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Form ADV Part 2A: Firm Brochure
Item 1 – Cover Page
1909 East Big Beaver
Troy, MI 48083
(248) 602-0555
www.vertrixwm.com
Effective Date: March 20th, 2026
Previous Revision Date: January 20th, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Vertrix Wealth Management, LLC (“Vertrix”, or “the Firm”). If you have any questions about the
contents of this brochure, please contact us at (248) 602-0555 or by email at kristie@vertrixwm.com . The
information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission (SEC) or by any State Securities Authority.
Additional information about Vertrix is also available at the SEC’s website www.adviserinfo.sec.gov
The use of the term “registered investment adviser” and description of Vertrix Wealth Management, LLC. and/or
our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this
Brochure and the Brochure Supplements for our firm’s associates who advise you for more information on the
qualifications of our firm and our employees.
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Item 2 – Material Changes
Vertrix Wealth Management LLC is required to amend our ADV Part 2A Firm Brochure when information
becomes materially inaccurate. If there are any material changes to our disclosure brochure, we are
required to notify you and provide you with a description of the material changes.
Since our last ADV 2A amendment filed on January 20th, 2026, we have made the following material
changes to our brochure.
• We have removed references to Fidelity as a qualified custodian utilized by our firm under Items
12 and 14. For our comprehensive portfolio management services, we only recommend the use
of Charles Schwab as the qualified custodian.
• Under Item 12 Brokerage Practices we removed reference to Matrix Trust and Advisor Trust as
two custodians recommended for retirement plan business.
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Item 3 – Table of Contents
Contents
Item 1 – Cover Page ................................................................................................... 1
Item 2 – Material Changes ......................................................................................... 2
Item 3 – Table of Contents ......................................................................................... 3
Item 4 – Advisory Business ....................................................................................... 4
Item 5 – Fees and Compensation ............................................................................... 6
Item 6 – Performance-Based Fees and Side-By-Side Management .......................... 8
Item 7 – Types of Clients ........................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................... 9
Item 9 – Disciplinary Information ...........................................................................12
Item 10 – Other Financial Industry Activities and Affiliations ...............................13
Item 11 – Code of Ethics, Participation or Interest in Client Transactions &
Personal Trading ......................................................................................................13
Item 12 – Brokerage Practices .................................................................................14
Item 13 – Review of Accounts .................................................................................19
Item 14 – Client Referrals and Other Compensation ...............................................19
Item 15 – Custody ....................................................................................................20
Item 16 – Investment Discretion ..............................................................................20
Item 17 – Voting Client Securities (i.e., Proxy Voting) ..........................................21
Item 18 – Financial Information ..............................................................................21
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Item 4 – Advisory Business
Vertrix Wealth Management, LLC (“Vertrix”, “Firm”, or “Adviser”) is a registered investment adviser with
the Securities and Exchange Commission. The Firm is organized as a limited liability company formed
under the laws of the state of Michigan on October 2025 and is principally owned by 24 Strand, LLC which
Kristie Guadiano is the sole member.
Advisory Services Offered:
Vertrix provides Investment Advisory Services to individuals, high net worth individuals, trusts, estates,
businesses, pensions and profit-sharing plans and charitable organizations (each referred to as a “Client”).
The Firm serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, Vertrix upholds the duty of loyalty, fairness and good faith towards each Client and seeks to
mitigate potential conflicts of interest.
We offer Clients comprehensive portfolio management on a discretionary and non-discretionary basis as
well as Pension and Retirement Plan Consulting. In a discretionary account, you authorize us to buy and
sell investments in your account without asking you in advance, subject to any reasonable investment
restrictions previously agreed upon in writing. In a non-discretionary account, you will decide what
investments are bought and sold within your account based off of the advice we give you. We will make
recommendations, if approved by you, we will then implement those recommendations. The nature of
our services provided will be detailed in the agreement you execute with us.
We tailor our advisory services to the individual Client’s needs, beginning with an understanding of the
Client’s financial position, investment experience and objectives. We request information regarding Client
assets, retirement plans, estate planning concerns and risk tolerance. We also inquire as to whether or
not the Client has any restrictions regarding specific investments, or if the Client holds any investments
for personal, socially responsible or other reasons. We work with our Clients to establish specific
investment portfolios appropriate to the Client’s investment time horizon, risk tolerance and any
restrictions. Each investment plan is uniquely modeled to the individual Client. Please refer to Item 8 of
this brochure for more information regarding our investment process.
Our comprehensive portfolio management services encompass asset management as well as financial
planning, which may include the preparation of a financial plan utilizing financial planning software.
Financial Planning services are provided at no additional cost to our advisory Clients.
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Fiduciary Responsibility for Retirement Accounts:
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interests ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interests, fees and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Retirement Plan Consulting
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis.
Generally, such consulting services consist of assisting employer plan sponsors in establishing monitoring
and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor
dictate, areas of advising could include investment options, plan structure and participant education.
All retirement plan consulting services shall follow the applicable state laws regulating retirement
consulting services. This applies to Client accounts that are retirement or other employee benefit plans
(“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the
Client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts,
our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA.
As a 3(38) Investment Manager, the Client gives our firm discretionary authority to manage the plan assets
and fiduciary responsibility to construct and select the plans menu of investment options.
For all qualified plans, and when acting in the capacity of a 3 (21) Fiduciary, we will generally assist with:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad strategies
to be employed to meet the objectives.
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•
Investment Options – Our firm will work with the plan sponsor to evaluate existing investment
options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation, and tolerance for risk.
•
Investment Monitoring – Our firm will monitor the performance of the investments and notify
the Client in the event of over/underperformance and in times of market volatility.
Additionally, if elected by the plan fiduciary we may also offer investment advice to plan participants as
an additional service to support the overall financial well-being and knowledge of plan participants. This
service will be limited to those participants who choose to meet with us and accept our services under
this election.
All services provided, and the nature of our engagement with plan Clients will be detailed within our ERISA
agreement executed with the plan sponsor(s).
Assets Under Management
The firm’s initial registration filing occurred in December 2025 and did not become operational until
January 2026. As of March 20th, 2026, the firm has $343,192,521 in discretionary regulatory assets under
management.
Item 5 – Fees and Compensation
The Fee and Compensation information below details the fees charged by Vertrix for the advisory services
offered. It is important to understand that the fees charged by our firm may be higher or lower than those
charged by other advisers offering comparable services.
For most services, the following blended tier fee schedule applies:
Account Value
First $1,000,000
Next $4,000,000
Next $5,000,000
Next $5,000,000
Next $10,000,000
Annual Fee Rate
1.25%
1.00%
0.90%
0.80%
0.75%
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Under our blended fee tier, your assets will be charged the corresponding fee for each asset tier
applicable, then a weighted average is applied to calculate your fee for the quarter. This fee schedule will
apply to both discretionary and non-discretionary services. We do not charge a separate fee for our
financial planning and consulting services as detailed above under Item 4: Advisory Services Offered. In
limited circumstances, advisory fees may be negotiable at our discretion based on factors such as account
size, overall Client relationship, or other circumstances
Investment Advisory Fees:
Asset Based Investment advisory fees are paid quarterly in advance pursuant to the terms of the
investment advisory agreement. The quarterly fee is based on the fair market value of a Client’s portfolio
assets under management within the Client’s account(s) on the last trading day of the previous calendar
quarter. Vertrix charges a fee of up to 1.25% annually based on several factors, including, the complexity
of the services to be provided, the level of assets to be managed, and the overall relationship with our
Firm. Relationships with multiple objectives, specific requirements, portfolio restrictions and other
complexities may be charged a higher fee. You provide authorization permitting the calculated fees to be
paid by the terms detailed herein and within your agreement with us.
The investment advisory fee in the first quarter of service is prorated from the effective date of the
executed agreement to the end of the first quarter. Fees and terms may be negotiable at the sole
discretion of the Firm. All securities held in accounts managed by Vertrix will be independently valued by
the chosen custodian. Fees are calculated based on the quarter-end valuation of portfolio assets provided
by the Custodian. Vertrix will send an invoice to the Custodian indicating the amount of the fees to be
deducted from the Account(s). Clients will receive independent statements from the Custodian no less
frequently than quarterly.
The advisory fee will be charged on cash and cash equivalents in the account(s) including without
limitation, cash management or short-term sweep accounts, money market funds or bank deposit
products.
In addition to advisory fees, we charge our advisory Clients a quarterly reporting fee per non-retirement
plan account. If a Client elects to have us send to them our reports by U.S. Mail, we will also charge a fee
per calendar quarter per household. Unless otherwise agreed to in writing in advance, we bill and deduct
the reporting fees and applicable mailing fees quarterly.
Fees are deducted directly from the Client’s account under the terms of the executed Investment Advisory
Agreement and the Client’s written authorization. Each quarter, Clients receive a statement from the
custodian detailing the deduction. If agreed upon, and at our discretion, Clients may also choose to be
invoiced and remit payment directly to Vertrix. The Client is responsible for ensuring timely payment in
accordance with the investment advisory agreement. In the event the advisory relationship is terminated
before the end of the billing period, our investment management fee is prorated through the effective
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date of termination. Clients may terminate the advisory relationship at any time pursuant to the terms of
the investment advisory agreement executed with us.
Retirement Plan Fees:
For services, a Client will pay a fee based on either the market value of the Plan assets, or a flat fee in
accordance with the schedule of fees described and selected by the Client unless otherwise agreed to by
both parties. The fee range for services is negotiable and may vary according to the facts and
circumstances including the scope of services to be provided, the duration of services and the size and
complexity of the Client (number of employees, number of annual meetings requested, nature of services
such as 3 (21) or 3 (38), plan or individual assets, and other demographic factors). Vertrix may receive fees
directly from a Client (plan sponsor or individual), we will provide the Client with an invoice to be paid by
a check, or we may instruct the record keeper to deduct fees from plan assets for providing any or all the
services described above. Fees are billed quarterly in advance. Our firm has a minimum plan fee of $2,000.
Other Fees and Expenses:
Clients will incur transaction fees charged by the Custodian for trades executed in their account(s).
Information regarding custodian transaction cost is outlined in the account’s custodial agreement. These
transaction fees are separate from our Firm’s investment advisory fees and will be disclosed by the
Custodian. Clients may also pay holdings charges imposed by the 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, 12(b)-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. Clients should carefully review the account statements and fund prospectuses
provided by the custodian to understand the total cost of their investments. Our firm does not receive a
portion of these fees.
Item 6 – Performance-Based Fees and Side-By-Side Management
Our firm does not charge performance-based fees for its investment advisory services. The fees charged
by Vertrix are described in Item 5 – Fees and Compensation above and are not based upon the capital
appreciation of the funds or securities held by any Client.
Item 7 – Types of Clients
We may provide investment advice to individuals, high net-worth Clients, small businesses, charitable
organizations, pension and profit-sharing plans, trusts and estates. We do not require a minimum account
size for our services.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis and Investment Strategies
(1) Investment Philosophy.
Vertrix Wealth Management (“Vertrix”) utilizes a tactical investment approach that seeks to respond
dynamically to evolving market conditions. Each Client portfolio begins with a diversified allocation
aligned to the Client’s investment objectives and risk tolerance; however, allocations may be actively
adjusted to help manage downside risk and pursue improved risk-adjusted returns.
Our investment philosophy is based on the integration of fundamental and technical analysis.
Fundamental analysis assists in identifying high-quality securities, while technical analysis informs entry
and exit timing decisions. We also monitor macroeconomic indicators and market sentiment to assess the
broader investment environment and adjust portfolio exposures accordingly.
(2) Methods of Analysis.
Vertrix employs multiple analytical techniques as part of its investment process:
(a) Fundamental Analysis – Focuses on a company’s financial and operational strength. By reviewing both
macroeconomic and microeconomic factors, Vertrix evaluates valuation metrics to estimate a security’s
intrinsic value and determine whether it may be under- or over-priced.
(b) Technical Analysis – Examines historical price and volume patterns to identify potential future trends
or reversal points, independent of a company’s financial statements.
(c) Market Sentiment Analysis – Measures prevailing investor attitudes (bullish or bearish) using various
indicators, providing insight into short-term trading dynamics.
(d) Macroeconomic Analysis – Evaluates key economic data such as employment, inflation, GDP growth,
and interest rates to gauge the overall health of the economy and its likely effect on markets.
All investing involves risk, including the possible loss of principal, and Clients should be prepared to bear
that loss.
(3) Investment Strategies.
Vertrix offers a variety of investment strategies designed to meet differing objectives, risk levels, and time
horizons. All strategies incorporate the firm’s tactical approach and risk-management discipline.
(a) ETF Strategies
• Dynamic ETF: Broadly diversified portfolios that invest across multiple asset classes, sectors, and
regions. Equity exposure may increase during periods of market strength and decrease during
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periods of market weakness. Vertrix offers Aggressive, Growth, Moderate, and Conservative risk
profiles.
(b) Stock Strategies
• Balanced Growth: Seeks long-term capital appreciation through diversified equity exposure with
a growth orientation. Stock exposure is tactically adjusted based on Vertrix research and market
conditions.
• Strategic Value: Pursues current income and long-term growth by investing primarily in dividend-
paying stocks, with a value-tilted allocation. Tactical exposure adjustments are based on market
strength or weakness.
• Focused Select: Targets long-term capital appreciation through a limited number of holdings. This
higher-conviction approach carries greater potential return and higher risk. Exposure levels are
adjusted tactically.
• Frontier: Focuses on long-term appreciation from innovative sectors such as technology, clean
energy, automation, artificial intelligence, biotechnology, and digital assets. This strategy is highly
volatile and intended for investors with the highest risk tolerance.
(c) Fixed Income Strategies
• Core Bond: Utilizes a blend of fixed-income exchange-traded funds (“ETFs”) to help reduce
volatility and overall portfolio risk. Objectives include income generation, capital preservation,
and protection during economic slowdowns.
(d) Blended Strategies
• Balanced Growth & Income: A moderate strategy combining the Balanced Growth and Core Bond
strategies with a 60% equity / 40% fixed-income allocation. Suitable for investors seeking
balanced growth and income.
• Strategic Value & Income: Combines Strategic Value and Core Bond strategies in a 60/40
allocation. Appropriate for Clients emphasizing income and moderate volatility.
• Focused Select & Income: Integrates the Focused Select and Core Bond strategies with a 60/40
allocation for investors seeking growth with some income stability.
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B. Material Risks (Including Significant or Unusual Risks) Relating to Investment Strategies
(1) Risk of Loss.
Investing in securities involves risk of loss that Clients should be prepared to bear. Although Vertrix
employs multiple methods to mitigate risk, no strategy or analysis technique can guarantee success or
prevent loss in adverse markets.
(2) Principal Risks.
The following are the primary risks associated with the firm’s investment strategies:
(a) Strategy Execution Risk – The analytical methods and tactical adjustments used may fail to achieve
the desired results or may underperform in certain environments.
(b) Market Risk – The value of securities may decline due to general market conditions, economic
developments, or global events. Market downturns can also reduce liquidity, making it more difficult to
sell positions.
(c) Security Selection Risk – Individual securities may decline due to company-specific factors, inaccurate
analysis, or shifts in investor perception.
(d) Sector / Industry Concentration Risk – Portfolios concentrated in specific industries or sectors may be
more volatile than diversified portfolios and are subject to sector-specific downturns.
(e) Liquidity Risk – Certain securities, particularly small- or mid-capitalization stocks, may trade
infrequently, resulting in delays or unfavorable pricing when buying or selling.
(f) Style Risk – Investment styles (e.g., growth vs. value, small- vs. large-cap) may cycle in and out of favor,
affecting relative performance.
(g) Small and Mid-Cap Company Risk – Smaller companies may have limited financial resources, less
liquidity, and greater price volatility compared with larger companies.
(h) Cryptocurrency Risk – Investments in cryptocurrency-related products are highly volatile and
speculative. These securities may trade at premiums or discounts to their underlying value, may employ
leverage or derivatives, and are subject to heightened cybersecurity and theft risk.
(i) Foreign Securities Risk – Investments in foreign securities may be affected by political instability,
currency fluctuations, differing accounting standards, and limited public information compared with U.S.
securities.
C. Risks Associated with Types of Securities Primarily Recommended
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(1) Equity Securities.
Equity securities fluctuate in value based on company performance, investor sentiment, and economic or
political developments. Different market segments (e.g., growth vs. value, large- vs. small-cap) may react
differently to these factors. Global disruptions such as pandemics, terrorism, or geopolitical conflict may
increase short-term volatility and negatively affect long-term returns.
(2) Fixed-Income and Debt Securities.
Investments in bonds and other debt instruments are subject to interest-rate risk (bond values decline
when rates rise), credit risk (issuers may default on payments), and liquidity risk (difficulty selling certain
securities). Lower-rated securities generally involve higher volatility and greater risk of default.
(3) Exchange-Traded Funds (ETFs).
ETFs trade intraday like stocks but represent baskets of underlying securities. Their prices may fluctuate
due to tracking error, market volatility, or supply-demand imbalances unrelated to the underlying
holdings.
(4) Equity Options.
Options provide the right, but not the obligation, to buy or sell a security at a fixed price prior to expiration.
They may be used for hedging or tactical purposes but carry significant risk, including the potential loss of
the entire premium paid. Leverage inherent in options can magnify both gains and losses.
Item 9 – Disciplinary Information
Securities laws require an adviser to disclose any instances where the adviser or its associated persons
have been found liable in a legal, regulatory, civil or arbitration matter that alleges violations of securities
and other statutes; fraud; false statements or omissions; theft; embezzlement or wrongful taking of
property; bribery; forgery; counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices.
Vertrix Wealth Management, LLC and its Management do not have any legal, financial or other
“disciplinary” item to report. We are obligated to disclose any disciplinary event that would be material
to you when evaluating our firm and our services we may provide to you.
The backgrounds of the Firm and its representatives are available on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching our Firm Name or representative’s name.
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Item 10 – Other Financial Industry Activities and Affiliations
its senior management or
investment adviser
Neither Vertrix Wealth Management, LLC, nor
representatives have any other Financial Industry Activities or Affiliations.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions &
Personal Trading
Vertrix has adopted a Code of Ethics (“Code”) that governs a number of potential conflicts of interest we
have when providing advisory services to our Clients. This Code is designed to ensure we meet our
fiduciary obligation to our Clients (or Prospective Clients) and to drive home a Culture of Compliance
within our firm.
An additional benefit of our Code is to detect and prevent violations of securities laws.
Our Code is comprehensive and is distributed to each employee at the time of hire, and annually
thereafter. We also supplement the Code with annual training and on-going monitoring of employee
activity. Our Code includes the following:
• Requirements related to the confidentiality of our Client information;
• Prohibitions on:
Insider trading (if we are in possession of material, non-public information);
o
o The acceptance of gifts and entertainment that exceed our policy standards;
• Reporting of gifts and business entertainment;
• Pre-clearance of certain employee and firm transactions;
• Reporting (on an on-going and quarterly basis) all personal securities transactions (what we call
“reportable securities” as mandated by regulation); and,
• On an annual basis, we require all employees to re-certify to our Code, identify members of their
household and any account to which they have a beneficial ownership (they “own” the account
or have “authority” over the account, securities held in certificate form and all securities they
own at that time).
Participation or Interest in Client Transactions and Personal Trading:
Personal Trading with Material Interest
Vertrix permits its supervised persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients. Our firm does not act as principal in any transactions. In addition,
our firm does not act as the general partner of a fund or advise an investment company. Vertrix does not
have a material interest in any securities traded in Client accounts.
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Personal Trading in Same Securities as Clients
Vertrix allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell)
to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated
through policies and procedures. As noted above, the Firm has adopted a Code of Ethics to address insider
trading (material non-public information controls); gifts and entertainment; outside business activities;
and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict
of interest if trading in the same securities.
Vertrix has adopted the Code, which includes formal insider trading and personal security transactions
policies and procedures.
The Code of Ethics serves to establish a standard of conduct for all of Vertrix’ supervised persons and is
based upon fundamental principles of transparency, integrity, honesty and trust. A copy of our Code of
Ethics is available on request.
Item 12 – Brokerage Practices
The Custodian and Brokers We Use
Vertrix does not maintain custody of your asset that we manage, although we may be deemed to have
custody of your assets if you give us authority to withdraw assets from your account (See Item 15 –
Custody, below) Your assets must be maintained in an account at a “qualified custodian,” generally a
broker-dealer or bank. We recommend that our Clients use Charles Schwab & Co., Inc. (Schwab), FINRA
registered broker-dealer, member SIPC, as the qualified custodian. Vertrix is independently owned and
operated and not affiliated with Schwab, . The chosen custodian will hold your assets in a brokerage
account and buy and sell securities when Vertrix or you instruct them to. While we recommend that you
use one of the qualified custodians noted above as custodian/broker, you will decide whether to do so
and open your account with the custodian by entering into an account agreement directly with them.
Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client
Referrals and Other Compensation). You should consider these conflicts of interest when selecting your
custodian.
We do not open the account for you, although we may assist you in doing so. Not all advisors require their
Clients to use a particular broker-dealer or custodian.
How We Select Brokers/Custodians
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We seek to recommend a custodian / broker who will hold your assets and execute transactions. When
considering whether the terms that the custodian provides are, overall, most advantageous to you when
compared with other available providers and their services, we consider a wide range of factors, including:
•
•
•
combination of transaction execution services combined with asset custody services (generally
without a separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for your account)
capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds, exchange traded
funds
• availability of investment research and tools that assist us in making investment decisions
• quality of services
•
competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate them
reputation, financial strength, and stability of the provider
their prior service to us and our Clients
•
•
• availability of other products and services that benefit us, as discussed below (see “Products and
Services Available to us from Schwab”)
Your Brokerage and Trading Costs
For our Clients’ accounts maintained at Schwab, the custodian generally does not charge you separately
for custody services but is compensated by charging you commissions or other fees on trades that it
executes or that settle into your Schwab account. Certain trades (for example, many mutual funds, and
U.S. exchange listed equities and ETFs) may not incur custodian commissions or transactions fees. Schwab
is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features
Program.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers. We have determined that
having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades.
Best execution means the most favorable terms for a transaction based on all relevant factors, including
those listed above (See “How we select brokers/custodians”). By using another broker or dealer you may
pay lower transaction costs.
The Custodian makes products and services available to Vertrix that benefit Vertrix but may not directly
benefit its Clients’ accounts. Many of these products and services are used to service all or a substantial
number of Vertrix accounts. Some of these products and services provided include software and other
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technology that provides access to Client account data (such as trade confirmations and account
statements); research, pricing, and other market data; facilitates payment of fees from Clients’ accounts;
and assists with back-office functions, recordkeeping, and Client reporting.
Additional Schwab Disclosures
Products and Services Available to Us from Schwab
Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like Vertrix.
Schwab provides us and our Clients with access to its institutional brokerage – trading, custody, reporting
and related services – many of which are not typically available to Schwab retail customers. However,
certain retail investors may be able to get institutional brokerage services from Schwab without going
through our firm. Schwab also makes available various support services. Some of those services help us
manage or administer our Clients’ accounts while others help us manage and grow our business. Schwab’s
support services are generally available to us at no charge. Here is a more detailed description of Schwab’s
support services:
Services that Benefit You: Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions and custody of Client assets. The investment
products available through Schwab include some to which we might not otherwise have access or that
would require a significantly higher minimum initial investment by our Clients. Schwab’s services
described in this paragraph generally benefit you and your account.
Services that Do Not Directly Benefit You: Schwab also makes available to us other products and services
that benefit us but do not directly benefit you or your account. These products and services assist us in
managing and administering our Client accounts. They include investment research, both Schwab’s own
and that of third parties. We use this research to service all or some substantial number of our Clients’
accounts, including accounts not maintained at Schwab, if any. In addition to investment research, Schwab
also makes available software and other technology that:
• provide access to Client account data (such as duplicate trade confirmations and account
statements
facilitate trade execution and allocate aggregated trade orders for multiple Client accounts
facilitate payment of our fees from our Clients’ accounts
•
• provide pricing and other market data
•
• assist with back-office functions, recordkeeping and Client reporting
Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage
and further develop our business enterprise. These services include:
• educational conferences and events
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technology, compliance, legal and business consulting
•
• publications and conferences on practice management and business succession
• access to employee benefits providers, human capital consultants and insurance providers
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab discounts or waives its fees for some of these services or pays all or a
part of a third party’s fees. Schwab also provides us with other benefits such as occasional business
entertainment of our personnel. If you did not maintain your account with Schwab, we would be required
to pay for these services from our own resources.
These services are available to independent investment advisers on an unsolicited basis at no charge to
them. Services provided by Schwab are not contingent upon Vertrix committing to Schwab any specific
amount of trading activity or purchasing of Schwab products.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or purchase
them. We do not have to pay for Schwab’s services. The fact that we receive these benefits from Schwab
is an incentive for us to recommend the use of Schwab rather than making such decisions based
exclusively on your interest in receiving the best value in custody services and the most favorable
execution of your transactions. This is a conflict of interest. We believe, however, taken in the aggregate,
our recommendation of Schwab as custodian and broker is in the best interests of our Clients. Our
selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select
brokers/custodians”) and not Schwab’s services that benefit only us.
Soft Dollar Benefits:
Soft Dollars are revenue programs offered by broker-dealers/custodians where a firm enters into an
agreement to place security trades with a broker-dealer/custodian in exchange for research and other
services. Vertrix does not participate in soft dollar programs sponsored by any broker-dealer/custodian.
However, the Firm receives certain economic benefits from the Custodian. Please see Item 14 – Client
Referrals and Other Compensation.
Brokerage Referrals:
Vertrix does not select or recommend broker-dealers based on our interest in receiving Client referrals
and does not receive any compensation from any third party in connection with the recommendation for
establishing an account.
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Directed Brokerage:
Vertrix will recommend that Clients open brokerage accounts with Schwab. We generally will not accept
directed brokerage arrangements. Not all advisers require their Clients to use a specific broker-dealer or
custodian. Our firm generally does not accept directed brokerage arrangements.
Order Aggregation:
Vertrix, where possible, may aggregate the purchase or sale of securities for various Client accounts in the
form of Block Trading. This method is used to obtain the best price in all available situations. Two factors
that may affect the decision to aggregate are (1) Amount of Security publicly traded and (2) Number of
Clients affected by the transaction. When aggregating trades, we will use an average price method to
ensure that no Client receives more favorable pricing than another.
Principal and Agency Cross Trading Policy:
It is our firm’s policy not to affect any principal or agency cross securities transactions for Client accounts.
Principal transactions are generally defined as transactions where an adviser, acting as principal for its
own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory
Client. An agency cross transaction is defined as a transaction where a person acts as an investment
adviser in relation to a transaction in which the investment adviser, or any person controlled by or under
common control with the investment adviser, acts as broker for both the advisory Client and for another
person on the other side of the transaction.
Trade Error Policy
In the event a trade error occurs, our firm will review all relevant facts and circumstances surrounding the
trade and will determine the appropriate course of action, as necessary. If an investment gain results from
correcting the trade, the gain will remain in the Client account(s) unless 1) the same error involved other
Client account(s) that should have received the gain, 2) it is not permissible for the Client to retain the
gain, or 3) Vertrix confers with the Client who decides to forego the gain (e.g., due to tax reasons).
If the gain does not remain in the Client’s account and Schwab is the custodian, Schwab will donate the
amount of any gain $100 and over to charity. Gains under $100 that are not retained in the Client’s
account are maintained by Schwab to minimize and offset its administrative time and expense.
If a trade error results in a loss greater than $100, Vertrix will pay for the loss except where its errors and
omissions insurance applies. For losses under $100, Schwab may choose to cover the loss. If related trade
errors result in both gains and losses in the Client's account, they will be netted.
In no event shall a trade error benefit our firm in any way.
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Item 13 – Review of Accounts
Frequency and Causes of Reviews:
Client account(s) are reviewed on a regular basis, but no less frequently than annually. From time-to-time
other factors may trigger additional reviews of Client accounts. These factors include but are not limited
to market conditions and volatility; economic news (which may have a material effect on particular sectors
or investments); Client inquiries; and investments of particular interest to specific Clients, and changes to
the Client’s personal situation.
Regular Reports:
The Client will receive brokerage statements no less frequently than quarterly from the Custodian. These
brokerage statements are sent directly from the Custodian to the Client. The Client may also establish
electronic access to the Custodian’s website so that the Client may view these reports and their account
activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s
account(s). Vertrix may also provide Clients with periodic reports regarding their holdings and allocations.
Client statements from Schwab, as the qualified custodian, will include all positions, transactions and fees
relating to your account(s). Please note the account statement provided by the custodian is the only
official record of your account(s).
Item 14 – Client Referrals and Other Compensation
Vertrix may refer Clients to various unaffiliated, non-advisory professionals (e.g. Attorneys, accountants)
to provide certain financial services necessary to meet the goals of its Clients. Likewise, our firm may
receive non-compensated referrals of new Clients from various third parties. Vertrix does not currently
pay promoters cash or other compensation for referring Clients and we are not compensated for any
referrals we may make.
Other Compensation:
We receive an economic benefit from Schwab in the form of the support products and services it makes
available to us and other independent investment advisors that have their Clients maintain accounts at
Schwab. You do not pay more for assets maintained at Schwab as a result of this arrangement. We benefit
from the products and services provided because the cost of these services would otherwise be borne
directly by us. This presents a conflict of interest as it creates an incentive for the firm to recommend
Clients hold their accounts at Schwab as custodian. You should consider these conflicts of interest when
selecting a custodian. These products and services, how they benefit us, and the related conflicts of
interest are described above (see “Item 12 – Brokerage Practices”). The availability to us of Schwab’s
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products and services is not based on us giving particular investment advice, such as buying particular
securities for our Clients.
Certain Clients of our firm were previously obtained through the TD Ameritrade Advisor Direct
Referral Program, and our firm continues to be under this agreement, which was assigned to Schwab, to
pay a referral fee for certain legacy Clients and their family members who engage us for advisory services.
Item 15 – Custody
Vertrix is deemed to have custody of Client funds and securities because the Client gives our firm the
authority to have advisory fees deducted directly from Client’s account. Authorization to trade in Client
accounts (discretion) is not deemed custody. Except for our ability to debit fees, Vertrix does not otherwise
have custody of the assets in Client accounts. The firm’s established procedures require all Client funds
and securities must be held by a qualified custodian in a separate account for each Client under that
Client’s name. The Client will execute an agreement that establishes each account; therefore, you will
know the qualified custodian’s name and address as well as the way your funds or securities are
maintained. Finally, the qualified custodian will deliver your account statements directly to you at least
quarterly. You should carefully review those statements and compare them to any communication you
receive from our firm for accuracy. Minor variations may occur because of reporting dates, accrual
methods of interest and dividends, and other factors. The custodial statement is the official record of your
account for tax purposes. If you ever have questions about your statements, please feel free to contact
our firm, your investment adviser representative, or your qualified custodian.
Item 16 – Investment Discretion
Our firm manages investment accounts on both a discretionary and non-discretionary basis. When
discretion is granted, our firm is authorized to execute securities transactions, determine which securities
are bought and sold, and the total amount to be bought and sold. Limitations may be imposed by the
Client in the form of specific constraints on any of these areas of discretion with our firm’s written
acknowledgement. Discretionary authority allows us to execute investment recommendations in
accordance with the investment policy statement (or similar document used to establish each Client’s
objectives and suitability), without Clients’ prior approval for each specific transaction. Under this
authority, granted in the executed Investment Advisory Agreement, Clients allow us to purchase and sell
securities and instruments in their account(s), arrange for delivery and payment in connection with the
foregoing and act on behalf of the Client in matters necessary or incidental to the handling of the account,
including monitoring certain assets.
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Item 17 – Voting Client Securities (i.e., Proxy Voting)
As a matter of policy, our firm does not have, and will not accept, authority to vote on Client securities.
Clients will receive proxies and other solicitations directly from the custodian. We will not offer any
opinions as to how a Client should vote on any specific proxy.
Item 18 – Financial Information
Neither Vertrix nor its principal owner have any adverse financial situations that would reasonably impair
the ability of the Firm to meet all obligations to its Clients. Neither Vertrix nor its principal owner have
been subject to bankruptcy or financial compromise.
A balance sheet is not required to be provided because our firm does not serve as a custodian for Client
funds or securities, nor does it require prepayment of fees of more than $1,200 per Client six months or
more in advance.
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