Overview
- Headquarters
- Tysons, VA
- Total Firm Assets
- $267 million
- Average High-Net-Worth Client Portfolio Size
- $1.8 million
- Stated Minimum Account Size
- $750,000
Fee Disclosure
VARIANT PRIVATE WEALTH PART 2A BROCHURE, WRAP APPENDIX, PART 2B AND PRIVACY POLICY
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $250,000 | 1.50% |
| $250,001 | $750,000 | 1.25% |
| $750,001 | $1,250,000 | 1.00% |
| $1,250,001 | $1,750,000 | 0.90% |
| $1,750,001 | $2,500,000 | 0.80% |
| $2,500,001 | $4,000,000 | 0.70% |
| $4,000,001 | $6,000,000 | 0.60% |
| $6,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | $30,000,000 | 0.40% |
| $30,000,001 | $60,000,000 | 0.35% |
| $60,000,001 | and above | 0.30% |
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $42,000 | 0.84% |
| $10 million | $68,000 | 0.68% |
| $50 million | $218,000 | 0.44% |
| $100 million | $373,000 | 0.37% |
Clients
- High-Net-Worth Share of Firm Assets
- 91.33%
- Number of High-Net-Worth Clients
- 136
- Total Client Accounts
- 851
- Discretionary Accounts
- 846
- Non-Discretionary Accounts
- 5
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 288011
Primary Brochure: VARIANT PRIVATE WEALTH PART 2A BROCHURE, WRAP APPENDIX, PART 2B AND PRIVACY POLICY (2026-09-16)
View Document Text
Item 1:
Cover Sheet
ADV 2A FIRM BROCHURE
8350 Broad St., Suite 220
Tysons, VA 22102-5151
David Morgante
703-760-7600
September 2026
This brochure provides information about the qualifications and business practices of Variant Private
Wealth, LLC. If you have any questions about the contents of this brochure, please contact us at 703-
760-7600. The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority. Our registration does not
imply a certain level of skill or training.
Additional information about Variant Private Wealth, LLC (CRD# 288011) is also available on the
SEC’s website at www.adviserinfo.sec.gov.
Item 2:
Statement of Material Changes
Variant Private Wealth, LLC is required to disclose any material changes to Form ADV in Item 2 of this
brochure.
Since our firm’s last annual amendment on 03/31/2026 we have no material changes to disclose.
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Item 3:
Table of Contents
TABLE OF CONTENTS
Item 1: Cover Sheet .................................................................................................................................... 1
Item 2: Statement of Material Changes ...................................................................................................... 2
Item 3: Table of Contents ........................................................................................................................... 3
Item 4: Advisory Business ......................................................................................................................... 4
Item 5: Fees and Compensation ................................................................................................................. 5
Item 6: Performance-Based Fees ................................................................................................................ 6
Item 7: Types of Clients ............................................................................................................................. 6
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 7
Item 9: Disciplinary Information .............................................................................................................. 12
Item 10: Other Financial Industry Activities and Affiliations .................................................................... 12
Item 11: Code of Ethics, Participation or Interest in .................................................................................. 13
Item 12: Brokerage Practices ..................................................................................................................... 13
Item 13: Review of Accounts ..................................................................................................................... 15
Item 14: Client Referrals and Other Compensation ................................................................................... 15
Item 15: Custody ........................................................................................................................................ 15
Item 16: Investment Discretion .................................................................................................................. 16
Item 17: Voting Client Securities ............................................................................................................... 16
Item 18: Financial Information .................................................................................................................. 17
Item 1B: Wrap Fee Program Cover Sheet .................................................................................................. 18
Item 2B: Statement of Material Changes .................................................................................................... 19
Item 3B: Services, Fees, and Compensation .......................................................................................... 20
Item 4B: Account Requirement and Type of Clients ........................................................................... 22
Item 5B: Portfolio Manager Selection and Evaluation ........................................................................ 23
Item 6B: Client Information provided to Portfolio Managers ............................................................ 23
Item 7B: Client Contact with Portfolio Managers ................................................................................ 23
Item 8B: Additional Information ........................................................................................................... 23
David Morgante ADV 2B ......................................................................................................................... 27
George Clark ADV 2B ............................................................................................................................. 31
Tyler Harper ADV 2B .............................................................................................................................. 34
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Alexander Tagliareni ADV 2B ................................................................................................................ 37
PRIVACY NOTICE ................................................................................................................................. 39
INFORMATIONAL BROCHURE
VARIANT PRIVATE WEALTH LLC
Item 4:
Advisory Business
Variant Private Wealth, LLC (“VPW”) has been in business since June 2017. David Morgante is the
firm’s only principal owner.
VPW provides personalized financial planning and investment management services to individuals,
families, trusts, and charitable organizations and foundations, pensions, and corporations. We are
dedicated to providing in-depth analysis of each individual client’s current situation, allowing us to
assist clients in obtaining each goal or objective set forth.
Financial Planning
VPW provides fee-based comprehensive and goal-based financial planning services. A comprehensive
plan generally includes setting financial objectives, identifying financial issues, cash flow
management, tax planning, investment review and advice, education funding planning, retirement
planning, insurance needs review and advice and estate planning. A goal-based plan is designed to
meet specific goals throughout a certain time horizon, whether it be short-term or long-term.
In a typical financial planning engagement, VPW will have an initial free consultation with you in
which you will state your financial needs and goals. Next, you will be requested to provide documents
including personal information, income, expenses, taxable and retirement investments, insurance, tax
and other necessary information. Through a strategy session, VPW will analyze your situation, prepare
projections when necessary and recommend alternatives to help achieve your goals using information
provided by you. A recommendation will be provided in writing and from there the implementation
process can begin.
The plan is intended to be a suggested blueprint of how to meet your goals. Not every plan will be the
same for every client. Each one is specific to the client who requested it. Because the plan is based on
information supplied by you, it is very important that you accurately and completely communicate to
us the information we need. Also, your circumstances and needs may change as your engagement with
us progresses. It is very important that you continually update us with any changes so that if the updates
require changes to your plan, we can make those changes. Otherwise, your plan may no longer be
accurate. An engagement may be terminated at any time by either VPW or the client by notifying the
other party in writing. An engagement is terminated when the specified services are completed.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial consulting services to clients for the management
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of financial resources based upon an analysis of current situation, goals, and objectives. This
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Financial consultations rendered to clients usually include general recommendations for a course of
activity or specific actions to be taken by the clients. Implementation of the recommendations will be
at the discretion of the client. Financial consultations are not typically accompanied by a written
summary of observations and recommendations, as the process is less formal than the planning
services. Assuming that all the information and documents requested from the client are provided
promptly, consultations are typically completed within 6 months of the client signing a contract with
our firm.
Reporting
Some clients may have assets held with custodians other than our recommended custodian(s). In these
cases, such clients may elect to provide us with information related to these accounts and VPW will
include those assets in consolidated reporting in order to give the client a more organized view of their
total assets for no additional fee.
Wrap Program Participation
Our firm offers and sponsors a wrap fee program. Asset Management services are only offered through
wrapped accounts, which are managed on an individualized basis according to the client’s investment
objectives, financial goals, risk tolerance, etc. Please see our Part 2A, Appendix 1 (the “Wrap Fee
Program Brochure”) for more information.
Assets Under Management
As of December 31, 2025, VPW has approximately $267,478,020 assets under management with
$266,058,085 managed on a discretionary basis and $1,419,935 managed on a non-discretionary basis.
Item 5:
Fees and Compensation
Financial Planning
Financial Planning fees for initial planning work will vary, but are generally expected to be in the fixed
fee range of $750 to $10,000 per plan. However, these fees are guidelines, subject to change according
to the complexity of the plan and the specific client’s circumstances. At the discretion of VPW,
financial planning services may be done on an hourly basis with a rate of $350 per hour. For some
clients who are also engaging VPW to provide asset management services, the preparation of the
financial plan may be included with the costs of asset management services, based on the assets under
management.
Financial Consulting
Our firm provides Financial Consulting services on an hourly basis charged in arrears. The total fee
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charged will be based on the number of hours of consulting provided to clients at our hourly rate of
$350.
A.
Fee Payment
Financial Planning: Financial Planning fees will be due upon receipt of invoice from VPW. In many
cases, clients will be asked to put forth a retainer at the onset of the engagement, which may be for up
to 50% of the expected final cost.
B.
Other Fees
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual
fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement
plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees
for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage
accounts and securities transactions. Our firm does not receive a portion of these fees.
Wrap clients will not incur transaction costs for trades by their chosen custodian. More information
about this can be found in our separate Wrap Fee Program Brochure.
Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and
custodial issues.
C.
Pro-rata Fees
If you become a client in the middle of a month, you will pay a management fee for the number of
days left in that month. If you terminate our relationship in the middle of a month, you will be
responsible for the payment of management fees for the portion of the month during which you were
a client. Once your notice of termination is received, we will assess pro-rated fees for the number of
days between the end of the prior billing period and the date of termination to be paid in whatever way
you direct (check, wire).
D.
Compensation for the Sale of Securities.
This item is not applicable.
Item 6:
Performance-Based Fees
VPW will not charge performance-based fees.
Item 7:
Types of Clients
Clients advised may include individuals, families, trusts, and charitable organizations and foundations,
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pensions and corporations. VPW requires each client to place at least $750,000 with the firm. This
minimum may be waived at the discretion of VPW.
Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity
will not be charged transaction fees for U.S. listed equities and exchange traded funds.
Item 8:
Methods of Analysis, Investment Strategies and Risk of Loss
It is important for you to know and remember that all investments carry risks. Investing in securities
involves risk of loss that clients should be prepared to bear.
Each client’s portfolio will be invested according to that client’s investment objectives, which are
ascertained through the financial planning process. The goal with asset management is to take the
financial planning blueprint and drive it forward, towards the client’s goals. Once we ascertain your
objectives for each account, we will develop a set of asset allocation guidelines. An asset allocation
strategy is a percentage-based allocation to different investment types. For example, a client may have
an asset allocation strategy that calls for 40-60% of the portfolio to be invested in equity securities,
with 20% of that allocated to international equities and the remaining balance in fixed income. Another
client may have an asset allocation of 50-60% in fixed income securities and the remainder equities.
The percentages in each type that we recommend are based on the typical behavior of that security
type, individual securities we follow, current market conditions, your current financial situation, your
financial goals, and the timeline to get you to those goals. Because we develop an investment strategy
based on your personal situation and financial goals, your asset allocation guidelines may be similar
to or different from another client’s. We utilize technical analyses, which means that we will review
the past behaviors of the security and the markets in which it trades for signals as to what might happen
in the future. Using fundamental analysis, we base our conclusions on predominantly publicly
available research, such as regulatory filings, press releases, competitor analyses, and in some cases
research we receive from our custodian or other market analyses.
It is important to remember that because market conditions can vary greatly, your asset allocation
guidelines are not necessarily strict rules. Rather, we review accounts individually, and may deviate
from the guidelines as we believe necessary.
Preferred Securities and Recommended Investments
• BDCs (Business Development Companies): Business Development Companies (BDCs) are a
specific subset of investment companies that receive preferential tax treatment provided they meet
certain investment restrictions and other regulatory requirements. Because BDCs are managed by
third parties, and are frequently chosen for the perceived strength of their managers, the investment
thesis, and tax treatment, the risks associated with a BDC investment generally follow directly from
the manager, in that the manager ultimately controls the investments, and can adversely impact the tax
treatment of the vehicle. Additional risks exist, and may be specific to the particular BDC.
Accordingly, investors should carefully review the BDC’s prospectus and any addendums thereto.
• Equity Securities. Equity securities represent an ownership position in a company. Equity
securities typically consist of common stocks. The prices of equity securities fluctuate based on, among
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other things, events specific to their issuers and market, economic and other conditions. For example,
prices of these securities can be affected by financial contracts held by the issuer or third parties (such
as derivatives) relating to the security or other assets or indices. There may be little trading in the
secondary market for particular equity securities, which may adversely affect our firm 's ability to
value accurately or dispose of such equity securities. Adverse publicity and investor perceptions,
whether or not based on fundamental analysis, may decrease the value and/or liquidity of equity
securities. Investing in smaller companies may pose additional risks as it is often more difficult to
value or dispose of small company stocks, more difficult to obtain information about smaller
companies, and the prices of their stocks may be more volatile than stocks of larger, more established
companies. Clients should have a long-term perspective and, for example, be able to tolerate
potentially sharp declines in value.
• Leveraged ETFs. An Exchange Traded Fund is a group of securities that trade intra-day and are
not managed actively, as a mutual fund would be. For example, there are ETFs that invest strictly in
the S&P 500, which means their performance should track the performance of that index over time. A
leveraged ETF is one that utilizes leverage when investing into the underlying securities. For example
a 3x levered ETF that tracks the S&P 500 would make $3.00 of investment for every $1.00 it received
from investors. This means that whatever volatility the underlying index has will be multiplied due to
the leverage.
• MLPs. VPW may recommend that portions of client portfolios be allocated to master limited
partnerships, otherwise known as “MLPs”. An MLP is a publicly traded entity that is designed to
provide tax benefits for the investor. In order to preserve these benefits, the MLP must derive most,
if not all, of its income from real estate, natural resources and commodities. While MLPs may add
diversification and tax favored treatment to a client’s portfolio, they also carry significant risks beyond
more traditional investments such as stocks, bonds and mutual funds. One such risk is management
risk-the success of the MLP is dependent upon the manager’s experience and judgment in selecting
investments for the MLP. Another risk is the governance structure, which means the rules under which
the entity is run. The investors are the limited partners of the MLP, with an affiliate of the manager
typically the general partner. This means the manager has all of the control in running the entity, as
opposed to an equity investment where shareholders vote on such matters as board composition. There
is also a significant amount of risk with the underlying real estate, resources or commodities
investments. Clients should ask VPW any questions regarding the role of MLPs in their portfolio.
• Mutual Funds. A mutual fund is a company that pools money from many investors and invests
that money in a variety of differing security types based on the objectives of the fund. The portfolio of
the fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors pay
for mutual fund shares are the fund’s per share net asset value (“NAV”) plus any shareholder fees that
the fund imposes at the time of purchase (such as sales loads). Investors typically cannot ascertain the
exact make-up of a fund’s portfolio at any given time, nor can they directly influence which securities
the fund manager buys and sells or the timing of those trades. With an individual stock, investors can
obtain real-time (or close to real-time) pricing information with relative ease by checking financial
websites or by calling a broker or your investment adviser. Investors can also monitor how a stock’s
price changes from hour to hour—or even second to second. By contrast, with a mutual fund, the price
at which an investor purchases or redeems shares will typically depend on the fund’s NAV, which is
calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
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investments across a wide range of companies and industry sectors can help lower the risk if a company
or sector fails. Some investors find it easier to achieve diversification through ownership of mutual
funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending on
the timing of their investment, investors may also have to pay taxes on any capital gains distributions
they receive. This includes instances where the fund performed poorly after purchasing shares.; (b)
Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor can
they directly influence which securities the fund manager buys and sells or the timing of those trades.;
and (c) With an individual stock, investors can obtain real-time (or close to real-time) pricing
information with relative ease by checking financial websites or by calling a broker or your investment
adviser. Investors can also monitor how a stock’s price changes from hour to hour—or even second to
second. By contrast, with a mutual fund, the price at which an investor purchases or redeems shares
will typically depend on the fund’s NAV, which the fund might not calculate until many hours after
the investor placed the order. In general, mutual funds must calculate their NAV at least once every
business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any capital
gains tax until the investor actually sells and makes a profit. Mutual funds, however, are different.
When an investor buys and holds mutual fund shares, the investor will owe income tax on any ordinary
dividends in the year the investor receives or reinvests them. Moreover, in addition to owing taxes on
any personal capital gains when the investor sells shares, the investor may have to pay taxes each year
on the fund’s capital gains. That is because the law requires mutual funds to distribute capital gains to
shareholders if they sell securities for a profit, and cannot use losses to offset these gains.
• REITs: In limited circumstances, VPW may recommend that portions of client portfolios be
allocated to real estate investment trusts, otherwise known as “REITs”. A REIT is an entity, typically
a trust or corporation, that accepts investments from a number of investors, pools the money, and then
uses that money to invest in real estate through either actual property purchases or mortgage loans.
While there are some benefits to owning REITs, which include potential tax benefits, income and the
relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also
have some increased risks as compared to more traditional investments such as stocks, bonds, and
mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen
may have a focus such as commercial real estate or real estate in a given location. Such investment
focus can be beneficial if the properties are successful, but lose significant principal if the properties
are not successful. REITs may also employ significant leverage for the purpose of purchasing more
investments with fewer investment dollars, which can enhance returns but also enhances the risk of
loss. The success of a REIT is highly dependent upon the manager of the REIT. Clients should ensure
they understand the role of the REIT in their portfolio.
• Structured Notes. A structured note is a form of negotiable debt obligation. The investor
purchases the structured note, the value and risk of which is tied to one or more underlying investments
or investment types. For example, a bank may package a structured note comprised of exposure to
one or more indices or commodities. Structured notes can be put together in almost any combination.
The risks of structured notes include the fact that they are obligations tied to underling investments, so
the risk of one investment can mitigate risks of others or enhance it. Structured notes can therefore be
9
used to hedge volatility or to enhance it depending upon the goal. Structured notes can also add risk
by including the concept of inherent leverage. This means that while the investor did not use margin
to purchase the structured note, the note itself includes leverage, making the note itself subject to
greater potential volatility. Structured notes may also not be as liquid as other investments, and
because they are a debt obligation, they are subject to the creditworthiness of the issuer.
Risk of Loss
There are always risks to investing. Clients should be aware that all investments carry various
types of risk including the potential loss of principal that clients should be prepared to bear. It is
impossible to name all possible types of risks. Among the risks are the following:
• Political Risks. Most investments have a global component, even domestic stocks. Political
events anywhere in the world may have unforeseen consequences to markets around the world.
• Cash & Cash Equivalent Risk: Cash and cash equivalents generally refer to either United States
dollars or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank
CD’s and commercial papers. Generally, these assets are considered nonproductive and will be
exposed to inflation risk and considerable opportunity cost risk. Investments in cash and cash
equivalents will generally return less than the advisory fee charged by our firm.
• General Market Risks. Markets can, as a whole, go up or down on various news releases or for
no understandable reason at all. This sometimes means that the price of specific securities could go
up or down without real reason, and may take some time to recover any lost value. Adding additional
securities does not help to minimize this risk since all securities may be affected by market fluctuations.
• Currency Risk. When investing in another country using another currency, the changes in the
value of the currency can change the value of your security value in your portfolio.
•
International Investing: Investing outside of the United States, especially in emerging
markets, can have special or enhanced risks. The most obvious are political risk (changes in local
politics can have a vast impact on the markets in that country as well as regulations affecting given
issuers) and currency risk (changes in exchange rates between the dollar and the local denominations
can materially affect the value of the security even if the underlying fundamentals and market price
are stagnant). There are other risks, including enhanced liquidity risk, meaning that while domestic
equities and mutual funds are generally easily liquidated (though there may be a risk of loss due to the
timing of the sale), equities in other jurisdictions may be subject to the circumstances of lower overall
market volume and fewer companies on an emerging exchange. In addition, there may be less
information and less transparency in a foreign market or from a foreign company. Foreign markets
impose different rules than domestic markets, which may not be to an investor's advantage. Also,
companies in foreign jurisdictions are generally able to avail themselves of local laws and venues,
meaning that legal remedies for U.S. investors may not be as easily obtained as in the U.S.
• Regulatory Risk. Changes in laws and regulations from any government can change the value
of a given company and its accompanying securities. Certain industries are more susceptible to
government regulation. Changes in zoning, tax structure or laws impact the return on these
investments.
• Tax Risks Related to Short Term Trading: Clients should note that VPW may engage in short-
term trading transactions. These transactions may result in short term gains or losses for federal and
state tax purposes, which may be taxed at a higher rate than long term strategies. VPW endeavors to
invest client assets in a tax efficient manner, but all clients are advised to consult with their tax
professionals regarding the transactions in client accounts.
• Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will
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decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its
relative value does, which is the same thing. Inflation can happen for a variety of complex reasons,
including a growing economy and a rising money supply.
• Business Risk. This can be thought of as certainty or uncertainty of income. Management comes
under business risk. Cyclical companies (like automobile companies) have more business risk because
of the less steady income stream. On the other hand, fast food chains tend to have steadier income
streams and therefore, less business risk.
• Financial Risk. The amount of debt or leverage determines the financial risk of a company.
• Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided
by several rating services help to identify those companies with more risk. Obligations of the U.S.
government are said to be free of default risk.
• Margin Risk. “Margin” is a tool used to maximize returns on a given investment by using
securities in a client account as collateral for a loan from the custodian to the client. The proceeds of
that loan are then used to buy more securities. Margin carries a higher degree of risk than investing
without margin.
• Risks specific to private placements, sub-advisors and other managers. If we invest some of
your assets with another advisor, including a private placement, there are additional risks. These
include risks that the other manager is not as qualified as we believe them to be, that the investments
they use are not as liquid as we would normally use in your portfolio, or that their risk management
guidelines are more liberal than we would normally employ.
•
Information Risk. All investment professionals rely on research in order to make conclusions
about investment options. This research is always a mix of both internal (proprietary) and external
(provided by third parties) data and analyses. Even an adviser who says they rely solely on proprietary
research must still collect data from third parties. This data, or outside research is chosen for its
perceived reliability, but there is no guarantee that the data or research will be completely accurate.
Failure in data accuracy or research will translate to a compromised ability by the adviser to reach
satisfactory investment conclusions.
• Small Companies. Some investment opportunities in the marketplace involve smaller issuers.
These companies may be starting up, or are historically small. While these companies sometimes have
potential for outsized returns, they also have the potential for losses because the reasons the company
is small are also risks to the company’s future. For example, a company’s management may lack
experience, or the company’s capital for growth may be restricted. These small companies also tend
to trade less frequently that larger companies, which can add to the risks associated with their securities
because the ability to sell them at an appropriate price may be limited as compared to the markets as a
whole. Not only do these companies have investment risk, if a client is invested in such small
companies and requests immediate or short term liquidity, these securities may require a significant
discount to value in order to be sold in a shorter time frame.
• Concentration Risk. While VPW selects individual securities, including mutual funds, for client
portfolios based on an individualized assessment of each security, this evaluation comes without an
overlay of general economic or sector specific issue analysis. This means that a client’s equity
portfolio may be concentrated in a specific sector, geography, or sub-sector (among other types of
potential concentrations), so that if an unexpected event occurs that affects that specific sector or
geography, for example, the client’s equity portfolio may be affected negatively, including significant
losses.
• Transition risk. As assets are transitioned from a client’s prior advisers to VPW there may be
securities and other investments that do not fit within the asset allocation strategy selected for the
client. Accordingly, these investments will need to be sold in order to reposition the portfolio into the
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asset allocation strategy selected by VPW. However, this transition process may take some time to
accomplish. Some investments may not be unwound for a lengthy period of time for a variety of
reasons that may include unwarranted low share prices, restrictions on trading, contractual restrictions
on liquidity, or market-related liquidity concerns. In some cases, there may be securities or
investments that are never able to be sold. The inability to transition a client's holdings into
recommendations of VPW may adversely affect the client's account values, as VPW’s
recommendations may not be able to be fully implemented.
• Restriction Risk. Clients may at all times place reasonable restrictions on the management of
their accounts. However, placing these restrictions may make managing the accounts more difficult,
thus lowering the potential for returns.
• Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in
value. All securities will have periods of time when the current price of the security is not an accurate
measure of its value. If you require us to liquidate your portfolio during one of these periods, you will
not realize as much value as you would have had the investment had the opportunity to regain its value.
Further, some investments are made with the intention of the investment appreciating over an extended
period of time. Liquidating these investments prior to their intended time horizon may result in losses.
Item 9:
Disciplinary Information
There are no disciplinary items to report.
Item 10:
Other Financial Industry Activities and Affiliations
Representatives of our firm are insurance agents/brokers. They offer insurance products and receive
customary fees as a result of insurance sales. A conflict of interest exists as these insurance sales create
an incentive to recommend products based on the compensation adviser and/or our supervised persons
may earn. To mitigate this potential conflict, our firm will act in the client’s best interest.
David Morgante also owns Variant Insurance, LLC an insurance brokerage firm. Clients may be
solicited to use the services of this firm and our representatives will receive commissions as a result of
these transactions. A conflict of interest exists as these commissionable securities sales create an
incentive to recommend products based on the compensation earned. To mitigate this potential
conflict, our firm will act in the client’s best interest.
Clients are under no obligation to purchase recommended insurance products through investment
adviser representatives of Variant Private Wealth, LLC, who are also insurance agents, or through
Variant Insurance, LLC.
David Morgante is also the owner of Variant Tax Services, LLC. As such, Mr. Morgante will provide
income tax preparation and accounting services. These services are independent of our financial
planning and investment advisory services and are governed under a separate engagement agreement.
Clients are not required to utilize services from Variant Tax Services, LLC.
12
Item 11:
Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
A.
A copy of our Code of Ethics is available upon request. Our Code of Ethics includes
discussions of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading
guidelines.
Not applicable. VPW does not recommend to clients that they invest in any security in which
B.
VPW or any principal thereof has any financial interest.
C.
On occasion, an employee of VPW may purchase for his or her own account securities which
are also recommended for clients. Our Code of Ethics details rules for employees regarding personal
trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a
trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee
trades are reviewed by the Compliance Officer. All employee trades must either take place in the same
block as a client trade or sufficiently apart in time from the client trade so the employee receives no
added benefit. Employee statements are reviewed to confirm compliance with the trading procedures.
D.
On occasion, an employee of VPW may purchase for his or her own account securities which
are also recommended for clients at the same time the clients purchase the securities. Our Code of
Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related
to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or
after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All
employee trades must either take place in the same block as a client trade or sufficiently apart in time
from the client trade so the employee receives no added benefit. Employee statements are reviewed to
confirm compliance with the trading procedures.
Item 12:
Brokerage Practices
A.
Recommendation of Broker-Dealer
Our firm has an arrangement with National Financial Services LLC and Fidelity Brokerage Services
LLC (collectively, and together with all affiliates, "Fidelity") through which Fidelity provides our firm
with "institutional platform services." Our firm is independently operated and owned and is not
affiliated with Fidelity. The institutional platform services include, among others, brokerage, custody,
and other related services. Fidelity's institutional platform services that assist us in managing and
administering clients' accounts include software and other technology that (i) provide access to client
account data (such as trade confirmations and account statements); (ii) facilitate trade execution and
allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other
13
market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office
functions, recordkeeping and client reporting.
VPW recommends Fidelity to its clients based on a variety of factors. These include, but are not limited
to, commission costs. Fidelity has what can be considered discounted commission rates. However, in
choosing a broker-dealer or custodian to recommend, we are most concerned with the value the client
receives for the cost paid, not just the cost. Fidelity adds value beyond commission cost. Other factors
that may be considered in determining overall value include speed and accuracy of execution, financial
strength, knowledge and experience of staff, research and service. Fidelity also has arrangements with
many mutual funds that enable them to purchase these mutual funds for client accounts at reduced
transaction charges (as opposed to other broker-dealers). VPW re-evaluates the use of Fidelity at least
annually to determine if they are still the best value for our clients.
Fidelity provides VPW with some non-cash benefits (not available to retail customers) in return for
placing client assets with them or executing trades through them. Currently, these benefits come in the
form of investment research and sponsored attendance at various investment seminars. We may also
receive such items as investment software, books and research reports. These products, services, or
educational seminars are items that will play a role in determining how to invest client accounts. If
there is any item that has a multi-use aspect, mixed between investment and non-investment purposes,
VPW will determine a reasonable allocation of investment to non-investment use and non-cash
benefits will be allocated only to the investment portion of the product (and we will pay the remaining
cost). VPW does receives a benefit from these services, as otherwise would be compiling the same
research on their own. This may cause a conflict of interest as VPW may want to place more client
accounts with a broker-dealer/custodian such as Fidelity, solely because of these added benefits. As
such, VPW may have an incentive to select or recommend a broker-dealer based on interests in
receiving the research or other products or services, rather than on clients’ interest in receiving most
favorable execution. VPW attempts to mitigate this potential conflict by performing regular reviews
of execution services and value clients receive to ensure clients are receiving the best possible value
for costs paid. However, the value to all of our clients of these benefits is included in our evaluation
of custodians. Products and services received will generally be used for the benefit of all clients.
However, it is possible that a given client’s trades will generate non-cash benefits that acquire products
and/or services that are not ultimately utilized for that same client’s account. Non-cash benefits provide
additional value, and are accordingly considered in determining which broker-dealer or custodian to
utilize as part of our best execution analysis.
We do not consider whether Fidelity or any other broker-dealer/custodian, refers clients to VPW as
part of our evaluation of these broker-dealers.
B.
Aggregating Trades
Commission costs per client may be lower on a particular trade if all clients in whose accounts the
trade is to be made are executed at the same time. This is called aggregating trades. Instead of placing
14
a number of trades for the same security for each account, we will, when appropriate, executed one
trade for all accounts and then allocate the trades to each account after execution. If an aggregate trade
is not fully executed, the securities will be allocated to client accounts on a pro rata basis, except
where doing so would create an unintended adverse consequence (For example, ¼ of a share, or a
position in the account of less than 1%.)
Directed Brokerage
VPW does not typically allow clients to direct brokerage. “Directing” brokerage means choosing to
maintain all or some of their assets with a broker-dealer that is not recommended by VPW. VPW may
be unable to achieve most favorable execution of client transactions if clients choose to direct
brokerage. This may cost clients’ money because without the ability to direct brokerage VPW may not
be able to aggregate orders to reduce transactions costs resulting in higher brokerage commissions and
less favorable prices. Not all investment advisers allow their clients to direct brokerage.
Item 13:
Review of Accounts
All accounts and corresponding financial plans will be managed on an ongoing basis, with formal
reviews with the client by a member of senior management on at least an annual basis. However, it is
expected that market conditions, changes in a particular client’s account, or changes to a client’s
circumstances will trigger a review of accounts.
Item 14:
Client Referrals and Other Compensation
A. Economic Benefit Provided by Third Parties for Advice Rendered to Client.
Please refer to Item 12, where we discuss recommendation of Broker-Dealers.
B. Compensation to Non-Advisory Personnel for Client Referrals.
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15:
Custody
While our firm does not maintain physical custody of client assets (which are maintained by a qualified
custodian, as discussed above), we are deemed to have custody of certain client assets if given the
authority to withdraw assets from client accounts, as further described below under “Standing
Instructions.” All our clients receive account statements directly from their qualified custodian(s) at
15
least quarterly upon opening of an account. We urge our clients to carefully review these statements.
Additionally, if our firm decides to send its own account statements to clients, such statements will
include a legend that recommends the client compare the account statements received from the
qualified custodian with those received from our firm. Clients are encouraged to raise any questions
with us about the custody, safety or security of their assets and our custodial recommendations.
The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under
the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody
Rule as well as clarified that an adviser who has the power to disburse client funds to a third party
under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has
adopted the following safeguarding procedures in conjunction with our custodian, Fidelity:
• Fidelity’s forms, used to establish a standing letter of authorization, include the name and account
number on the receiving account and must be signed by the client.
• Fidelity’s SLOA forms currently require client’s signature.
• Fidelity performs verification on all SLOA forms and sends a transfer of notice to the client
promptly following the transaction.
• Clients always have the ability to terminate (or amend) an SLOA in writing.
• Our firm has no authority, or ability, to amend the third party designated on a standing instruction.
• Our firm maintains records showing the third party is not a related party of our firm or located at
our firm.
Fidelity notifies the client in writing when a new standing instruction is set up. Clients also receive an
annual mailing reconfirming the existence of the standing instruction.
Item 16:
Investment Discretion
When VPW is engaged to provide asset management services on a discretionary basis, we will monitor
your accounts to ensure that they are meeting your asset allocation requirements. If any changes are
needed to your investments, we will make the changes. These changes may involve selling a security
or group of investments and buying others or keeping the proceeds in cash. You may at any time place
restrictions on the types of investments we may use on your behalf, or on the allocations to each
security type. You may receive at your request written or electronic confirmations from your account
custodian after any changes are made to your account. You will also receive monthly statements from
your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited
Power of Attorney (granting us the discretionary authority over the client accounts) as well as an
Investment Management Agreement that outlines the responsibilities of both the client and VPW.
Item 17:
Voting Client Securities
Copies of our Proxy Voting Policies are available upon request.
16
From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may
be permitted to vote on various types of corporate actions. Examples of these actions include mergers,
tender offers, or board elections. Clients are required to vote proxies related to their investments, or to
choose not to vote their proxies. VPW will not accept authority to vote client securities. Clients will
receive their proxies directly from the custodian for the client account. VPW will not give clients
advice on how to vote proxies.
Item 18:
Financial Information
VPW does not require the prepayment of fees more than six (6) months or more in advance and
therefore has not provided a balance sheet with this brochure.
As an advisory firm that maintains discretionary authority for client accounts, Variant Private Wealth,
LLC is required to disclose any financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients. At this time, VPW does not reasonably believe that any financial
conditions will likely impair our ability to meet any of its’ contractual commitments.
17
Item 1B:
Wrap Fee Program Cover Sheet
INFORMATIONAL BROCHURE
WRAP FEE PROGRAM
VARIANT PRIVATE WEALTH LLC
8350 Broad St., Suite 220
Tysons, VA 22102-5151
David Morgante
703-760-7600
September 2026
This brochure provides information about the qualifications and business practices of Variant Private
Wealth, LLC. If you have any questions about the contents of this brochure, please contact us at 703-
760-7600. The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority. Our registration does not
imply a certain level of skill or training.
Additional information about Variant Private Wealth, LLC (CRD# 288011) is also available on the
SEC’s website at www.adviserinfo.sec.gov.
18
Item 2B:
Statement of Material Changes
Since our firm’s last annual amendment on 03/31/2026 we have no material changes to disclose.
19
Item 3B: Services, Fees, and Compensation
Our firm manages assets for many different types of clients to help meet their financial goals while
remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in
the client’s best interest. This is accomplished in part by knowing the client. Our firm has established
a service-oriented advisory practice with open lines of communication. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind of
working relationship we value.
Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for
investment advisory services and associated custodial transaction costs. Transaction fees will be paid
by our firm via individual transaction charges. Because our firm absorbs client transaction fees, an
incentive exists to limit trading activities in client accounts.
Fidelity Brokerage Services (“Fidelity”) eliminated transaction fees for U.S. listed equities and
exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1
million in assets at Fidelity. This presents a conflict of interest because we are incentivized to
recommend U.S. listed equities and exchange traded funds over other types of securities in order to
reduce our costs for qualifying clients.
Our Wrap advisory Services
Wrap Asset Management:
As part of our Wrap Asset Management service, a portfolio is created, consisting of individual stocks,
bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities
or investments. The client’s individual investment strategy is tailored to their specific needs and may
include some or all of the previously mentioned securities. Portfolios will be designed to meet a
particular investment goal, determined to be suitable to the client’s circumstances. Once the
appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if
necessary, rebalanced based upon the client’s individual needs, stated goals and objectives.
Fee Schedule
Assets Under Management
$0 - $249,999
$250,000 - $749,999
$750,000 - $1,249,999
$1,250,000 - $1,749,999
$1,750,000 - $2,499,999
$2,500,000 - $3,999,999
$4,000,000 - $5,999,999
$6,000,000 - $9,999,999
$10,000,000 - $29,999,999
$30,000,000 - $59,999,999
Annual Rate
1.50%
1.25%
1.00%
.90%
.80%
.70%
.60%
.50%
.40%
.35%
20
$60,000,000 and above
.30%
Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized
fees are billed on a pro-rata basis monthly in arrears based on the value of the account(s) on the last
day of the month. Fees are negotiable and will be deducted from client account(s). Adjustments will
be made for deposits and withdrawals during the quarter. Further, it is important to note that our firm
assesses advisory fees on cash and cash equivalents. As part of this process, Clients understand the
following:
(a) The client’s independent custodian sends statements at least quarterly showing the market values
for each security included in the Assets and all account disbursements, including the amount of
the advisory fees paid to our firm;
(b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm
will send an invoice directly to the custodian; and
(c) If our firm sends a copy of our invoice to the client, legend urging the comparison of information
provided in our statement with those from the qualified custodian will be included.
Comprehensive Wrap Asset Management:
As part of our Comprehensive Portfolio Management service clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients in
meeting their financial goals through the use of a financial plan or consultation. Our firm conducts
client meetings to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what is learned, an investment approach is presented to the client,
consisting of individual stocks, bonds, ETFs, options, fee based variable annuities, mutual funds and
other public and private securities or investments. Once the appropriate portfolio has been determined,
portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the
client’s individual needs, stated goals and objectives. Upon client request, our firm provides a
summary of observations and recommendations for the planning or consulting aspects of this service.
Fee Schedule
Assets Under Management
$0 - $249,999
$250,000 - $749,999
$750,000 - $1,249,999
$1,250,000 - $1,749,999
$1,750,000 - $2,499,999
$2,500,000 - $3,999,999
$4,000,000 - $5,999,999
$6,000,000 - $9,999,999
$10,000,000 - $29,999,999
$30,000,000 - $59,999,999
$60,000,000 and above
Annual Rate
2.00%
1.50%
1.25%
1.15%
1.00%
0.90 %
0.75%
0.60%
0.50%
0.45%
0.40%
21
Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized
fees are billed on a pro-rata basis monthly in arrears based on the value of the account(s) on the last
day of the month. Fees are negotiable and will be deducted from client account(s). Adjustments will
be made for deposits and withdrawals during the quarter. Further, it is important to note that our firm
assesses advisory fees on cash and cash equivalents. As part of this process, Clients understand the
following:
(d) The client’s independent custodian sends statements at least quarterly showing the market values
for each security included in the Assets and all account disbursements, including the amount of
the advisory fees paid to our firm;
(e) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm
will send an invoice directly to the custodian; and
(f) If our firm sends a copy of our invoice to the client, legend urging the comparison of information
provided in our statement with those from the qualified custodian will be included.
Other Fees:
In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen
custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange
traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or
deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees,
IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads
paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees
and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of
these fees.
Please make sure to read Item 12 of the ADV 2A Firm Brochure, where we discuss broker-dealer and
custodial issues.
Pro-rata Fees:
If you become a client in the middle of a month, you will pay a management fee for the number of
days left in that month. If you terminate our relationship in the middle of a month, you will be
responsible for the payment of management fees for the portion of the month during which you were
a client. Once your notice of termination is received, we will assess pro-rated fees for the number of
days between the end of the prior billing period and the date of termination to be paid in whatever way
you direct (check, wire).
Item 4B: Account Requirement and Type of Clients
Clients advised may include individuals, families, trusts, and charitable organizations and foundations,
pensions and corporations. VPW requires each client to place at least $750,000 with the firm. This
minimum may be waived at the discretion of VPW.
22
Item 5B: Portfolio Manager Selection and Evaluation
The wrap fee program offered by VPW is sponsored by the firm, and VPW is the only portfolio
manager. The only fees covered under the wrap fee program are transaction fees associated with the
purchase and sale of securities in an account managed by VPW. All client accounts managed by VPW,
including wrap fee program clients, are managed with similar processes, although account
recommendations may differ.
Item 6B: Client Information provided to Portfolio Managers
Please see response to Item 6, above
Item 7B: Client Contact with Portfolio Managers
Clients may contact VPW, the only portfolio manager, at any time.
Item 8B: Additional Information
Disciplinary Information
Neither the firm not any of its employees or principals has any disciplinary information to report.
Other Financial Industry Activities and Affiliations
Broker-dealer
This item is not applicable.
Futures Commission Merchant/Commodity Trading Advisor
Neither members of management, nor any related persons are registered, or have an application
pending to register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or an associated person of the foregoing entities.
Relationship with Related Persons
Certain professionals of VPW are separately licensed as independent insurance agents. As such, these
professionals may conduct insurance product transactions for VPW clients, in their capacity as licensed
insurance agents, and will receive customary commissions for these transactions in addition to any
compensation received in his capacity as employees of VPW. Commissions from the sale of insurance
products will not be used to offset or as a credit against advisory fees. These professionals therefore
have incentive to recommend insurance products based on the compensation to be received, rather
than on a client’s needs. The receipt of additional fees for insurance commissions is therefore a conflict
of interest, and clients should be aware of this conflict when considering whether to engage VPW or
23
utilize these professionals to implement any insurance recommendations. VPW attempts to mitigate
this conflict of interest by disclosing the conflict to clients, and informing the clients that they are
always free to purchase insurance products through other agents that are not affiliated with VPW, or
to determine not to purchase the insurance product at all. VPW also attempts to mitigate the conflict
of interest by requiring employees to acknowledge in the firm’s Code of Ethics, their individual
fiduciary duty to the clients of VPW, which requires that employees put the interests of clients ahead
of their own.
David Morgante also owns Variant Insurance, LLC an insurance brokerage firm. Clients may be
solicited to use the services of this firm and our representatives will receive commissions as a result of
these transactions. A conflict of interest exists as these commissionable securities sales create an
incentive to recommend products based on the compensation earned. To mitigate this potential conflict,
our firm will act in the client’s best interest.
Clients are under no obligation to purchase recommended insurance products through investment
adviser representatives of Variant Private Wealth, LLC, who are also insurance agents, or through
Variant Insurance, LLC.
David Morgante is also the owner of Variant Tax Services, LLC. As such, Mr. Morgante will provide
income tax preparation and accounting services. These services are independent of our financial
planning and investment advisory services and are governed under a separate engagement agreement.
Clients are not required to utilize services from Variant Tax Services, LLC.
Recommendations of other Advisers
VPW does not utilize nor select other advisers or third party managers. All assets are managed by
VPW management.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A.
A copy of our Code of Ethics is available upon request. Our Code of Ethics includes
discussions of our fiduciary duty to clients, political contributions, gifts, entertainment, and
trading guidelines.
B.
Not applicable. VPW does not recommend to clients that they invest in any security in which
VPW or any principal thereof has any financial interest.
C.
On occasion, an employee of VPW may purchase for his or her own account securities which
are also recommended for clients. Our Code of Ethics details rules for employees regarding
personal trading and avoiding conflicts of interest related to trading in one’s own account. To
avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of
a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must
either take place in the same block as a client trade or sufficiently apart in time from the client
trade so the employee receives no added benefit. Employee statements are reviewed to confirm
compliance with the trading procedures.
D.
On occasion, an employee of VPW may purchase for his or her own account securities which
24
are also recommended for clients at the same time the clients purchase the securities. Our Code
of Ethics details rules for employees regarding personal trading and avoiding conflicts of
interest related to trading in one’s own account. To avoid placing a trade before a client (in the
case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by
the Compliance Officer. All employee trades must either take place in the same block as a
client trade or sufficiently apart in time from the client trade so the employee receives no added
benefit. Employee statements are reviewed to confirm compliance with the trading procedures.
Review of Accounts
All accounts will be reviewed by a senior professional on at least an annual basis. However,
it is expected that market conditions, changes in a particular client’s account, or changes to a
client’s circumstances will trigger a review of accounts.
The annual report in writing provided by VPW is intended to review asset allocation. All
clients will receive statements and confirmations of trades directly from Fidelity. Please refer
to Item 15 of the Information Brochure regarding Custody.
Client Referrals and Other Compensation
Fidelity provides us with some non-cash benefits (not available to retail customers) in return
for placing client assets with them or executing trades through them. Such non-cash benefits
are referred to as “soft dollars”. Currently, these benefits come in the form of investment
research and sponsored attendance at various investment seminars. We may also receive such
items as investment software, books and research reports. These products, services, or
educational seminars are items that will play a role in determining how to invest client
accounts. If there is any item that has a multi-use aspect, mixed between investment and non-
investment purposes, VPW will determine a reasonable allocation of investment to non-
investment use and soft dollars will be allocated only to the investment portion of the product
(and we will pay the remaining cost). VPW receives a benefit from these services, as otherwise
we would be compiling the same research ourselves. This may cause a conflict of interest as
we may to want to place more client accounts with a broker-dealer/custodian such as Fidelity,
solely because of these added benefits. As such, VPW may have an incentive to select or
recommend a broker-dealer based on interests in receiving the research or other products or
services, rather than on clients’ interest in receiving most favorable execution. VPW attempts
to mitigate this potential conflict by performing regular reviews of execution services and
value clients receive to ensure clients are receiving the best possible value for costs paid.
However, the value to all of our clients of these benefits is included in our evaluation of
custodians. Products and services received via soft dollars will generally be used for the benefit
of all clients. However, it is possible that a given client’s trades will generate soft dollars that
acquire products and/or services that are not ultimately utilized for that same client’s account.
Soft dollars provide additional value, and are accordingly considered in determining which
broker-dealer or custodian to utilize as part of our best execution analysis.
25
Financial Information
VPW does not require the prepayment of fees more than six (6) months or more in advance
and therefore has not provided a balance sheet with this brochure.
As an advisory firm that maintains discretionary authority for client accounts, Variant Private Wealth,
LLC is required to disclose any financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients. At this time, VPW does not reasonably believe that any financial
conditions will likely impair our ability to meet any of its’ contractual commitments.
26
Item 1: Cover Sheet
ADV Part 2B: David Morgante
FORM ADV PART 2B
BROCHURE SUPPLEMENT
David Morgante ADV 2B
VARIANT PRIVATE WEALTH LLC
8350 Broad St., Suite 220
Tysons, VA 22102-5151
703-760-7600
September 2026
This Brochure Supplement provides information about David Morgante that supplements the Variant
Private Wealth, LLC Brochure. You should have received a copy of that Brochure. Please contact us at
703-760-7600 if you have any questions about the contents of this supplement. Registration does not
imply any certain level of skill or training.
information about David Morgante
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
27
Item 2:
Educational Background and Business Experience
David Morgante
Born: 1978
EDUCATION:
SUNY Brockport, 1999
Strayer University, 2020
BUSINESS EXPERIENCE:
Variant Private Wealth LLC
Managing Member, 06/2017 – Present
Ameriprise Financial Services, Inc.
Financial Advisor, 08/2004 – 06/2017
08/2000 – 04/2001
MML Investor Services
Financial Advisor, 11/2001 – 12/2002
PROFESSIONAL DESIGNATIONS / LICENSES:
CFP® - 03/2021
Series 66 – 12/2004
Series 7 – 09/2000
SIE – 06/2017
CRPC® - Chartered Retirement Planning Counselor
Individuals who hold the CRPC® designation have completed a course of study encompassing pre-and post-
retirement needs, asset management, estate planning and the entire retirement planning process using models
and techniques from real client situations. Additionally, individuals must pass an end-of-course examination
that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations.
All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary
process.
Designees renew their designation every two-years by completing 16 hours of continuing education,
reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure
requirements.
28
Certified Financial Planner™, CFP®
The CFP® certification is obtained by completing an advanced college-level course of study addressing the
financial planning subject areas that the CFP® Board’s studies have determined as necessary for the competent
and professional delivery of financial planning services, a comprehensive certification exam and agreeing to
be bound by the CFP® board’s Standard of Professional Conduct. As a prerequisite, the individual must have
a Bachelor’s degree from a regionally accredited United States college or university (or foreign university
equivalent) and have at least 3 years of full time financial planning experience (or equivalent measured at 2,000
hours per year). This designation requires 30 hours of continuing education every 2 years and renewing an
agreement to be bound by the Standards of Professional Conduct.
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Mr. Morgante.
Item 4:
Other Business Activities
Mr. Morgante is the owner of DM Global LLC, a commercial real estate holding company. He spends 0 hours
per month in this capacity with no time spent during the trading day.
Mr. Morgante is the owner of Morgante Properties LLC, a real estate company. He spends approximately 1-9
hours per month in this capacity with no time spent during the trading day.
Mr. Morgante is the owner of Variant Financial LLC, a financial holding company. He does not spend any
time in this capacity during the trading day.
Mr. Morgante is the owner of Variant Insurance LLC, an Insurance Agency licensed in the state of Virginia.
He spends approximately 1-2 hours per month in this capacity with no time spent during the trading day. As
such, he may offer insurance products and receive customary fees as a result of insurance sales. A conflict of
interest may arise as these insurance sales may create an incentive to recommend products based on the
compensation earned. To mitigate this potential conflict, Mr. Morgante as a fiduciary, will act in the client’s
best interest
Mr. Morgante is also the owner of Variant Tax Services, LLC. As such, Mr. Morgante will provide income tax
preparation and accounting services. These services are independent of our financial planning and investment
advisory services and are governed under a separate engagement agreement. Clients are not required to utilize
services from Variant Tax Services, LLC.
Item 5:
Additional Compensation
Other than salary, annual bonuses, or regular bonuses, Mr. Morgante does not receive any economic benefit
from any person, company, or organization, in exchange for providing clients advisory services through VPW.
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Item 6:
Supervision
Mr. Morgante is the principal of the firm, and also the firm’s Chief Compliance Officer. He has no direct
supervisor. However, all employees of M&A are required to follow the supervisory guidelines and procedures
manual which is designed to ensure compliance with securities laws in the states where VPW is registered.
30
Item 1: Cover Sheet
FORM ADV PART 2B
BROCHURE SUPPLEMENT
George Clark ADV 2B
VARIANT PRIVATE WEALTH LLC
8350 Broad St., Suite 220
Tysons, VA 22102-5151
703-760-7600
September 2026
This Brochure Supplement provides information about George Clark that supplements the Variant
Private Wealth, LLC Brochure. You should have received a copy of that Brochure. Please contact us at
703-760-7600 if you have any questions about the contents of this supplement. Registration does not
imply any certain level of skill or training.
information about George Clark
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
Item 2:
Educational Background and Business Experience
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George Clark
Born: 2001
EDUCATION:
Virginia Tech, 2024
BUSINESS EXPERIENCE:
Variant Private Wealth, LLC
Financial Planning & Investment Specialist, 07/2024 – Present
Intern, 06/2023 – 08/2023; 12/2023 – 1/2024
Virginia Tech
Student, 08/2020 – 06/2021; 08/2021 – 12/2021; 04/2024 – 06/2024
Home Depot
Front End Associate, 02/2022 – 05/2022; 08/2022 – 12/2022; 01/2023 – 05/2023; 08/2023 – 12/2023; 02/2024
– 04/2024
LII Wealth Management
Intern, 06/2022 – 08/2022; 12/2022 – 01/2023
Bull Run Golf Club
Outside Services, 06/2021 – 08/2021; 12/2021 – 01/2022; 05/2022 – 08/2022
TJ Maxx
Front End Associate, 08/2019 – 08/2020
Freedom High School
Student, 08/2016 – 08/2019
Lunsford Middle School
Student, 07/2014 – 08/2016
PROFESSIONAL DESIGNATIONS / LICENSES:
CFP® - 04/2026
Series 65 – 07/2024
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Certified Financial Planner™, CFP®
The CFP® certification is obtained by completing an advanced college-level course of study addressing the
financial planning subject areas that the CFP® Board’s studies have determined as necessary for the competent
and professional delivery of financial planning services, a comprehensive certification exam and agreeing to
be bound by the CFP® board’s Standard of Professional Conduct. As a prerequisite, the individual must have
a Bachelor’s degree from a regionally accredited United States college or university (or foreign university
equivalent) and have at least 3 years of full time financial planning experience (or equivalent measured at 2,000
hours per year). This designation requires 30 hours of continuing education every 2 years and renewing an
agreement to be bound by the Standards of Professional Conduct.
Item 3:
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Mr. Clark.
Item 4:
Other Business Activities
Mr. Clark does not have any outside business activities to report.
Item 5:
Additional Compensation
Other than salary, annual bonuses, or regular bonuses, Mr. Clark does not receive any economic benefit from
any person, company, or organization, in exchange for providing clients advisory services through VPW.
Item 6:
Supervision
David Morgante, Managing Member and Chief Compliance Officer of Variant Private Wealth, LLC,
supervises and monitors Mr. Clark’s activities on a regular basis to ensure compliance with our firm’s Code of
Ethics. Please contact David Morgante if you have any questions about Mr. Clark’s brochure supplement at
703-760-7600.
33
Item 1: Cover Sheet
FORM ADV PART 2B
BROCHURE SUPPLEMENT
Tyler Harper ADV 2B
VARIANT PRIVATE WEALTH LLC
8350 Broad St., Suite 220
Tysons, VA 22102-5151
703-760-7600
September 2026
This Brochure Supplement provides information about Tyler Harper that supplements the Variant
Private Wealth, LLC Brochure. You should have received a copy of that Brochure. Please contact us at
703-760-7600 if you have any questions about the contents of this supplement. Registration does not
imply any certain level of skill or training.
information about Tyler Harper
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
34
Item 2:
Educational Background and Business Experience
Tyler Harper
Born: 2001
EDUCATION:
Virginia Tech, 2023
BUSINESS EXPERIENCE:
Variant Private Wealth, LLC
Client Service Associate, 07/2023 – Present
Virginia Tech
Student, 08/2019 – 06/2023
PROFESSIONAL DESIGNATIONS / LICENSES:
CFP® - 03/2026
Series 65 – 08/2024
Certified Financial Planner™, CFP®
The CFP® certification is obtained by completing an advanced college-level course of study addressing the
financial planning subject areas that the CFP® Board’s studies have determined as necessary for the
competent and professional delivery of financial planning services, a comprehensive certification exam and
agreeing to be bound by the CFP® board’s Standard of Professional Conduct. As a prerequisite, the
individual must have a Bachelor’s degree from a regionally accredited United States college or university (or
foreign university equivalent) and have at least 3 years of full time financial planning experience (or
equivalent measured at 2,000 hours per year). This designation requires 30 hours of continuing education
every 2 years and renewing an agreement to be bound by the Standards of Professional Conduct.
Disciplinary Information
Item 3:
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Mr. Harper.
Other Business Activities
Item 4:
Mr. Harper does not have any outside business activities to report.
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Additional Compensation
Item 5:
Other than salary, annual bonuses, or regular bonuses, Mr. Harper does not receive any economic benefit from
any person, company, or organization, in exchange for providing clients advisory services through VPW.
Supervision
Item 6:
David Morgante, Managing Member and Chief Compliance Officer of Variant Private Wealth, LLC,
supervises and monitors Mr. Harper’s activities on a regular basis to ensure compliance with our firm’s Code
of Ethics. Please contact David Morgante if you have any questions about Mr. Harper’s brochure supplement
at 703-760-7600.
36
Item 1: Cover Sheet
FORM ADV PART 2B
BROCHURE SUPPLEMENT
Alexander Tagliareni
ADV 2B
VARIANT PRIVATE WEALTH LLC
8350 Broad St., Suite 220
Tysons, VA 22102-5151
703-760-7600
September 2026
This Brochure Supplement provides information about Alexander Tagliareni that supplements the
Variant Private Wealth, LLC Brochure. You should have received a copy of that Brochure. Please
contact us at 703-760-7600 if you have any questions about the contents of this supplement. Registration
does not imply any certain level of skill or training.
information about Alexander Tagliareni
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov.
37
Item 2:
Educational Background and Business Experience
Alexander Tagliareni
Born: 2004
EDUCATION:
Virginia Tech, 2026
BUSINESS EXPERIENCE:
Variant Private Wealth, LLC
Financial Planning and Investment Specialist, 07/2026 – Present
Virginia Tech
Student, 08/2022 – 06/2026
PROFESSIONAL DESIGNATIONS / LICENSES:
Series 65 – 07/2026
Disciplinary Information
Item 3:
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to your evaluation of each supervised person providing investment advice. No
information is applicable to this Item for Mr. Tagliareni.
Other Business Activities
Item 4:
Mr. Tagliareni does not have any outside business activities to report.
Additional Compensation
Item 5:
Other than salary, annual bonuses, or regular bonuses, Mr. Tagliareni does not receive any economic benefit
from any person, company, or organization, in exchange for providing clients advisory services through VPW.
Supervision
Item 6:
David Morgante, Managing Member and Chief Compliance Officer of Variant Private Wealth, LLC,
supervises and monitors Mr. Tagliareni’s activities on a regular basis to ensure compliance with our firm’s
Code of Ethics. Please contact David Morgante if you have any questions about Mr. Tagliareni’s brochure
supplement at 703-760-7600.
38
PRIVACY NOTICE
Maintaining the trust and confidence of our clients is a high priority. That is why we want you to
understand how we protect your privacy when we collect and use information about you, and the steps
that we take to safeguard that information. This notice is provided to you on behalf of Variant Private
Wealth, LLC (“VPW”).
Information We Collect: In connection with providing investment products, financial advice, or other
services, we obtain non-public personal information about you, including:
•
•
•
•
Information we receive from you on account applications, such as your address, date of birth, Social
Security Number, occupation, financial goals, assets and income;
Information about your transactions with us, our affiliates, or others;
Information about your visit to our website. We store that information in web server logs, which are
records of the activities on our sites. The servers automatically capture and save the information
electronically. The information we collect in web server logs helps us administer the site, analyze its
usage, protect the website and its content from inappropriate use and improve the user’s experience.
Information received from credit or service bureaus or other third parties, such as your credit history
or employment status.
Categories of Information We Disclose: We may only disclose information that we collect in accordance
with this policy. VPW does not sell customer lists and will not sell your name to telemarketers.
Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your account
at VPW, except under the following circumstances:
• To entities that perform services for us or function on our behalf, including financial service providers
such as a clearing broker-dealer, investment company, or insurance company. We require these third-
party service providers to maintain appropriate administrative, technical, and physical safeguards
designed to protect the confidentiality and security of your nonpublic personal information and to use
such information only for the purposes for which it was provided;
• To comply with broker-dealer firms that have regulatory requirements to supervise certain
representatives’ activities;
• To third parties who perform services or marketing, client resource management or other parties to
help manage your account on our behalf;
• To your attorney, trustee or anyone else who represents you in a fiduciary capacity;
• To our attorneys, accountants or auditors; and
• To government entities or other third parties in response to subpoenas or other legal process as required
by law or to comply with regulatory inquiries.
How We Use Information: Information may be used among companies that perform support services for us,
such as data processors, client relationship management technology, technical systems consultants and
programmers, or companies that help us market products and services to you for a number of purposes, such
as:
• To protect your accounts/non-public information from unauthorized access or identity theft;
• To process your requests such as securities purchases and sales;
• To establish or maintain an account with an unaffiliated third party, such as a clearing broker-
dealer providing services to you and/or VPW;
• To service your accounts, such as by issuing checks and account statements;
39
• To comply with Federal, State, and Self-Regulatory Organization requirements;
• To keep you informed about financial services of interest to you.
Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using
eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential
marketing use of that information has been clearly, conspicuously and concisely disclosed to the consumer;
(2) the consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the
marketing solicitations; and (3) the consumer has not opted out.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that
controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity
theft. We have developed an ITPP to adequately identify and detect potential red-flags to prevent and mitigate
identity theft.
Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who
need to know that information to provide products or services to you and perform their respective duties. We
maintain physical, electronic, and procedural security measures to safeguard confidential client information.
We further maintain a written incident response program designed to identify, respond to, and mitigate the
effects of unauthorized access to or use of client information. Where required, we will notify affected
individuals as promptly as practicable, and no later than required under applicable regulations.
Cyber Security: Internal policies and procedures are in place to address cyber security. A copy of this policy
is available upon request.
Departing Investment Adviser Representatives (“IARs”):
If your IAR’s affiliation with VPW ends and he or she joins a non-affiliated securities broker-dealer or
registered investment adviser, VPW will permit the IAR to use certain client contact information to solicit
clients to join the IAR's new firm. The client contact information that the IAR may use is limited to your name,
address, email address, phone number and account title.
Certain states have adopted a requirement for you to approve the sharing of information in advance, otherwise
known as an “opt-in” choice. If you live in an “opt-in” state (e.g., California, Massachusetts, Maine, Alaska,
North Dakota or Vermont), then VPW will require your consent to share your information with unaffiliated
third parties who are not servicing your account. State requirements vary and may change without notice.
Succession Planning: In the event that the owner(s) of VPW retire, become incapacitated or perish
unexpectedly, your information would be disclosed to an unaffiliated third party for the purposes of facilitating
a business succession plan. A change in control of ownership of VPW would require your consent, as dictated
by your signed agreement with VPW, in order to continue providing services to you.
Your Right to Opt Out: Federal privacy laws give you the right to restrict some sharing of your personal
financial information. These laws balance your right to privacy with VPW’s need to provide information for
normal business purposes. You have the right to opt out of some information sharing with companies that are
(1) Part of the same corporate group as our financial company (or affiliates); or (2) Not part of the same
corporate group as our financial company (or non-affiliates). Choosing to restrict the sharing of our personal
financial information will not apply to (1) Information about you to firms that help promote and market the
company's own products or products offered under a joint agreement between two financial companies; (2)
40
Records of your transactions--such as your loan payments, credit card or debit card purchases, and checking
and savings account statements--to firms that provide data processing and mailing services for your company;
(3) Information about you in response to a court order; and (4) Your payment history on loans and credit cards
to credit bureaus. If you opt out, you limit the extent to which VPW can provide your personal financial
information to non-affiliates. If you wish to exercise your right to opt out, please contact Variant Private
Wealth, LLC at (703) 760-7600.
Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our
Privacy Policy will continue to apply to you.
Complaint Notification: Please direct complaints to: David Morgante at Variant Private Wealth, LLC,
8350 Broad St., Suite 220 Tysons, VA 22102-5151; (703) 760-7600.
Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate
confidential information, we will notify you. If you have any questions concerning this Privacy Policy, please
contact us at: Variant Private Wealth, LLC, 8350 Broad St., Suite 220 Tysons, VA 22102-5151; (703) 760-
7600.
41