View Document Text
TOTAL SOLUTIONS
ENTERPRISE, LLC
d/b/a Sparta Wealth Partners
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Total Solutions
Enterprise, LLC, which does business as Sparta Wealth Partners. If you have any questions about the contents
of this brochure, please contact us at (704) 575-1148 or by email at: bt@spartawp.com. The information in this
brochure has not been approved or verified by the United States Securities and Exchange Commission or by
any state securities authority.
Additional information about Total Solutions Enterprise, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Total Solutions Enterprise, LLC ’s CRD number is: 318036.
4500 Cameron Valley Parkway
Suite 130
Charlotte, NC 28211
(704) 575-1148
bt@spartawp.com
Registration as an investment adviser does not imply a certain level of skill or training.
Version Date: 7/07/2025
i
Item 2: Material Changes
Total Solutions Enterprise, LLC is required to update this brochure annually and any material changes
will be summarized here in Item 2.
No material changes.
As a registered investment adviser, we must ensure that our brochure is current and accurate and
makes full disclosure of all material facts relating to the advisory relationship. If there have been any
material changes to our business or advisory practices since our last annual update, we will provide a
description of such material changes here.
We encourage you to read through our Form ADV Part 2A Disclosure Brochure in its entirety to fully
understand the services we provide and the associated fees.
Item 3: Table of Contents
Item 1: Cover Page……………………………………………………………………………………………………i
Item 2: Material Changes ........................................................................................................................................ ii
Item 3: Table of Contents ........................................................................................................................................ ii
Item 4: Advisory Business ...................................................................................................................................... 1
Item 5: Fees and Compensation ............................................................................................................................. 3
Item 6: Performance-Based Fees and Side-By-Side Management ...................................................................... 6
Item 7: Types of Clients ........................................................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................................ 8
Item 9: Disciplinary Information .......................................................................................................................... 10
Item 10: Other Financial Industry Activities and Affiliations .......................................................................... 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 11
Item 12: Brokerage Practices ................................................................................................................................. 12
Item 13: Review of Accounts ................................................................................................................................ 14
Item 14: Client Referrals and Other Compensation ........................................................................................... 15
Item 15: Custody .................................................................................................................................................... 16
Item 16: Investment Discretion ............................................................................................................................ 16
Item 17: Voting Client Securities (Proxy Voting) ............................................................................................... 16
ii
Item 18: Financial Information…………………………………………………………………………………….16
Brochure Supplements
Blair Thompson…………………………………………………………………………………………...18
Lori Copeland……………………………………………………………………………………………..20
Thomas James (TJ) Randt II………………………………………………………………………………22
David Monk………………………………………………………………………………………………...24
Matthew A. Novak ……………………………………………………………………………………...26
Jackson Klein……………………………………………………………………………………………..28
Ori Elyse Boucvalt……………………………………………………………………………………….29
Kristopher Alexander Roper.…………………………………………………………………………..31
iii
Item 4: Advisory Business
A. Description of the Advisory Firm
Total Solutions Enterprise, LLC d/b/a Sparta Wealth Partners (hereinafter “Sparta Wealth Partners”)
is a Limited Liability Company organized in the State of North Carolina. The firm was formed in
January 2020, and the principal owner is Total Solutions Enterprise Holdings, LLC.
B. Types of Advisory Services
Portfolio Management Services
Sparta Wealth Partners offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. Sparta Wealth Partners creates an
Investment Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels). Portfolio management services include, but are not limited to:
investment strategy; asset allocation; risk tolerance; personal investment policy; asset selection and
regular portfolio monitoring.
Sparta Wealth Partners evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. Sparta Wealth Partners will request discretionary authority from
clients in order to select securities and execute transactions without permission from the client prior to
each transaction. Risk tolerance levels are documented, a copy of which is given to each client.
Sparta Wealth Partners seeks to make investment decisions that are in accordance with the fiduciary
duties owed to its clients and without consideration of Sparta Wealth Partners’ economic, investment
or other financial interests.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment planning;
insurance; tax concerns; retirement planning; college planning; estate planning; and debt/credit
planning.
Retainer Services
Some clients may want Sparta Wealth Partners to assist them with ongoing financial planning with
a goal toward increased assets. We have a select group of clients that would be ideally served with
our retainer service. Sparta Wealth Partners offers this comprehensive service to clients that want to
focus on financial planning and personal financial preparation. It is charged as an on-going monthly
retainer program of an amount negotiated between the client and Sparta Wealth Partners.
Held Away Account Asset Management
We use a third-party platform (Pontera) to facilitate management of held away assets, such as defined
1
contribution plan participant accounts, with discretion. The platform allows us to avoid being
considered to have custody of Client funds since we do not have direct access to Client login
credentials to conduct trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. When deemed necessary, Adviser will rebalance
the account considering client investment goals and risk tolerance, and any change in allocations will
consider current economic and market trends. Client account(s) will be reviewed at least quarterly
and allocation changes will be made as deemed necessary.
Securities Based Line of Credit (SBLOC)
If Sparta Wealth Partners believes it is appropriate, then it introduces clients to lenders who offer a
line of credit that is backed by securities in their portfolio, which is known as a Securities Based Lines
of Credit (SBLOC). Sparta Wealth Partners does not receive compensation for SBLOC. Sparta Wealth
Partners encourages its clients to carefully read the documents and other disclosures that the lender
provides them for information about the potential restrictions and risks associated with an SBLOC.
C. Client Tailored Services and Client Imposed Restrictions
Sparta Wealth Partners offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client’s situation (income, tax
levels, and risk tolerance levels as examples). Clients may impose restrictions in investing in certain
securities or types of securities in accordance with their values or beliefs. However, if the restrictions
prevent Sparta Wealth Partners from properly servicing the client account, or if the restrictions would
require Sparta Wealth Partners to deviate from its standard suite of services, Sparta Wealth Partners
reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that includes
management fees, transaction costs, fund expenses, and other administrative fees. Sparta Wealth
Partners does not participate in any wrap fee programs.
E. Assets Under Management
Sparta Wealth Partners has the following assets under management:
Discretionary Amounts:
Date Calculated:
Non-discretionary
Amounts:
March 1, 2025
$265,387,750
$0
2
Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management Fees
Sparta Wealth Partners’ advisory fees are negotiable and do not exceed 2.00%. Fees are charged
monthly in advance or arrears. The final fee schedule will be memorialized in the client’s advisory
agreement and custodial agreements. Sparta Wealth Partners uses the value of the account as of the
last business day of the billing period, after taking into account deposits and withdrawals, for
purposes of determining the market value of the assets upon which the advisory fee is based. The
value of the account includes assets held at the client’s custodian as well as investments in private
placements made directly with issuers. Consulting services are included in these fees for asset
management services with the exception of unique circumstances that may require a separate
agreement for financial planning services (description and fees are discussed below). If the situation
warrants separate financial planning fees, it will be discussed upfront and a separate agreement will
be negotiated.
Clients may terminate the agreement without penalty for a full refund of Sparta Wealth Partners' fees
within five business days of signing the Investment Advisory Contract. Thereafter, clients may
terminate the Investment Advisory Contract generally with 30 days' written notice. Clients who
terminate investment advisory services during a month, are charged a prorated advisory free based
on the date of Sparta Wealth Partners’ receipt of client’s written notice to terminate. Any earned but
unpaid fees are immediately due and payable, and any prepaid and unearned fees will be
immediately refunded.
Long/Short Strategy
For clients that elect a Long/Short strategy with a sub-advisor, a 1.00% annual asset-based and a 10%
performance-based “incentive” fee will be charged. The annual asset-based fee is payable monthly
in advance or in arrears, in accordance with the client’s agreement, and is based on the value of the
client’s account at the end of the prior month, with performance-based fee being assessed quarterly
in arrears. If management begins after the start of a month, fees will be prorated accordingly. With
client authorization, fees are normally debited directly from client accounts.
Held Away participant 401K accounts may be charged a lower fee depending on the scope and
complexity of the plan options.
Performance Fee Calculation Methodology
Sparta Wealth Partners gives certain clients the option of being charged performance-based fees.
Due to strict regulatory requirements, performance-based fees can only be charged to “qualified
clients”. A qualified client is defined as a client that has over $1.1 million invested with us, OR a
net worth of at least $2.2 million, excluding primary residence. Performance-based fees may not be
charged to any client that does not meet the definition of a qualified client. For accounts that are
charged performance-based fees, the performance-based fee component of the investment
management fee is calculated as of December 31 of each year. When “Net Profits” are earned for
3
the current period, Sparta Wealth Partners and the sub-advisor will internally share the
performance fee of 10% of the Net Profits generated, subject to a “High Water Mark.” No
performance fee is assessed in any performance measurement period if the Net Profits for the
performance measurement period are zero or negative.
Net Profits for any calculation period equal the current period ending value of net assets (including
unrealized gains and losses, accrued dividends, accrued interest and net of asset-based fees), less
the current High-Water Mark.
The High-Water Mark for an account for any calculation period is the highest ending value of net
assets of an account for which a performance fee was previously paid by the account. The High-Water
Mark will be increased for any deposits added to an account during a calculation period.
If a client withdraws capital from its account before the end of an annual performance period, the
performance fee for the amount withdrawn will be calculated based on the Net Profits for the year
as of the withdrawal date and based on the High-Water Mark.
Performance-based compensation may create an incentive for our firm to recommend investments
that may carry higher degrees of risk to the client. Sparta Wealth Partners has a fiduciary
responsibility to our clients, and we will only make recommendations that meet our clients’
investment objectives and goals.
Financial Planning Fees
Financial planning services are charged in advance or arrears through a fixed fee or hourly
arrangement as agreed upon between the client and Sparta Wealth Partners. There will never be an
instance where $1,200 or more in fees is charged six or more months in advance. Similar financial
planning services may be available elsewhere for a lower cost to the client.
Fixed Fees
Fixed fees are generally quoted to the client for longer-term consulting projects. Fees are negotiable
and vary depending upon the complexity of the client situation and services to be provided. The
negotiated fixed rate for creating client financial plans is a maximum annual fee of $30,000. An
estimate for total hours and charges is determined at the start of the advisory relationship.
Hourly Fees
Hourly fees are generally charged when the scope of services cannot be determined or if the services
are limited to one meeting. Fees are negotiable and vary depending upon the complexity of the client
situation and services to be provided. The negotiated hourly fee for these services is no more than
$500.
Retainer Services
Retainer services are available to clients that wish to have ongoing financial planning and consulting.
Retainer services include coordinating, advising and consulting on all financial matters, and
4
introducing clients to outside professionals whose areas of expertise are outside Sparta Wealth
Partners’ professional expertise. Services may include financial advising on expected life changes,
personal budgeting, estate planning, and insurance assessment. In addition, retainer services may
include creating budgets and planning for saving and retirement contributions. The retainer services
provide clients with a “go to” person on any financial matter that arises. Retainer fees are billed
monthly and in advance or arrears. The fee is negotiable and can be renegotiated on an annual basis.
The retainer fee includes an on-board and initial plan fee as well as the ongoing monthly fee charged
in advance or arrears. Clients are provided a fee invoice which is payable upon receipt. Should the
Agreement be terminated, the retainer fee will not be prorated for any remaining days in the month.
Clients may terminate the agreement without penalty, for full refund of Sparta Wealth Partners’ fees,
within five business days of signing the Financial Planning Agreement. Thereafter, clients may
terminate the Financial Planning Agreement generally upon written notice. Upon receipt of written
notification, any earned fee will immediately become due and payable, and any prepaid and
unearned fees will be immediately refunded.
B. Payment of Fees
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's
written authorization on a monthly basis. Fees are paid in accordance with the client’s agreement
with Sparta, which may be in advance or in arrears.
Payment of Financial Planning Fees
Financial planning fees are paid via check, ACH or credit card.
Fixed financial planning fees are paid 100% in advance, but never more than six months in advance.
Hourly financial planning fees are paid 100% in advance, but never more than six months in advance.
C. Client Responsibility For Third-Party Fees
Clients are responsible for the payment of all third-party fees (i.e., custodian fees, brokerage fees,
mutual fund fees, transaction fees, lending fees, etc.). Those fees are separate and distinct from the
fees and expenses charged by Sparta Wealth Partners. Please see Item 12 of this brochure regarding
broker-dealer/custodian.
D. Prepayment of Fees
Sparta Wealth Partners collects certain fees in advance and certain fees in arrears, as indicated above.
Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned
within fourteen days to the client via check, or return deposit back into the client’s account.
5
Fixed fees that are collected in advance will be refunded based on the prorated amount of work
completed at the point of termination.
For hourly fees that are collected in advance, the fee refunded will be the balance of the fees collected
in advance minus the hourly rate times the number of hours of work that has been completed up to
and including the day of termination.
E. Outside Compensation For the Sale of Securities to Clients
With certain outside business activities (see Item 10 below), representatives of Sparta Wealth
Partners, including but not limited to Blair Thompson, are licensed to accept compensation for the
sale of investment products to Sparta Wealth Partners clients. As such, the supervised person may
receive compensation from Sparta Wealth Partners in regard to clients assets under management plus
commissions for the sales of investment products through a broker-dealer. Consequently, this gives
the supervised person an incentive to recommend products based on the compensation received
rather than on the client’s needs. Clients always have the right to decide whether to purchase
recommended products and, if purchasing, have the right to purchase those products through other
brokers or agents that are not affiliated with Sparta Wealth Partners.
Item 6: Performance-Based Fees and Side-By-Side Management
As noted above, Sparta Wealth Partners offers to manage Long/Short Strategy portfolios pursuant to
an asset-based investment management fee and performance-based investment management fee
arrangement. The client compensates Sparta Wealth Partners for its services, in addition to an asset-
based investment management fee based on the market value of the client’s assets, by paying Sparta
Wealth Partners a percentage of the Net Profits of the client’s investment in the strategy. Sparta
Wealth Partners charges these performance-based fees on Net Profits each year, however, if a
portfolio subject to such a fee arrangement has no Net Profits in a particular year, no performance fee
will be charged until prior losses have been recouped (see discussion of “High Water Mark” in Item 5
Fees and Compensation above).
Performance-based fees are calculated and assessed in arrears, and the client should carefully review
the performance fee calculations described in Item 5 Fees and Compensation above for accuracy.
Clients should be aware that when Sparta Wealth Partners receives a performance-based fee, which
is a financial incentive to achieve gains in excess of the disincentive to suffer losses, Sparta Wealth
Partners and/or sub advisors may have an incentive to choose investments that are riskier or more
speculative than might otherwise be chosen. Sparta Wealth Partners has a fiduciary responsibility
to our clients, and we will only make recommendations that we believe meet our clients’ investment
objectives and goals.
6
Item 7: Types of Clients
Sparta Wealth Partners generally provides advisory services to the following types of clients:
Individuals
High-Net-Worth Individuals
Pension and Profit-Sharing Plans
Corporations or Business Entities
❖
❖
❖
❖
There is no account minimum for any of Sparta Wealth Partners’ services.
Item 8: Methods of Analysis, Investment Strategies, &
Risk of Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
Sparta Wealth Partners’ methods of analysis include Fundamental analysis and Technical analysis.
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages.
Technical analysis involves the analysis of past market data; primarily price and volume.
Investment Strategies
Sparta Wealth Partners uses long-term trading and short-term trading.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
7
B. Material Risks Involved
Methods of Analysis
Fundamental analysis concentrates on factors that determine a company’s value and expected future
earnings. This strategy would normally encourage equity purchases in stocks that are undervalued
or priced below their perceived value. The risk assumed is that the market will fail to reach
expectations of perceived value.
Technical analysis attempts to predict a future stock price or direction based on market trends. The
assumption is that the market follows discernible patterns and if these patterns can be identified then
a prediction can be made. The risk is that markets do not always follow patterns and relying solely
on this method may not take into account new patterns that emerge over time.
Investment Strategies
Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the
long-term investment strategy can expose clients to various types of risk that will typically surface at
various intervals during the time the client owns the investments. These risks include but are not
limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and
political/regulatory risk.
Short-term trading risks include liquidity, economic stability, and inflation, in addition to the long-
term trading risks listed above. Frequent trading can affect investment performance, particularly
through increased brokerage costs and taxes.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
C. Risks of Specific Securities Utilized
Clients should be aware that there is a material risk of loss using any investment strategy. The
investment types listed below are not guaranteed or insured by the Federal Deposit Insurance
Corporation (FDIC) or any other government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money
investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can
be of bond “fixed income” nature (lower risk) or stock “equity” nature.
Equity investment generally refers to buying shares of stocks in return for receiving a future payment
of dividends and/or capital gains if the value of the stock increases. The value of equity securities
may fluctuate in response to specific situations for each company, industry conditions and the general
economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount of the
payments can vary. This type of investment can include corporate and government debt securities,
leveraged loans, high yield, and investment grade debt and structured products, such as mortgage
8
and other asset-backed securities, although individual bonds may be the best known type of fixed
income security. In general, the fixed income market is volatile and fixed income securities carry
interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually
more pronounced for longer-term securities.) Fixed income securities also carry inflation risk,
liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of
default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury
defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal. Risks of investing in foreign fixed income securities also include the general risk of
non-U.S. investing described below.
Exchange-Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to
stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of an
ETF that holds a single stock that enters bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the possibility of
inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and
shutdown risks, risks associated with a change in authorized participants and non-participation of
authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price
fluctuation and disassociation from the index being tracked.
With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low
fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the
market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the
majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs
have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading
conditions are more accurately reflected in implied liquidity rather than the average daily volume of
the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its
underlying assets. ETFs are subject to market volatility and the risks of their underlying securities,
which may include the risks associated with investing in smaller companies, foreign securities,
commodities, and fixed income investments (as applicable).
Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and
political risks, all of which are magnified in emerging markets. ETFs that target a small universe of
securities, such as a specific region or market sector, are generally subject to greater market volatility,
as well as to the specific risks associated with that sector, region, or other focus. ETFs that use
derivatives, leverage, or complex investment strategies are subject to additional risks.
The return of an index ETF is usually different from that of the index it tracks because of fees,
expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV)
(or indicative value in the case of exchange-traded notes). The degree of liquidity can vary
significantly from one ETF to another and losses may be magnified if no liquid market exists for the
ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its
prospectus, offering circular, or similar material, which should be considered carefully when making
investment decisions.
Alternative Investments: Alternative Investments are unregistered private investment partnerships,
funds or pools that may invest and trade in many different market strategies, and instruments
(including securities, non-securities and derivatives) and that employ different investment, hedging,
leverage and arbitrage methodologies. Alternative Investments are not subject to the same regulatory
9
requirements as mutual funds, including requirements to provide certain periodic and standardized
pricing and valuation information to investors. Alternative Investment documents are not reviewed
or approved by federal or state regulators. Alternative Investments are not required to provide
periodic pricing or valuation information to investors and it may be their practice not to provide such
information.
An Alternative Investment may have limited liquidity or may be illiquid and there may be significant
restrictions on transferring interests. Moreover, there is no secondary market for an investor’s
investment in an Alternative Investment and none is expected to develop.
An Alternative Investment’s fees and expenses, which may be substantial regardless of any positive
return, will offset the investment’s trading profits.
Alternative Investments may have little or no operating history or performance and may use
hypothetical or pro forma performance which may not reflect actual trading done by the manager or
advisor and such history or performance should be reviewed carefully.
Past performance is not indicative of future results. Investing in securities involves a risk of loss
that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-Regulatory Organization (SRO) Proceedings
Other than what is disclosed in the Part 2B of this disclosure for Lori Copeland, there are no self-
regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Certain representatives of Sparta Wealth Partners are also registered representatives of Realta
Equities, Inc. (CRD# 23769), as indicated in Part 2B of this disclosure.
10
B. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor
Neither Sparta Wealth Partners nor its representatives are registered as or have pending applications
to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity
Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business
and Possible Conflicts of Interests
Blair Thompson is an independent licensed insurance agent, and from time to time, will offer clients
advice or products from those activities. Clients should be aware that these services pay a commission
or other compensation and involve a conflict of interest, as commissionable products conflict with
the fiduciary duties of a registered investment adviser. Sparta Wealth Partners always acts in the best
interest of the client; including the sale of commissionable products to advisory clients. Clients are in
no way required to utilize the services of any representative of Sparta Wealth Partners in connection
with such individual's activities outside of Sparta Wealth Partners.
D. Selection of Other Advisers or Managers and How This Adviser
is Compensated for Those Selections
Sparta Wealth Partners may recommend third-party asset managers from whom we will receive a
portion of the advisory fees charges to you by the third-party manager. This is a conflict of interest
which we manage by selecting only third-party managers that provide services advantageous to our
clients based on cost, management styles, past history, ability to meet client needs, and unique
services not otherwise available to our clients. The portion of the fee that we receive is based on the
size and growth of your account, so our interests are aligned with yours to work to achieve your
performance objectives.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
Sparta Wealth Partners has a written Code of Ethics that covers prohibited transactions, insider
trading, and conflicts of interest, among other provisions. Sparta Wealth Partners’ Code of Ethics is
available free upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
Sparta Wealth Partners does not recommend that clients buy or sell any security in which a related
person to Sparta Wealth Partners or Sparta Wealth Partners has a material financial interest.
11
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of Sparta Wealth Partners may buy or sell securities for themselves
that they also recommend to clients. This may provide an opportunity for representatives of Sparta
Wealth Partners to buy or sell the same securities before or after recommending the same securities
to clients resulting in representatives profiting off the recommendations they provide to clients. Such
transactions may create a conflict of interest. Sparta Wealth Partners will always document any
transactions that could be construed as conflicts of interest and will never engage in trading that
operates to the client’s disadvantage when similar securities are being bought or sold.
D. Trading Securities At/Around the Same Time as Clients’
Securities
From time to time, representatives of Sparta Wealth Partners may buy or sell securities for themselves
at or around the same time as clients. This may provide an opportunity for representatives of Sparta
Wealth Partners to buy or sell securities before or after recommending securities to clients resulting
in representatives profiting off the recommendations they provide to clients. Such transactions may
create a conflict of interest; however, Sparta Wealth Partners will never engage in trading that
operates to the client’s disadvantage if representatives of Sparta Wealth Partners buy or sell securities
at or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker-Dealers
Custodians/broker-dealers will be recommended based on Sparta Wealth Partners’ duty to seek “best
execution,” which is the obligation to seek execution of securities transactions for a client on the most
favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest
commission or commission equivalent, and Sparta Wealth Partners may also consider the market
expertise and research access provided by the broker-dealer/custodian, including but not limited to
access to written research, oral communication with analysts, admittance to research conferences and
other resources provided by the brokers that may aid in Sparta Wealth Partners’ research efforts.
Sparta Wealth Partners will never charge a premium or commission on transactions beyond the actual
cost imposed by the broker-dealer/custodian.
Sparta Wealth Partners typically recommends Schwab Institutional, a division of Charles Schwab &
Co., Inc., Interactive Brokers and IRA Club.
While you are free to choose any broker-dealer or other service provider, we recommend that you
establish an account with a brokerage firm with which we have an existing relationship. Such
relationships may include benefits provided to our firm, including, but not limited to research,
market information, and administrative services that help our firm manage your account(s). We
believe that recommended broker-dealers provide quality execution services for our clients at
competitive prices. Price is not the sole factor we consider in evaluating best execution. We also
12
consider the quality of the brokerage services provided by the recommended broker-dealers,
including the value of research provided, the firm’s reputation, execution capabilities, commission
rates, and responsiveness to our clients and our firm.
You may direct us in writing to use a particular broker-dealer to execute some or all of the transactions
for your account. If you do so, you are responsible for negotiating the terms and arrangements for the
account with that broker-dealer. We may not be able to negotiate commissions, obtain volume
discounts, or best execution. 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 broker
or dealer and other clients who do not direct us to use a particular broker or dealer.
Sparta Wealth Partners does not receive client referrals from broker-dealers in exchange for cash or
other compensation, such as brokerage services or research.
Sparta Wealth Partners does not have any formal soft dollar arrangements.
B. Aggregating (Block) Trading for Multiple Client Accounts
If Sparta Wealth Partners buys or sells the same securities on behalf of more than one client, then it
may (but would be under no obligation to) aggregate or bunch such securities in a single transaction
for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more
efficient execution. In such case, Sparta Wealth Partners would place an aggregate order with the
broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that
trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged
by this policy. Sparta Wealth Partners would determine the appropriate number of shares and select
the appropriate brokers consistent with its duty to seek best execution, except for those accounts with
specific brokerage direction (if any).
To meet its fiduciary obligations, Sparta Wealth Partners attempts to avoid, among other things,
investment or trading practices that systematically advantage or disadvantage certain client
portfolios, and accordingly, Sparta Wealth Partners’ policy is to seek fair and equitable allocation of
investment opportunities/transactions among its clients to avoid favoring one client over another
over time. It is Sparta Wealth Partners’ policy to allocate investment opportunities and transactions
it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time.
13
Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes
Those Reviews
Account reviews are performed annually or at the request of the client by the Investment Adviser
Representative assigned to the account. They monitor the performance of each investment based
on how similar investments have performed and make changes when necessary. The portfolio
manager determines the investment strategies and parameters for each account. Account reviews
are performed more frequently when market conditions dictate.
While reviews and updates to the financial plan are not part of the contracted services, at your
request we will review your financial plan to determine if the investment advice provided is
consistent with your investment needs and objectives. We will also update the financial plan at
your request. At our sole discretion, reviews and updates may be subject to our current hourly rate.
For those clients to whom Sparta Wealth Partners provides ongoing financial advisory services,
reviews are conducted on an as needed or agreed upon basis. Such reviews are conducted by one
of Sparta Wealth Partners investment adviser representatives or principals.
B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
Reviews may be triggered by material market, economic or political events, or by changes in client's
financial situations (such as retirement, termination of employment, physical move, or inheritance).
With respect to financial plans, Sparta Wealth Partners’ services will generally conclude upon
delivery of the financial plan.
C. Content and Frequency of Regular Reports Provided to Clients
Each client of Sparta Wealth Partners' advisory services provided on an ongoing basis will receive a
quarterly report detailing the client’s account, including assets held, asset value, and calculation of
fees. This written report will come from the custodian.
Each financial planning client will receive the financial plan upon completion.
14
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice
Rendered to Clients (Includes Sales Awards or Other Prizes)
Other than soft dollar benefits as described in Item 12 above, Sparta Wealth Partners does not receive
any economic benefit, directly or indirectly from any third party for advice rendered to Sparta Wealth
Partners clients.
With respect only to Schwab, Sparta Wealth Partners receives access to Schwab’s institutional trading
and custody services, which are typically not available to Schwab retail investors. These services
generally are available to independent investment advisers on an unsolicited basis, at no charge to
them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts
at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the
execution of securities transactions, custody, research, including that in the form of advice, analyses
and reports, and access to mutual funds and other investments that are otherwise generally available
only to institutional investors or would require a significantly higher minimum initial investment.
For Sparta Wealth Partners client accounts maintained in its custody, Schwab generally does not
charge separately for custody services but is compensated by account holders through commissions
or other transaction-related or asset-based fees for securities trades that are executed through Schwab
or that settle into Schwab accounts.
Schwab also makes available to Sparta Wealth Partners other products and services that benefit
Sparta Wealth Partners but may not benefit its clients’ accounts. These benefits may include national,
regional or Sparta Wealth Partners specific educational events organized and/or sponsored by
Schwab Advisor Services. Other potential benefits may include occasional business entertainment of
personnel of Sparta Wealth Partners by Schwab Advisor Services personnel, including meals,
invitations to sporting events, including golf tournaments, and other forms of entertainment, some
of which may accompany educational opportunities. Other of these products and services assist Sparta
Wealth Partners in managing and administering clients’ accounts. These include software and other
technology (and related technological training) that provide access to client account data (such as
trade confirmations and account statements), facilitate trade execution (and allocation of aggregated
trade orders for multiple client accounts, if applicable), provide research, pricing information and
other market data, facilitate payment of Sparta Wealth Partners’ fees from its clients’ accounts (if
applicable), and assist with back-office training and support functions, recordkeeping and client
reporting. Many of these services generally may be used to service all or some substantial number of
Sparta Wealth Partners’ accounts. Schwab Advisor Services also makes available to Sparta Wealth
Partners other services intended to help Sparta Wealth Partners manage and further develop its
business enterprise. These services may include professional compliance, legal and business
consulting, publications and conferences on practice management, information technology, business
succession, regulatory compliance, employee benefits providers, human capital consultants,
insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for
these types of services rendered to Sparta Wealth Partners by independent third parties. Schwab
Advisor Services may discount or waive fees it would otherwise charge for some of these services or
pay all or a part of the fees of a third-party providing these services to Sparta Wealth Partners. Sparta
15
Wealth Partners is independently owned and operated and not affiliated with Schwab.
B. Compensation to Non – Advisory Personnel for Client Referrals
Sparta Wealth Partners does not directly or indirectly compensate any person who is not advisory
personnel for client referrals.
Item 15: Custody
Sparta Wealth Partners does not take custody of client funds. When advisory fees are deducted
directly from client accounts at client's custodian, Sparta Wealth Partners must have written
authorization from the client to do so. Clients will receive all account statements and billing invoices
that are required in each jurisdiction, and they should carefully review those statements for
accuracy.
Item 16: Investment Discretion
Sparta Wealth Partners provides discretionary and non-discretionary investment advisory services
to clients. The advisory contract established with each client sets forth the discretionary authority for
trading. Where investment discretion has been granted, Sparta Wealth Partners generally manages the
client’s account and makes investment decisions without consultation with the client as to when the
securities are to be bought or sold for the account, the total amount of the securities to be bought/sold,
what securities to buy or sell, or the price per share.
Item 17: Voting Client Securities (Proxy Voting)
Sparta Wealth Partners will not ask for, nor accept, voting authority for client securities. Clients will
receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy
questions to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
Sparta Wealth Partners neither requires nor solicits prepayment of more than $1,200 in fees per client,
six months or more in advance, and therefore is not required to include a balance sheet with this
brochure.
16
B. Financial Conditions Reasonably Likely to Impair Ability to
Meet Contractual Commitments to Clients
Neither Sparta Wealth Partners nor its management has any financial condition that is likely to
reasonably impair Sparta Wealth Partners’ ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
Sparta Wealth Partners has not been the subject of a bankruptcy petition in the last ten years.
17
Brochure Supplement: Blair Thompson
Form ADV, Part 2B Brochure Supplement
Blair Thompson, President & Partner Advisor
Born: 1982
Total Solutions Enterprise, LLC (d/b/a Sparta Wealth Partners)
4500 Cameron Valley Parkway
Suite 130
Charlotte, NC 28211
(704) 575-1148
bt@spartawp.com
July 07, 2025
This brochure supplement provides information about David (“Blair”) Thompson that
supplements the Sparta Wealth Partners brochure. You should have received a copy of that
brochure. Please contact him at (704) 575-1148 if you did not receive the Sparta Wealth Partners
brochure or if you have questions or comments about this supplement. Additional information
about Mr. Thompson also is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Education Background and Business Experience
Mr. Thompson serves as Founder and President of Sparta Wealth Partners. Employing his strategic
background, Mr. Thompson has assembled a wealth of business and financial resource specialists to
meet the full spectrum of client needs all in one place. As both an adviser and leader of Sparta, helping
others be successful is truly Mr. Thompson's passion.
Formerly a Senior Vice President and HNW Relationship Manager with private banks, Mr.
Thompson delivered a full suite of private banking, investment management, wealth planning, trust,
insurance and estate services to high net worth individuals and companies across the country. Prior
to the private banking roles, Mr. Thompson owned and operated his own firm, Thompson Financial
Partners, that evolved from a career adviser to a fully independent model in the late 2000’s prior to
being rolled into the bank channel. This experience serves as a tremendous basis for helping
successful business owners evaluate what banking products, offerings and services best meet their
needs from an agnostic advocate or personal CFO type lens.
Mr. Thompson holds a bachelor’s degree in Economics and Spanish from the University of North
Carolina at Chapel Hill. He has also served on the boards of the Society of Financial Services
Professionals, National Association of Insurance and Financial Advisers, Special Operator Transition
Foundation, The Rosie Network and the SEAL Naval Special Warfare Family Foundation. While Mr.
Thompson is a civilian, he has also served on a National Innovation Council with the Department of
Defense and is a uniquely positioned strategic adviser to companies in the US Special Operations
Command Network. Mr. Thompson was also appointed as the Private Capital Adviser for NavalX, a
government organization focused on connecting the US Navy with private sector companies,
entrepreneurs and disruptive technology. Mr. Thompson maintains his Series 7, 63, and 65
18
registrations along with life, health, disability and long-term care insurance licenses. Born in 1982.
Item 3 – Disciplinary Information
Mr. Thompson has not been the subject of any legal or disciplinary event requiring disclosure under
the laws or regulations governing disclosure to investment advisory clients.
Item 4 – Other Business Activities
Mr. Thompson is a registered representative of Realta Equities, Inc. He is also a licensed insurance
agent. From time to time, he will offer clients advice or products from those activities. Clients should
be aware that these services pay a commission or other compensation and involve a conflict of
interest, as commissionable products may conflict with the fiduciary duties of a Registered
Investment Adviser. Sparta Wealth Partners acts in the best interest of the client; including the sale
of commissionable products to advisory clients. Clients always have the right to decide whether or
not to utilize the services of any Sparta Wealth Partners representative in such individual’s outside
capacities. He spends approximately 5 hours a month on each activity.
Additional information about Mr. Thompson can be found at brokercheck.finra.org.
Item 5 – Additional Compensation
Mr. Thompson does not receive any economic benefit from any person, company, or organization
other than Sparta Wealth Partners in exchange for providing clients advisory services. However, Mr.
Thompson receives additional compensation from his brokerage and insurance commission business,
as well as from consulting fees and other revenue generated by Backstage Pass LLC, Sine Pari LLC
or DBT Consulting LLC.
Item 6 – Supervision
As Sparta Wealth Partners’ Chief Compliance Officer, Mr. Thompson supervises all activities of the
firm. His contact information is on the cover page of this disclosure document. Mr. Thompson
adheres to applicable regulatory requirements, together with all policies and procedures outlined in
the firm’s code of ethics and compliance manual.
19
Brochure Supplement: Lori Copeland
Form ADV, Part 2B Brochure Supplement
Lori Copeland, Senior Adviser
Born: 1974
Total Solutions Enterprise, LLC (d/b/a Sparta Wealth Partners)
4500 Cameron Valley Parkway
Suite 130
Charlotte, NC 28211
(704) 575-1148
July 07, 2025
This brochure supplement provides information about Lori Copeland that supplements the Sparta
Wealth Partners brochure. You should have received a copy of that brochure. Please contact Blair
Thompson at (704) 575-1148 if you did not receive the Sparta Wealth Partners brochure or if you
have questions or comments about this supplement. Additional
information about Ms.
Copeland also is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Education Background and Business Experience
Ms. Copeland became a Senior Adviser of Sparta Wealth Partners in January 2023. Prior to joining
Sparta Wealth Partners, she was an Investment Advisor Representative of Independent Advisor
Alliance, LLC and a Registered Representative of LPL Financial, positions she had held since 2021.
She was the Director of Marketing of SilverRock Wealth Partners from 2017 to 2021. Born in 1974.
Ms. Copeland earned a Bachelor of Science, Finance from the University of South Carolina, South
Carolina Honors College.
Item 3 – Disciplinary Information
On February 21, 2024, Ms. Copeland entered a Letter of Acceptance, Waiver, and Consent (AWC)
with the Financial Industry Regulatory Authority, Inc. (FINRA) in which, without admitting or
denying them, Ms. Copeland accepted and consented to FINRA's finding that she refused to provide
documents and information requested pursuant to FINRA Rule 8210, in violation of FINRA Rules
8210 and 2010, and a bar from associating with any FINRA member in all capacities.
Item 4 – Other Business Activities
Ms. Copeland is not currently involved with any other business activities.
Item 5 – Additional Compensation
Ms. Copeland does not receive any compensation other than she receives for performing services for
Sparta Wealth Partners, as disclosed in the firm’s various disclosures.
20
Item 6 – Supervision
Ms. Copeland reports directly to and is supervised by Blair Thompson. Mr. Thompson periodically
reviews all accounts serviced by Ms. Copeland and regularly communicates with Ms. Copeland
regarding the status of client accounts. Any client with questions or concerns regarding the
supervision of Ms. Copeland is asked to contact Mr. Thompson directly at (704) 575-1148.
21
Brochure Supplement: Thomas James (TJ) Randt II
Form ADV, Part 2B Brochure Supplement
Thomas J. Randt, Advisor
Born: 1989
Total Solutions Enterprise, LLC (d/b/a Sparta Wealth Partners)
10909 East Decatur Circle
Mesa, Arizona 85207
(480) 580-3058
July 7, 2025
This brochure supplement provides information about TJ Randt that supplements the Sparta
Wealth Partners brochure. You should have received a copy of that brochure. Please contact Blair
Thompson at (704) 575-1148 if you did not receive the Sparta Wealth Partners brochure or if you
have questions or comments about this supplement. Additional information about Mr. Randt
also is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Education Background and Business Experience
Mr. Randt serves as an advisor of Sparta Wealth Partners. Prior to joining Sparta Wealth Partners,
Mr. Randt was a Vice President and Financial Consultant with Charles Schwab, where he advised
clients with various needs that ranged from conducting financial planning sessions to educating
them on derivative strategies such as covered calls and cash secured equity puts. From August 2017
to October 2021, Mr. Randt held positions as an Equity Trader at T3 Trading Group, an Associate
Account Executive at Mutual of America Securities and a Financial Solutions Advisor at Bank of
America-Merrill Lynch. He holds the Series 7, 57 and 66 licenses as well as Life, Variable Life and
Variable Annuity and Accident and Health or Sickness insurance licenses in Arizona. Born in 1989.
Item 3 – Disciplinary Information
Mr. Randt has not been the subject of any legal or disciplinary event requiring disclosure under the
laws or regulations governing disclosure to investment advisory clients.
Item 4 – Other Business Activities
Additional information about Mr. Randt can be found at brokercheck.finra.org.
Item 5 – Additional Compensation
Mr. Randt does not receive any economic benefit from any person, company, or organization, other
than from Sparta Wealth Partners in exchange for providing clients advisory services.
22
Item 6 – Supervision
Mr. Randt reports directly to and is supervised by Blair Thompson. Mr. Thompson periodically
reviews all accounts serviced by Mr. Randt and regularly communicates with Mr. Randt regarding
the status of client accounts. Any client with questions or concerns regarding the supervision of Mr.
Randt is asked to contact Mr. Thompson directly at (704) 575-1148.
23
Brochure Supplement: David Monk
Form ADV, Part 2B Brochure Supplement
David Lewis Monk, Advisor Born: 1995
Total Solutions Enterprise, LLC (d/b/a Sparta Wealth Partners)
423 Hurston Circle
Charlotte, NC 28208
(336) 425-5413
July 7, 2025
This brochure supplement provides information about David Monk that supplements the Sparta
Wealth Partners brochure. You should have received a copy of that brochure. Please contact Blair
Thompson at (704) 575-1148 if you did not receive the Sparta Wealth Partners brochure or if you
have questions or comments about this supplement. Additional information about Mr. Monk
also is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Education Background and Business Experience
Mr. Monk joined Sparta Wealth Partners as a Financial Planning Coordinator in September 2024 and
added the role of Financial Advisor in December 2024. Prior to joining Sparta Wealth Partners, Mr.
Monk was a Client Associate/Paraplanner with The Pelora Group from April 2022 to June 2024.
There he helped clients gather and analyze their financial data and built comprehensive financial
plans and insurance proposals based on his analysis of that data and other financial requirements.
From November 2020 to January 2022, Mr. Monk was an agent with New York Life, where he helped
his clients determine their insurance risk, goals, current coverage, and financial situation and
identify insurance needs. Prior to joining New York Life, he was an Operations Manager for
Lexington Barbeque from June 2018 to October 2020. Mr. Monk earned his Bachelor of Science
degree at East Carolina University and holds the Series 6, 63 and 65 licenses as well as Life, Accident
and Health or Sickness and Medicare Supplement/Long-Term Care insurance licenses in North
Carolina. Born in 1995.
Item 3 – Disciplinary Information
Mr. Monk has not been the subject of any legal or disciplinary event requiring disclosure under the
laws or regulations governing disclosure to investment advisory clients.
Item 4 – Other Business Activities
Mr. Monk helps Lexington Barbecue, which is a family business, fulfill orders for its sauces and
merchandise. This is a part-time position that he typically performs outside regular business hours.
24
Item 5 – Additional Compensation
Mr. Monk does not receive any economic benefit from any person, company, or organization, other
than from Sparta Wealth Partners in exchange for providing clients advisory services.
Item 6 – Supervision
Mr. Monk reports directly to and is supervised by Blair Thompson. Mr. Thompson periodically
reviews all accounts serviced by Mr. Monk and regularly communicates with Mr. Monk regarding
the status of client accounts. Any client with questions or concerns regarding the supervision of Mr.
Monk is asked to contact Mr. Thompson directly at (704) 575-1148.
25
Brochure Supplement: Matthew A. Novak
Form ADV, Part 2B Brochure Supplement
Matthew A. Novak, Advisor
Born: 1986
Total Solutions Enterprise, LLC (d/b/a Sparta Wealth Partners)
12805 US-98 E Ste B202
Inlet Beach, FL 34261
(330) 719-7187
July 7, 2025
This brochure supplement provides information about Matthew A. Novak that supplements the
Sparta Wealth Partners brochure. You should have received a copy of that brochure. Please contact
Blair Thompson at (704) 575-1148 if you did not receive the Sparta Wealth Partners brochure or if
you have questions or comments about this supplement. Additional information about Mr.
Novak also is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Education Background and Business Experience
Mr. Novak joined Sparta Wealth Partners as an Advisor in April 2025. He is a registered
representative with Realta Equities, Inc. since April 2025. He was an investment advisor
representative with International Asset Advisory, LLC from June 2018 to April 2025. He was a
registered representative with International Asset Investment Management, LLC from June 2018 to
May 2024. He was a Wealth Management Advisor with Morgan Stanley from December 2013 to June
2018. Mr. Novak earned his Bachelor of Science degree in Finance from the Ohio State University
and a Master of Science degree in Real estate from Florida International University. Mr. Novak holds
the Series 7, 63 and 65 licenses.
Item 3 – Disciplinary Information
Mr. Novak has not been the subject of any legal or disciplinary event requiring disclosure under the
laws or regulations governing disclosure to investment advisory clients.
Item 4 – Other Business Activities
Mr. Novak has the following outside business activities:
• 305 NAILS & SPA; 733 5TH ST MIAMI BEACH, FL 33139; NOT INVESTMENT RELATED;
NAIL SALON; 305NAILSMIAMI.COM/HOME/APPOINTMENTLINK; OWNER; NET
PROFITS; 0.5 HOURS NONE DURING NORMAL TRADING HOURS.
• CIPCO LLC; 3645 NW 36TH ST APT 509 MIAMI, FL 33142; REAL ESTATE HOLDING;
OWNER/REALTOR; NET PROFITS; 1 HOUR PER WEEK NONE DURING NORMAL
TRADING HOURS.
• HILL COLEMAN ENTERPRISE; 12805 US HWY 98 E STE B202 INLET BEACH, FL 32461; NOT
INVESTMENT RELATED; ACCOUNTING FIRM; HILLCOLEMANCPA.COM;
26
OWNER/BUSINESS DEVELOPMENT; NET PROFITS; 5 HOURS PER WEEK NONE DURING
NORMAL TRADING HOURS.
• NOVAK INSURANCE GROUP; 3645 NW 36TH ST APT 509 MIAMI, FL 33142; NOT
INVESTMENT RELATED; INSURANCE SALES; INSURANCE AGENT SINCE 6/2022;
COMMISSIONS; 2 HOURS PER WEEK NONE DURING NORMAL TRADING HOURS.
• MATTHEW NOVAK REAL ESTATE; 3645 NW 36TH ST APT 509 MIAMI, FL 33142; NOT
INVESTMENT RELATED; REAL ESTATE AGENT; MATTHEWNOVAKREALESTATE.COM;
OWNER/REAL ESTATE AGENT; COMMISSIONS; 2 HOURS PER WEEK NONE DURING
NORMAL TRADING HOURS.
• THE MAN ASSOCIATION; 3645 NW 36th St Apt 509 Miami, FL 33142; PERSONAL HOLDING
CO. FOR INVESTMENT BUSINESS EARNINGS - OWNER SINCE 6/2018; COMMISSIONS; 40
HOURS PER WEEK DURING NORMAL TRADING HOURS.
• BARBY NAILS SPA; 224 MIRACLE MILE BAY 224 CORAL GABLES, FL 33134; NOT
INVESTMENT RELATED; NAIL SALON; BARBY-NAILS-SPA-LLC.SQUARE.SITE/; OWNER;
NET PROFITS; 1 HOURS PER WEEK NONE DURING NORMAL TRADING HOURS.
• ANDERSON & COLE NAIL SPA; 14741 BISCAYNE BLVD SPACE 150 NORTH MIAMI
BEACH, FL 33181; NOT INVESTMENT RELATED; NAIL SALON;
ANDERSONANDCOLENAIL.COM; OWNER SINCE 9/2023; NET PROFITS; 1 HOUR PER
WEEK NONE DURING NORMAL TRADING HOURS
Item 5 – Additional Compensation
Mr. Novak does not receive any economic benefit from any person, company, or organization, other
than from Sparta Wealth Partners in exchange for providing clients advisory services.
Item 6 – Supervision
Mr. Novak reports directly to and is supervised by Blair Thompson. Mr. Thompson periodically
reviews all accounts serviced by Mr. Novak and regularly communicates with Mr. Novak regarding
the status of client accounts. Any client with questions or concerns regarding the supervision of Mr.
Novak is asked to contact Mr. Thompson directly at (704) 575-1148.
27
Brochure Supplement: Jackson Klein
Form ADV, Part 2B Brochure Supplement
Jackson Klein, Advisor
Born: 2003
Total Solutions Enterprise, LLC (d/b/a Sparta Wealth Partners)
4500 Cameron Valley Parkway
Suite 130
Charlotte, NC 28211
(704) 575-1148
July 07, 2025
This brochure supplement provides information about Jackson Klein that supplements the Sparta
Wealth Partners brochure. You should have received a copy of that brochure. Please contact Blair
Thompson at (704) 575-1148 if you did not receive the Sparta Wealth Partners brochure or if you
have questions or comments about this supplement. Additional information about Mr. Novak
also is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Education Background and Business Experience
Mr. Klein joined Sparta Wealth Partners as an Advisor in June 2025. In May 2025, he graduated with
a bachelor’s degree from the University of South Carolina. While in college, he interned with Cola
Wealth Advisers, Morgan Stanley, and United Community Bank.
Item 3 – Disciplinary Information
Mr. Klein has not been the subject of any legal or disciplinary event requiring disclosure under the
laws or regulations governing disclosure to investment advisory clients.
Item 4 – Other Business Activities
Mr. Klein has no outside business activities:
Item 5 – Additional Compensation
Mr. Klein does not receive any economic benefit from any person, company, or organization, other
than from Sparta Wealth Partners in exchange for providing clients advisory services.
Item 6 – Supervision
Mr. Klein reports directly to and is supervised by Blair Thompson. Mr. Thompson periodically
reviews all accounts serviced by Mr. Novak and regularly communicates with Mr. Novak regarding
the status of client accounts. Any client with questions or concerns regarding the supervision of Mr.
Novak is asked to contact Mr. Thompson directly at (704) 575-1148.
28
Brochure Supplement: Ori Boucvalt
Form ADV, Part 2B Brochure Supplement
Ori Boucvalt, Advisor
Born: 2003
Total Solutions Enterprise, LLC (d/b/a Sparta Wealth Partners)
4500 Cameron Valley Parkway
Suite 130
Charlotte, NC 28211
(704) 575-1148
July 07, 2025
This brochure supplement provides information about Ori Boucval that supplements the Sparta
Wealth Partners brochure. You should have received a copy of that brochure. Please contact Blair
Thompson at (704) 575-1148 if you did not receive the Sparta Wealth Partners brochure or if you
have questions or comments about this supplement. Additional information about Mr. Novak
also is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Education Background and Business Experience
Ms. Boucvalt joined Sparta Wealth Partners as an Advisor in July 2025. In 2025, she graduated with a
a master’s degree from Vanderbilt University and in 2024, graduated with a bachelor’s degree from
Clemson University.
Item 3 – Disciplinary Information
Ms. Boucvalt has not been the subject of any legal or disciplinary event requiring disclosure under the
laws or regulations governing disclosure to investment advisory clients.
Item 4 – Other Business Activities
Ms. Boucvalt has the following outside business activities:
• Environmental Safety and Health Consulting Not investment-related Address: 2516 Engineers
Road Belle Chasse, LA 70037 Emergency response/Environmental clean up Board Member Start
Date: 02/06/2017 1 hour a month devoted 0 hours devoted during security trading hours
Provide oversight, set strategic direction, vote on key decisions, and ensure the organization
fulfills its mission and operates responsibly
• Morgan Companies Investment-related 4521 Sharon Rd #275, Charlotte, NC 28211 Full-service
commercial real estate firm Consultant 07/01/25 80 hours devoted a month 3 hours devoted
during security trading hours Consulting on projects
Item 5 – Additional Compensation
Ms. Boucvalt does not receive any economic benefit from any person, company, or organization, other
29
than from Sparta Wealth Partners in exchange for providing clients advisory services.
Item 6 – Supervision
Ms. Boucvalt reports directly to and is supervised by Blair Thompson. Mr. Thompson periodically
reviews all accounts serviced by Mr. Novak and regularly communicates with Mr. Novak regarding
the status of client accounts. Any client with questions or concerns regarding the supervision of Mr.
Novak is asked to contact Mr. Thompson directly at (704) 575-1148.
30
Brochure Supplement: Kristopher Alexander Roper
Form ADV, Part 2B Brochure Supplement
Kristopher Alexander Roper, Advisor
Born: 1996
Total Solutions Enterprise, LLC (d/b/a Sparta Wealth Partners)
4500 Cameron Valley Parkway
Suite 130
Charlotte, NC 28211
(704) 575-1148
July 07, 2025
This brochure supplement provides information about Kristopher Alexander Roper that
supplements the Sparta Wealth Partners brochure. You should have received a copy of that
brochure. Please contact Blair Thompson at (704) 575-1148 if you did not receive the Sparta Wealth
Partners brochure or if you have questions or comments about this supplement. Additional
information about Mr. Novak also is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Education Background and Business Experience
Mr. Roper joined Sparta Wealth Partners as an Advisor in July 2025. Prior to joining Sparta Wealth
Partner, he was as an Associate Wealth Advisor with Coastal Bridge Advisors, as a client associate
with TrinityPoint Wealth. He graduated with a bachelor’s degree in Finance and master’s degree in
Business Administration from Winthrop University. He also is a Certified Financial Planner.
Item 3 – Disciplinary Information
Mr. Roper has not been the subject of any legal or disciplinary event requiring disclosure under the
laws or regulations governing disclosure to investment advisory clients.
Item 4 – Other Business Activities
Mr. Roper has the following outside business activities:
• Hickory Tavern - No - 12210 Copper Way Ste. 212, Charlotte, NC 28277 - Restaurant - Cook -
Part time cook - 07/14/2025 - 48 hours per month - 0 hours - Part-time cook at upscale casual
restaurant, two nights per week
Item 5 – Additional Compensation
Mr. Roper does not receive any economic benefit from any person, company, or organization, other
than from Sparta Wealth Partners in exchange for providing clients advisory services.
31
Item 6 – Supervision
Mr. Roper reports directly to and is supervised by Blair Thompson. Mr. Thompson periodically
reviews all accounts serviced by Mr. Novak and regularly communicates with Mr. Novak regarding
the status of client accounts. Any client with questions or concerns regarding the supervision of Mr.
Novak is asked to contact Mr. Thompson directly at (704) 575-1148.
32