline Wealth may provide investment advisory services with respect to Health
Savings Accounts (“HSAs”), including standalone HSA custodial accounts and brokerage-based HSA
investment accounts made available through third-party custodians or platform providers.
HSA investment options, contribution eligibility, tax treatment, withdrawal rules, and available account
features are determined by applicable law and the policies of the HSA custodian or provider. Clients
remain responsible for determining their eligibility to contribute to an HSA, monitoring annual contribution
limits, maintaining required records, and complying with applicable tax rules and distribution
requirements. Threadline Wealth does not provide tax or legal advice, and clients are encouraged to
consult with their tax advisor regarding the use and tax treatment of HSAs.
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Item 5: Fees and Compensation
Fees for Investment Advisory Services – Private Client
Threadline Wealth provides investment advisory and portfolio management services to individual and
private clients on a customized basis. Portfolios are managed in accordance with the client’s investment
objectives, financial circumstances, risk tolerance, and liquidity needs.
Investment advisory fees are calculated as a percentage of assets under management according to the
following annual fee schedule:
ASSETS UNDER MANAGEMENT
$1,000,000 and under
1.25%
$1,000,001 to $2,000,000
1.00%
$2,000,001 to $5,000,000
0.75%
$5,000,001 to $10,000,000
0.50%
$10,000,001 and above
0.25%
Fees are calculated on a graduated basis. For example, an account with assets of $2,000,000 would pay
1.25% on the first $1,000,000 and 1.00% on the next $1,000,000.
For fee calculation purposes, Threadline Wealth may aggregate accounts for related clients, including
certain family members, household relationships, trusts, or related entities, where appropriate and at the
firm’s discretion.
Threadline Wealth reserves the right to negotiate fees based on factors including account size,
complexity, anticipated future assets, scope of services, related accounts, and other relevant
considerations.
Fees for Investment Advisory Services – Institutional
Threadline Wealth provides investment advisory and consulting services to institutional clients, including
charitable organizations, foundations, endowments, retirement plans, corporations, business entities,
tribal governments, and other organizations.
Institutional advisory fees are calculated as a percentage of assets under management according to the
following annual fee schedule:
ASSETS UNDER MANAGEMENT
$10,000,000 and under
0.50%
Over $10 million
0.25%
Fees are calculated on a graduated basis unless otherwise agreed in writing.
Threadline Wealth reserves the right to negotiate fees based on factors including account size,
complexity, scope of services, anticipated future assets, reporting requirements, fiduciary consulting
needs, and other relevant considerations.
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More Information on Investment Advisory Services Fees
Advisory fees are billed quarterly in arrears based on the market value of assets under management as of
the last trading day of the applicable calendar quarter, unless otherwise agreed in writing. Fees for partial
billing periods are prorated based on the number of days assets were managed during the period.
Clients typically authorize Threadline Wealth to deduct advisory fees directly from designated custodial
accounts. Fee deductions are reflected on custodial account statements provided directly by the
custodian. In limited circumstances, clients may be invoiced directly pursuant to separate written
arrangements.
Assets invested in private funds or alternative investments are included in the calculation of advisory fees
unless otherwise disclosed. Valuations for private or alternative investments are based on values
provided by custodians, fund sponsors, administrators, or other third parties. Due to the illiquid nature of
such investments, valuation updates may occur after quarter-end reporting periods.
Cash and cash equivalents are generally included in assets under management for fee calculation
purposes unless otherwise agreed in writing. Threadline Wealth may maintain cash positions for liquidity,
defensive positioning, portfolio management, or other client-specific reasons. Clients should understand
that advisory fees charged on cash positions may exceed the yield earned on such assets during certain
market environments.
Client accounts may utilize margin borrowing where appropriate. Margin involves additional risks,
including the potential for amplified losses and increased interest expense. Because advisory fees are
calculated based on total assets under management, including margined assets, the use of margin
creates a conflict of interest because it increases the advisory fees paid to Threadline Wealth. The firm
seeks to address this conflict through its fiduciary obligations and internal policies and procedures.
Threadline Wealth may negotiate advisory fees or utilize alternative fee arrangements based on factors
including account size, anticipated future assets, scope and complexity of services, related accounts,
legacy fee arrangements, employee and family relationships, and other relevant considerations. As a
result, similarly situated clients may pay different fees for similar services.
Clients will incur additional fees and expenses separate from Threadline Wealth’s advisory fees, including
brokerage commissions, transaction charges, custody fees, mutual fund and ETF expenses, private fund
fees and expenses, third-party manager fees, margin interest, and other investment-related costs. These
fees and expenses are described in the applicable custodial agreements, offering documents, fund
prospectuses, and program disclosures.
Investments in mutual funds, ETFs, private funds, and other pooled investment vehicles are subject to
internal management fees and expenses charged by the investment sponsor or manager in addition to
the advisory fees charged by Threadline Wealth.
Either the client or Threadline Wealth may terminate the advisory relationship at any time by written notice
in accordance with the terms of the applicable advisory agreement. Advisory fees are prorated through
the effective date of termination.
Fees for Financial Planning
Fees for financial planning services are based on the scope, complexity, and nature of the services to be
provided and are set forth in a separate written financial planning or consulting agreement.
Financial planning fees generally range from approximately $3,500 to $30,000 or more depending on the
complexity of the engagement, the level of ongoing services requested, and the client’s financial
circumstances.
Financial planning fees are structured as fixed fees and billed in arrears pursuant to the terms of the
applicable agreement. Certain ongoing planning engagements may be billed quarterly or pursuant to
another agreed fee schedule.
The applicable agreement will describe the services to be provided, billing arrangements, and other terms
of the engagement.
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Either party may terminate the planning engagement in accordance with the terms of the applicable
agreement. Upon termination, clients are responsible for any earned but unpaid fees through the effective
date of termination.
Fees for Investment Consulting Services
Investment consulting fees are generally structured as fixed fees based on the scope, complexity, and
nature of the services to be provided. The specific services, fee arrangements, and other terms of the
engagement will be set forth in a separate written consulting agreement.
Depending on the nature of the engagement, consulting fees may be billed upon completion of specified
milestones, quarterly, or pursuant to another agreed fee schedule.
Either party may terminate the consulting engagement in accordance with the terms of the applicable
agreement. Upon termination, clients are responsible for payment of fees associated with services
performed and work completed through the effective date of termination, whether or not the engagement
has been fully completed or final deliverables have been provided.
Item 6: Performance Fees and Side-by-Side Management
Threadline Wealth does not charge performance-based fees (fees based on a share of capital gains or
capital appreciation of client assets).
Threadline Wealth does not engage in side-by-side management arrangements involving accounts
charged performance-based fees alongside accounts charged asset-based fees.
Item 7: Types of Clients
Threadline Wealth provides investment advisory and consulting services to individuals, families, trusts,
estates, charitable organizations, foundations, endowments, retirement plans, corporations, business
entities, tribal government enterprises, and other institutional clients.
Certain services or investment opportunities, including private and alternative investments, may be
available only to clients who satisfy applicable eligibility, sophistication, or minimum asset requirements.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Threadline Wealth develops portfolio allocation strategies based on each client’s financial circumstances,
investment objectives, risk tolerance, liquidity needs, tax considerations, time horizon, and other relevant
factors. Portfolios may be adjusted periodically in response to changes in client circumstances, market
conditions, economic environments, or investment opportunities.
In evaluating investments and investment managers, Threadline Wealth utilizes a combination of
quantitative and qualitative analysis. Quantitative analysis may include review of factors such as historical
performance, volatility, expenses, manager tenure, portfolio characteristics, credit quality, peer
comparisons, style consistency, and risk-adjusted return metrics.
Qualitative analysis may include evaluation of investment philosophy, portfolio management processes,
risk management practices, organizational stability, personnel changes, trading disciplines, operational
infrastructure, and other relevant factors. Threadline Wealth may also review prospectuses, offering
documents, shareholder reports, manager commentary, third-party research, and other publicly available
information as part of its due diligence process.
Threadline Wealth generally constructs portfolios using diversified strategic asset allocation approaches
intended for long-term investing. Depending on client circumstances and objectives, portfolios may
include mutual funds, ETFs, fixed income securities, third-party managers, private investments, cash and
cash equivalents, options strategies, and margin utilization, where appropriate.
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Investment Strategies
Threadline Wealth utilizes diversified asset allocation strategies designed to align with each client’s
investment objectives, risk tolerance, liquidity needs, tax considerations, and time horizon. Portfolio
construction seeks to balance long-term return objectives with appropriate levels of portfolio risk and
diversification.
Portfolios are constructed using a combination of asset classes, investment styles, and risk exposures
intended to reduce concentration risk and improve long-term portfolio outcomes across varying market
environments.
Within growth-oriented allocations, Threadline Wealth may utilize a “core and satellite” investment
approach. Core investments are generally intended to provide broad market exposure, diversification, tax
efficiency, and lower-cost access to major market segments. Satellite investments are typically more
specialized strategies intended to enhance diversification, provide targeted market exposure, address
specific portfolio objectives, or seek additional return opportunities.
Satellite investments may involve greater complexity, volatility, liquidity constraints, or higher costs than
core investments and therefore may not be appropriate for all clients.
For certain clients, portfolios may also include alternative investments or real assets, such as private
investments, real estate-related strategies, commodities-related investments, or other non-traditional
asset classes. Alternative investments are generally intended to provide additional diversification and
differentiated sources of return, although such investments involve unique risks, including illiquidity,
valuation uncertainty, higher fees and expenses, and potentially greater volatility.
Tax-Aware / Direct Indexing Strategies
For certain clients, Threadline Wealth may utilize tax-aware or direct indexing strategies through third-
party investment managers or separately managed account programs. These strategies generally seek to
provide exposure similar to a designated benchmark while incorporating tax-management techniques,
customization features, or client-specific restrictions.
Such strategies may utilize representative sampling, optimization techniques, tax-loss harvesting, or other
portfolio management approaches that may cause performance to differ from the selected benchmark or
from comparable passive index strategies.
Efforts to manage tax consequences may limit investment flexibility, increase portfolio turnover, defer
gains, or otherwise affect portfolio performance. There can be no guarantee that tax-management
strategies will be successful or that any particular tax result will be achieved.
Risk of Loss
All investments involve varying degrees of risk, including the potential loss of principal. Clients should not
assume that any investment or investment strategy recommended by Threadline Wealth will be profitable
or achieve any particular performance result. Past performance is not indicative of future results.
Investment recommendations and portfolio strategies are based on a client’s financial circumstances,
investment objectives, risk tolerance, liquidity needs, and other factors; however, there can be no
guarantee that investment objectives will be achieved.
Clients should carefully review all prospectuses, offering documents, subscription materials, and other
investment-related disclosures for a more complete discussion of the risks associated with a particular
investment or strategy.
Fixed Income Risks
Fixed income investments are subject to various risks, including credit risk, interest rate risk, market risk,
and liquidity risk. Credit risk is the risk that an issuer may fail to make timely payments of principal or
interest. Interest rate risk is the risk that the value of fixed income securities will fluctuate due to changes
in market interest rates. Generally, when interest rates rise, bond prices decline, and vice versa.
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Certain fixed income securities may be difficult to sell at a favorable price or within the desired timeframe,
particularly during periods of market stress or reduced market liquidity.
Municipal securities are also subject to risks specific to governmental issuers, including changes in tax
laws, legislative or regulatory developments, economic conditions affecting governmental entities, and
varying levels of market liquidity.
Liquidity Risk
Liquidity risk is the risk that an investment cannot be sold at a favorable price or within the desired
timeframe without negatively affecting its value. Certain investments, including private and alternative
investments, interval funds, thinly traded securities, and certain fixed income investments, may involve
significant liquidity constraints.
Periods of market volatility or disruption may further impair liquidity and increase the difficulty of selling
investments at desired prices or times.
Inflation Risk
Inflation risk is the risk that the purchasing power of assets or investment returns will be reduced over
time due to rising prices for goods and services. Inflation may negatively affect the real value of
investment returns and may reduce the future purchasing power of portfolio assets and income streams.
Interval Funds / Risks and Limitations
Investments in interval funds involve additional risks and limitations, including limited liquidity and
restrictions on withdrawals or redemptions. Interval funds are generally not listed on securities exchanges
and are not publicly traded. As a result, there is typically no secondary market for an investor’s shares.
Unlike traditional mutual funds, interval funds only periodically offer to repurchase a limited portion of
outstanding shares pursuant to the terms of the fund’s repurchase program. There can be no assurance
that an investor will be able to redeem shares when desired or in the amount requested. During periods
outside the repurchase window, investors may not redeem or sell shares.
In addition, interval funds may limit or prorate repurchase requests during periods of high redemption
demand, and the value received upon redemption may be less than the value originally invested or the
value at the time a redemption request is submitted.
Interval funds may also involve additional risks associated with the underlying investments held by the
fund, including private credit, real estate, structured products, or other less liquid or alternative
investments.
Because interval funds involve significant liquidity constraints and additional risks, they are generally
appropriate only for investors with a long-term investment horizon, the ability to tolerate illiquidity, and the
financial ability to withstand potential loss of principal.
ESG / Values-Based Investing Risks and Limitations
Threadline Wealth may incorporate environmental, social, governance (“ESG”), sustainability, or other
values-based considerations into certain investment strategies or client-directed investment restrictions.
The use of ESG or other values-based criteria may limit the investments and investment strategies
available within a portfolio and may result in performance that differs from or underperforms broader
market indices or investment strategies that do not apply such criteria.
In addition, ESG-related investment data, scoring methodologies, and evaluation frameworks may vary
among investment managers, issuers, and third-party data providers. As a result, there may be
inconsistencies in how ESG characteristics are assessed or applied across investments and strategies.
There can be no guarantee that ESG-focused or values-based investment strategies will be successful or
achieve their intended investment objectives.
Equity and Issuer Risk
Equity securities and other investments are subject to the risk that issuers may experience adverse
financial, operational, regulatory, or economic developments that negatively affect the value of the
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investment. Factors such as declining revenues, increased borrowing costs, operational failures,
management changes, competitive pressures, litigation, economic downturns, or excessive leverage may
impair an issuer’s financial condition and result in declines in market value or potential loss of principal.
Certain investments may also experience increased volatility during periods of market stress, economic
uncertainty, or changing interest rate environments.
Borrowing / Margin Risk
Clients may choose to utilize securities-based lending, margin, or other borrowing arrangements
collateralized by investment assets. These strategies involve additional risks, including amplified losses,
margin calls, forced liquidation of securities, increased interest expense, and the potential loss of pledged
assets.
Declines in account value may require clients to deposit additional assets or repay outstanding
borrowings on short notice. In certain circumstances, custodians or lenders may liquidate securities
without prior client consent in order to satisfy collateral or margin requirements.
Custodians and lenders maintain discretion regarding lending terms, collateral requirements, interest
rates, and liquidation decisions. Clients should carefully review all applicable lending and margin
disclosures before utilizing these strategies.
Tax Management and Direct Indexing Risk
Tax-aware investment strategies and direct indexing approaches involve additional risks and limitations.
Strategies designed to minimize taxes or harvest losses may underperform comparable strategies that do
not incorporate tax-management considerations.
In addition, differences in portfolio construction methodologies, customization constraints, sampling
techniques, trading activity, cash flows, account transitions, and tax-management decisions may cause
portfolio performance to deviate from the selected benchmark or index.
Tax laws and regulations are subject to change, and there can be no guarantee that any tax strategy will
achieve the intended result or provide a particular tax benefit.
Risks of Private and Alternative Investments
From time to time, Threadline Wealth may recommend that eligible clients invest a portion of their assets
in private funds, private fund-of-funds, and other illiquid or alternative investments (collectively,
“alternative investments”). Alternative investments are not suitable for all clients and are recommended
only when Threadline Wealth believes such investments are consistent with a client’s overall investment
objectives, financial circumstances, risk tolerance, liquidity needs, and investment sophistication.
Alternative investments are typically offered only to investors who meet applicable eligibility standards,
such as “accredited investor,” “qualified client,” or “qualified purchaser” definitions under applicable
federal securities laws.
Alternative investments involve substantial risks and should be considered speculative. These
investments are subject to limited liquidity, limited transparency, higher fees and expenses, complex tax
reporting, limited operating history, subjective valuation methodologies, reliance on underlying managers,
the potential use of leverage, and a heightened risk of loss, including the possible loss of principal. In
many cases, Alternative investments are not registered under federal securities laws and are subject to
reduced regulatory oversight compared to publicly traded investments.
Threadline Wealth relies on information provided by fund sponsors, managers, administrators,
custodians, and other third parties and does not independently audit or verify all such information.
A more complete description of the risks, investment terms, fees, expenses, withdrawal limitations, and
other important considerations associated with a particular Alternative Investment is contained in the
applicable offering documents, subscription materials, and related disclosures. Clients should carefully
review these materials and consult with their legal, tax, and other professional advisers before investing.
12
Health Savings Account (HSA) Considerations
Investments held within Health Savings Accounts (“HSAs”) are subject to the same market and
investment risks associated with other investment accounts. In addition, HSAs are subject to specific tax
rules, contribution limits, eligibility requirements, and withdrawal restrictions established by law. Improper
contributions or distributions may result in taxes, penalties, or other adverse consequences.
Certain HSA providers may also limit available investment options, transfer capabilities, trading features,
or account functionality
Market Disruption Risks
Investment markets and securities may be adversely affected by domestic and international political
developments, war, terrorism, civil unrest, trade disputes, sanctions, natural disasters, public health
events, supply chain disruptions, cyber incidents, changes in government policy, and other geopolitical or
economic events. These events may cause significant market volatility, reduced liquidity, inflationary
pressures, interest rate fluctuations, credit deterioration, operational disruptions, and broader economic
uncertainty.
The occurrence of such events may negatively affect the value and liquidity of client investments and may
increase the risks associated with other investment strategies and asset classes discussed in this
Brochure. The timing, duration, and overall impact of these events can be difficult or impossible to predict.
Types of Investments
Threadline Wealth provides investment advice across a broad range of asset classes and investment
strategies, including cash and cash equivalents, money market instruments, corporate, municipal, and
U.S. government fixed income securities, domestic and foreign equities, exchange-traded funds (“ETFs”),
mutual funds, and other publicly traded securities.
Where appropriate based on a client’s objectives and circumstances, Threadline Wealth may recommend
third-party investment managers, including separately managed account (“SMA”) programs and model
portfolio strategies.
For certain clients, Threadline Wealth may incorporate environmental, social, governance (“ESG”),
sustainability-related, or other client-directed investment preferences into portfolio construction or
manager selection. ESG and sustainability considerations are one of many factors evaluated and may not
be determinative in the investment decision-making process.
For eligible and qualified clients, Threadline Wealth may also recommend private funds and other illiquid
alternative investments.
Threadline Wealth may also provide advice regarding assets held prior to the commencement of the
advisory relationship, including assets that are not directly managed by the firm.
Item 9: Disciplinary Information
Threadline Wealth is required to disclose any legal or disciplinary events that are material to a client’s or
prospective client’s evaluation of the firm or the integrity of its management personnel. The Firm has no
legal or disciplinary events required to be disclosed under this Item.
Item 10: Other Financial Industry Activities and Affiliations
Threadline Wealth is an SEC-registered investment adviser. Threadline Wealth is a wholly owned
subsidiary of Threadline Holdings, LLC. Threadline Holdings, LLC is governed by a board of managers
that includes representatives of certain ownership stakeholders. Threadline Wealth’s management and
advisory operations are conducted by the firm’s executive leadership and advisory personnel.
Certain employees of Threadline Wealth may hold professional designations or licenses, including
certified public accountant (“CPA”) licenses. However, such individuals devote their professional time to
Threadline Wealth and do not provide public accounting services, tax return preparation services, or other
separate professional services through the firm unless otherwise specifically disclosed.
13
Threadline Wealth may maintain relationships with unaffiliated service providers, including investment
managers, insurance professionals, accountants, attorneys, custodians, and other financial professionals
in connection with serving clients. These relationships may present a conflict of interest to the extent the
firm has an incentive to recommend or coordinate with certain providers. Clients are not required to
engage any recommended provider and may select any professional service provider of their choosing.
Threadline Wealth does not receive compensation from private fund sponsors, investment managers, or
other third parties in connection with client investments unless otherwise specifically disclosed.
Certain entities under common ownership or control with Threadline Wealth may provide investment
advisory or other financial-related services. Although these entities operate independently of Threadline
Wealth, such relationships may present potential conflicts of interest from time to time. Threadline Wealth
maintains policies and procedures reasonably designed to identify and address material conflicts of
interest in the best interests of clients.
From time to time, Threadline Wealth personnel may attend educational conferences, seminars, due
diligence meetings, or other industry events sponsored or hosted by investment managers, custodians, or
other financial services firms. In certain circumstances, the sponsoring firm may pay for or subsidize
travel, lodging, meals, registration fees, or related expenses associated with attendance at such events.
These events are generally educational or business-related in nature; however, the receipt of such
benefits presents a conflict of interest because it may create an incentive to favor or recommend certain
firms or products. Threadline Wealth maintains policies and procedures designed to identify and manage
such conflicts in the best interests of clients.
Insurance Consulting and Policy Management Arrangements
Threadline Wealth has an arrangement with Long Road Risk Management Services, LLC (“LRRM”) to
facilitate access to certain insurance related solutions, including life insurance, disability insurance, and
long-term care insurance. Clients who elect to implement insurance products through LRRM or its
affiliates enter into separate agreements directly with those entities.
For certain insurance policies implemented through this arrangement, Threadline Wealth receives an
ongoing fee from ValMark Policy Management Company, LLC (“VPMC”) in connection with providing
investment advisory and policy management-related services, including periodic policy review and
reporting services for clients who own such policies.
This compensation creates a conflict of interest because Threadline Wealth has a financial incentive to
recommend or maintain insurance products associated with this arrangement. Clients are under no
obligation to utilize LRRM, VPMC, or any insurance-related recommendation made by Threadline Wealth
and are free to obtain insurance products or services through other providers.
Neither LRRM nor VPMC is affiliated with Threadline Wealth. No investment adviser representative of
Threadline Wealth is licensed to sell insurance products or receives insurance sales commissions in
connection with these arrangements.
Non-Investment Consulting and Implementation Services
As part of its advisory services, Threadline Wealth may provide planning and consulting guidance on non-
investment matters, including estate planning, tax planning, insurance planning, charitable giving,
business planning, and other financial-related matters. Such services are provided for informational and
planning purposes only.
Threadline Wealth does not provide legal services, accounting services, or tax return preparation
services, and clients are encouraged to consult with their own attorneys, accountants, tax professionals,
insurance professionals, or other specialists, as appropriate.
At a client’s request, Threadline Wealth may recommend or coordinate with third-party professionals in
connection with the implementation of planning strategies. Clients are under no obligation to engage any
recommended professional and retain full discretion over whether to implement any recommendation or
engage any service provider.
14
Clients remain responsible for informing Threadline Wealth of any material changes to their financial
circumstances, investment objectives, or other relevant information so that the firm may evaluate whether
prior recommendations remain appropriate.
Additional Reporting and Data Aggregation Services
Threadline Wealth may utilize third-party financial data aggregation and reporting providers to assist in
delivering consolidated financial reporting, account analysis, performance reporting, or other planning-
related services for clients. These services may aggregate information from client accounts held at
various financial institutions and other third-party sources.
Clients who elect to utilize such services may be required to enter into separate agreements or provide
separate consent directly to the applicable third-party provider. Threadline Wealth is not responsible for
the systems, operations, security protocols, or data accuracy of third-party aggregation providers.
In certain circumstances, client reports may include assets that are not managed by Threadline Wealth
(“Unmanaged Assets”). Unless otherwise agreed in writing, Threadline Wealth does not provide
discretionary management, trading authority, continuous monitoring, or implementation services with
respect to Unmanaged Assets. The client and/or other advisers responsible for such assets remain solely
responsible for investment decisions, management, and performance related to those assets.
The inclusion of Unmanaged Assets in consolidated reports is provided for informational and planning
purposes only and should not be interpreted as an indication that Threadline Wealth is actively managing
or supervising those assets.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Summary
Threadline Wealth has adopted a Code of Ethics (the “Code”) designed to ensure that the firm and its
personnel meet their fiduciary obligations and conduct business in the best interests of clients. The Code
establishes standards of conduct and addresses, among other things, personal securities transactions,
conflicts of interest, confidentiality, insider trading, and compliance with applicable federal securities laws.
The Code is intended to prevent employees from:
• Placing personal interests ahead of client interests;
• Taking inappropriate advantage of their position with the firm;
• Misusing confidential information; or
• Engaging in conduct that creates actual or potential conflicts of interest.
As a fiduciary, Threadline Wealth and its personnel are required to act with honesty, integrity, and in the
best interests of clients at all times. All employees are required to acknowledge and comply with the
Code.
Clients and prospective clients may obtain a copy of the firm’s Code of Ethics by contacting Threadline
Wealth.
Participation or Interest in Client Transactions
Threadline Wealth may receive client referrals from, or provide referrals to, Baker Tilly and other
professional service providers from time to time. These referrals are intended to support client service and
coordination efforts. Threadline Wealth does not compensate Baker Tilly for such referrals, nor does the
firm receive compensation from Baker Tilly in connection with client referrals.
Although no direct compensation is paid for referrals, these relationships may create a conflict of interest
because the parties may have an incentive to recommend one another’s services. Clients are under no
obligation to engage Threadline Wealth, Baker Tilly, or any other recommended professional or service
provider.
15
Threadline Wealth does not engage in principal transactions, agency cross transactions, or cross trades
between client accounts.
A principal transaction involves an investment adviser, acting for its own account or an affiliated account,
buying securities from or selling securities to a client account. An agency cross transaction involves an
investment adviser or affiliated party acting as broker for both the client and another party in the same
transaction.
Personal Trading
Employees and related persons of Threadline Wealth may buy or sell securities for their personal
accounts that are also recommended to or purchased for client accounts. As a result, employees may
have an interest in securities that are also held by clients.
In certain circumstances, employee trades may be aggregated with client transactions. When aggregated,
participating accounts generally receive an average transaction price and share transaction costs on a
pro rata basis, consistent with the firm’s trade allocation policies.
Personal trading by employees presents potential conflicts of interest because employees could benefit
from trading activity in securities also purchased or sold for clients. Threadline Wealth maintains policies
and procedures reasonably designed to detect and prevent conflicts of interest and to ensure that client
transactions are effected in a manner consistent with the firm’s fiduciary duty and Code of Ethics.
Item 12: Brokerage Practices
General
Threadline Wealth seeks to place client transactions with broker-dealers and custodians that the firm
believes are capable of providing best execution under the circumstances. In evaluating broker-dealers
and custodians, Threadline Wealth considers a variety of factors, including execution capability,
transaction costs, responsiveness, financial stability, quality of service, available investment products,
reporting capabilities, technology, and operational support.
Threadline Wealth does not maintain traditional soft dollar arrangements under which the firm receives
research products or services from broker-dealers in exchange for client brokerage transactions.
However, as described below, custodians and broker-dealers may provide the firm with certain research,
technology, administrative, and practice management support in connection with the firm’s custodial
relationships.
Custodial Brokerage
Threadline Wealth recommends that clients establish brokerage accounts with Charles Schwab & Co.,
Inc. (“Schwab”), Fidelity Investments (“Fidelity”) to maintain custody of client assets and execute
securities transactions. Schwab and Fidelity are registered broker-dealers and members of SIPC.
Threadline Wealth is independently owned and operated and is not affiliated with Schwab or Fidelity.
Client accounts are established directly with the custodian, and the custodian maintains possession of
client assets, executes transactions, and provides account statements and trade confirmations directly to
clients.
In recommending custodians, Threadline Wealth considers a variety of factors, including:
• Execution capability and trading quality
• Custody and settlement services
• Breadth of available investment products
• Technology, reporting, and operational support
• Financial strength and stability
• Responsiveness and service quality
• Overall cost structure and pricing
• Ability to support the firm’s investment and service model
16
Schwab and Fidelity as custodians may provide Threadline Wealth with products and services that assist
the firm in managing and administering client accounts. These services may include trading and portfolio
management software, account reporting systems, access to market data and research, pricing services,
compliance and operational tools, educational resources, and practice management support.
Certain of these products and services benefit Threadline Wealth and may not directly benefit client
accounts. The availability of these services creates a conflict of interest because the firm may have an
incentive to recommend custodians that provide such benefits. Threadline Wealth nevertheless seeks to
recommend custodians and brokerage arrangements that it believes are in the best interests of clients.
Custodians may also make available institutional trading, custody, and investment services that are not
available to retail investors. Some services may be offered without direct cost to Threadline Wealth based
on the level of client assets maintained with the custodian.
Clients should understand that brokerage and transaction costs charged by recommended custodians
may be higher or lower than those available through other broker-dealers or custodians.
Threadline Wealth recommends custodians that are compatible with the firm’s operational, trading, and
reporting systems. Clients should evaluate the overall services, costs, and features of any recommended
custodian to determine whether the arrangement is appropriate for their needs.
Best Execution
As a fiduciary, Threadline Wealth seeks to obtain best execution for client transactions under the
circumstances of each transaction. In seeking best execution, the firm considers a variety of factors,
including execution capability, commission and transaction costs, financial responsibility, responsiveness,
research and support services, and the overall value of services provided by the broker-dealer or
custodian.
Accordingly, Threadline Wealth does not necessarily seek the lowest possible transaction cost for every
trade if the firm believes that a higher-cost broker-dealer or custodian may provide greater overall value
or execution quality under the circumstances.
Transaction fees, commission rates, and other costs may vary among clients based on account type,
custodial platform, transaction size, security type, or other relevant factors.
Trading Practices
Threadline Wealth maintains trading and allocation policies and procedures designed to ensure that client
transactions are handled fairly and consistent with the firm’s fiduciary obligations.
The firm may aggregate transactions for multiple client accounts when it believes aggregation is
consistent with seeking best execution and is advantageous to participating accounts. When transactions
are aggregated, participating accounts receive an average transaction price, and transaction costs are
allocated in a manner the firm believes is fair and equitable over time.
Threadline Wealth is not obligated to aggregate trades. The firm may determine that aggregation is not
appropriate under certain circumstances based on client objectives, investment restrictions, account size,
available cash, tax considerations, timing differences, or other factors.
Trade allocations are made using the firm’s business judgment and in accordance with applicable legal
and regulatory requirements. Although Threadline Wealth seeks to allocate investment opportunities fairly
over time, there can be no assurance that each client will participate in every investment opportunity or
receive identical allocations.
Directed Brokerage
Threadline Wealth does not accept client-directed brokerage arrangements. Client-directed brokerage
may limit the firm’s ability to seek best execution, aggregate transactions, negotiate favorable trading
terms, or efficiently manage client accounts.
17
Accordingly, clients grant Threadline Wealth discretion to select broker-dealers and custodians for the
execution of transactions and custody of assets, subject to the terms of the applicable advisory
agreement.
Item 13: Review of Accounts
Threadline Wealth monitors client portfolios on an ongoing basis as part of its investment advisory
services and in accordance with the client’s investment objectives, risk tolerance, liquidity needs, and
other guidelines established with the client, including any applicable Investment Policy Statement (“IPS”)
or Investment Objectives Statement (“IOS”).
Portfolio reviews are conducted by the client’s wealth advisor and may include consideration of factors
such as investment performance, asset allocation, market conditions, cash flows, changes in client
circumstances, manager or strategy changes, and other relevant considerations. Threadline Wealth may
periodically rebalance portfolios to maintain alignment with a client’s investment objectives and target
allocations.
Clients are encouraged to meet with their advisor periodically to review financial circumstances,
investment goals, risk tolerance, and other relevant information. The frequency of reviews and client
meetings may vary depending on client needs, account complexity, services provided, and other relevant
factors.
For clients receiving financial planning or consulting services, reviews are generally conducted on an as
needed basis or as otherwise agreed with the client.
Clients receive trade confirmations and account statements directly from their custodian or broker-dealer.
In addition, clients receiving investment advisory services typically receive periodic performance reports
and other account-related information from Threadline Wealth. Reports are provided electronically unless
otherwise requested by the client.
Threadline Wealth may also provide consolidated or aggregated reporting services that include assets not
directly managed by the firm (“Unmanaged Assets”). Such reporting is provided for informational and
planning purposes only. Unless otherwise agreed in writing, Threadline Wealth does not exercise trading
authority, discretionary management, or ongoing supervision over Unmanaged Assets, and the client
and/or other advisors responsible for those assets remain solely responsible for investment decisions and
performance associated with such assets.
Clients remain responsible for notifying Threadline Wealth of any material changes to their financial
circumstances, investment objectives, or other information relevant to the advisory relationship.
Item 14: Client Referrals and Other Compensation
Threadline Wealth may receive referrals from, or provide referrals to, Baker Tilly and other professional
service providers from time to time in connection with serving clients. These referrals may involve
accounting, tax, consulting, legal, insurance, or other professional services.
Clients are under no obligation to engage Baker Tilly or any other recommended professional or service
provider. Clients remain free to select any service provider of their choosing, and Threadline Wealth will
work with other professionals selected by the client.
Threadline Wealth does not pay compensation to Baker Tilly for client referrals and does not receive
referral compensation from Baker Tilly in connection with such referrals.
Although no direct compensation is exchanged for referrals, these relationships may create a conflict of
interest because the parties may have an incentive to recommend one another’s services. Threadline
Wealth seeks to address such conflicts in the best interests of clients.
Threadline Wealth also maintains certain insurance consulting and policy management arrangements, as
described in Item 10 of this Brochure. Under certain arrangements, Threadline Wealth may receive
ongoing servicing or advisory-related compensation associated with insurance products implemented
18
through third-party providers. These arrangements create a conflict of interest because Threadline Wealth
has a financial incentive associated with the recommendation or retention of such products.
Item 15: Custody
Threadline Wealth is deemed to have custody of certain client assets solely as a result of its authority to
deduct advisory fees directly from client accounts and, in limited circumstances, due to certain standing
letters of authorization (“SLOAs”) or other third-party money movement authorizations granted by clients
in accordance with applicable SEC guidance.
Client assets are maintained with qualified custodians, such as Schwab or Fidelity, and not by Threadline
Wealth. Clients receive account statements directly from their custodian at least quarterly and should
carefully review those statements.
In addition, Threadline Wealth may provide clients with supplemental performance reports, consolidated
reports, or other account-related information. These reports are based on information obtained from
custodians and other third parties believed to be reliable; however, clients should compare any reports
received from Threadline Wealth with the statements received directly from their custodian. In the event of
any discrepancy, the custodian’s records should control. Clients should promptly notify Threadline Wealth
of any discrepancies or concerns.
Threadline Wealth does not take physical custody of client funds or securities.
Item 16: Investment Discretion
Threadline Wealth generally provides investment advisory services on a discretionary basis. Discretionary
authority is granted by clients through the execution of an Investment Advisory Agreement and authorizes
Threadline Wealth to purchase and sell securities, select investment managers, and otherwise manage
client accounts in accordance with the client’s investment objectives, risk tolerance, financial
circumstances, and any agreed investment guidelines or restrictions.
When exercising discretionary authority, Threadline Wealth does not take custody or possession of client
assets beyond the limited authority necessary to effect securities transactions and deduct authorized
advisory fees.
Investment decisions are typically guided by the client’s Investment Policy Statement (“IPS”) or
Investment Objectives Statement (“IOS”), if applicable, as well as ongoing discussions regarding the
client’s financial situation, objectives, and preferences.
Clients may impose reasonable restrictions on the management of their accounts, including restrictions
on specific securities, industries, asset classes, or investment strategies. Threadline Wealth reserves the
right to decline or terminate an advisory relationship if requested restrictions would materially impair the
firm’s ability to manage the account effectively or consistently with the agreed investment strategy.
For clients receiving non-discretionary advisory services, Threadline Wealth must obtain client
authorization prior to implementing investment transactions. As a result, the firm may be unable to
implement recommendations in a timely manner if the client is unavailable or delays providing
instructions, which may adversely affect account performance.
Item 17: Voting Client Securities
Threadline Wealth does not accept authority to vote proxies on behalf of clients and does not provide
advice regarding proxy voting, corporate actions, legal proceedings, class action matters, bankruptcies, or
other issuer-related matters involving securities held in client accounts.
Clients retain responsibility for receiving and responding to proxy materials and other shareholder
communications delivered by issuers, custodians, or transfer agents.
19
Item 18: Financial Information
Threadline Wealth is not aware of any financial condition that is reasonably likely to impair the firm’s
ability to meet its contractual commitments to clients.
Threadline Wealth does not require or solicit the prepayment of advisory fees six months or more in
advance.
20
Rev. 05/26
FACTS
WHAT DOES MOSS ADAMS WEALTH ADVISORS LLC D/B/A
THREADLINE WEALTH DO WITH YOUR PERSONAL
INFORMATION?
Why?
Financial companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law also requires us to tell you how
we collect, share, and protect your personal information. Please read this notice carefully to
understand what we do.
What?
The types of personal information we may collect and share depends on the product or service you
have with us. This information can include:
Tax Identification Number Income
Securities positions Risk Tolerance
Investment Experience Account balances
All financial companies need to share customers’ personal information to run their everyday
business. In the section below, we list the reasons financial companies can share their customers’
personal information; the reasons Moss Adams Wealth Advisors LLC d/b/a Threadline Wealth
chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Can you limit this sharing?
Does Threadline Wealth
share?
YES
NO
For our everyday business purposes— such
as to process your transactions, maintain your
account(s), respond to court orders and legal
investigations, or report to credit bureaus
For our marketing purposes— to
offer our products and services to you
YES
NO
NO
WE DON’T SHARE
For joint marketing with other financial
companies
For our affiliates’ everyday business purposes—
information about your experiences
NO
WE DON’T SHARE
For our affiliates’ everyday business purposes—
information about your creditworthiness
NO
WE DON’T SHARE
For our affiliates to market to you
NO
WE DON’T SHARE
For nonaffiliates to market to you
NO
WE DON’T SHARE
Call 425-650-9500 — our menu will prompt you through your choice(s)
Visit us online: threadlinewealth.com
To limit our
sharing
Please note:
If you are a new customer, we can begin sharing your information 5 days from the date we sent this
notice. When you are no longer our customer, we continue to share your information as described
in this notice.
However, you can contact us at any time to limit our sharing.
Questions? Call 425-650-9500 or go to threadlinewealth.com
Moss Adams Wealth Advisors LLC is doing business as Threadline Wealth is a registered investment advisor with the SEC. Registration does not imply a certain level of
skill or training. Threadline Wealth does not provide tax or legal advice. Threadline Wealth is not an attorney. Estate planning can involve a complex web of tax rules and
regulations. Consider consulting a tax or legal professional about your particular circumstances before implementing any tax or legal strategy. The information provided
here is of a general nature and is not intended to address the specific circumstances of any individual or entity.
Page 2
Who we are
Who is providing this notice?
Moss Adams Wealth Advisors LLC d/b/a Threadline Wealth
What we do
How does Threadline Wealth protect my
personal information?
To protect your personal information from unauthorized access and
use, we use security measures that comply with federal law. These
measures include computer safeguards and secured files and
buildings.
We restrict access to your personal information to those employees
who need it to perform their job responsibilities.
How does Threadline Wealth collect my
personal information?
We collect your personal information, for example, when
you:
seek investment advice
enter into an agreement with Threadline Wealth
Why can’t I limit all sharing?
Federal law gives you the right to limit only
sharing for affiliates’ everyday business purposes
- information about your creditworthiness
affiliates from using your information to market to you
sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to
limit sharing.
We will stop sharing all information about that account.
What happens when I limit sharing
for an account I hold jointly with
someone else?
Definitions
Affiliates
Companies related by common ownership or control. They can be
financial and nonfinancial companies.
Threadline Wealth does not share with affiliates.
Nonaffiliates
Companies not related by common ownership or control. They can be
financial and nonfinancial companies.
Threadline Wealth does not share with nonaffiliates so they can
market to you.
Joint marketing
A formal agreement between nonaffiliated financial companies that
together market financial products or services to you.
Threadline Wealth does not engage joint marketing.
Other important information
You may also opt out from sharing your information by sending an e-mail to compliance@threadlinewealth.com or
call 425-650-9500.
Moss Adams Wealth Advisors LLC is doing business as Threadline Wealth is a registered investment advisor with the SEC. Registration does not imply a certain level of
skill or training. Threadline Wealth does not provide tax or legal advice. Threadline Wealth is not an attorney. Estate planning can involve a complex web of tax rules and
regulations. Consider consulting a tax or legal professional about your particular circumstances before implementing any tax or legal strategy. The information provided
here is of a general nature and is not intended to address the specific circumstances of any individual or entity.