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Item 1: Cover Page
2071D Lawrence Dr
De Pere WI 54115
(920)328-0793
www.veruswealthmgmt.com
Form ADV Part 2A – Firm Brochure
Dated: February 10, 2026
This Brochure provides information about the qualifications and business practices of Verus Wealth Management,
LLC. If you have any questions about the contents of this Brochure, please contact us at (920)328-0793 and/or
mark@veruswealthmgmt.com. The information in this Brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority.
Verus Wealth Management, LLC is a registered investment adviser. Registration does not imply a certain level of
skill or training.
Additional information about Verus Wealth Management, LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov, which can be found using the firm’s identification number, 323130.
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Item 2: Material Changes
Since the last annual filing on 03/18/2025, the material changes are described below. In the future, any material
changes made during the year will be reported here.
• The firm added a minimum quarterly advisory fee and updated the fees for Ongoing Financial Planning and
Project-Based Financial Planning services
• The firm added a second approved custodian, Interactive Brokers
From time to time, we may amend this Brochure to reflect changes in our business practices, changes in regulations,
and routine annual updates as required by securities regulators. Either this complete Brochure or a Summary of
Material Changes shall be provided or made available to each Client annually and if a material change occurs in the
business practices of Verus Wealth Management, LLC.
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Item 3: Table of Contents
Item 1: Cover Page
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Item 2: Material Changes
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Item 3: Table of Contents
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Item 4: Advisory Business
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Item 5: Fees and Compensation
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Item 6: Performance-Based Fees and Side-By-Side Management
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Item 7: Types of Clients
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Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
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Item 9: Disciplinary Information
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Item 10: Other Financial Industry Activities and Affiliations
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
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Item 12: Brokerage Practices
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Item 13: Review of Accounts
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Item 14: Client Referrals and Other Compensation
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Item 15: Custody
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Item 16: Investment Discretion
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Item 17: Voting Client Securities
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Item 18: Financial Information
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Item 4: Advisory Business
Description of Advisory Firm
Verus Wealth Management, LLC is an Investment Adviser principally located in the state of Wisconsin. We are a
limited liability company founded in January 2022. Verus Wealth Management, LLC became registered in 2022.
Mark Albers is the principal owner and Chief Compliance Officer (“CCO”).
As used in this brochure, the words “VWM”, "we", "our firm", “Advisor” and "us" refer to Verus Wealth
Management, LLC and the words "you", "your" and "Client" refer to you as either a client or prospective client of
our firm.
Types of Advisory Services
VWM is a fee-only firm, meaning the only compensation we receive is from our Clients for our services. From time
to time, VWM recommends third-party professionals such as attorneys, accountants, tax advisors, insurance agents,
or other financial professionals. Clients are never obligated to utilize any third-party professional we recommend.
VWM is not affiliated with nor does VWM receive any compensation from third-party professionals we may
recommend.
Wealth Management Services
Wealth Management encompasses investment management services and financial planning. Our firm provides
continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client.
Through personal discussions in which goals and objectives based on a Client's particular circumstances are
established, we develop a Client's personal investment policy or an investment plan with an asset allocation target
and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a
Client’s prior investment history, as well as family composition and background. Account supervision is guided by
the stated objectives of the Client (e.g., maximum capital appreciation, growth, income, or growth, and income), as
well as risk tolerance and tax considerations.
We primarily advise our Clients regarding investments in stocks, bonds, mutual funds, ETFs, U.S. government and
municipal securities, and cash and cash equivalents. We may also provide advice regarding investments held in
Client’s portfolio at the inception of our advisory relationship and/or other investment types not listed above, at the
Client’s request.
When we provide investment management services, Clients grant us limited authority to buy and sell securities on
a discretionary basis. More information on our trading authority is explained in Item 16 of this Brochure. Clients
may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors.
As a benefit of utilizing our Wealth Management Services, VWM also provides the Client with a financial plan
should they choose to have one done. This is provided at no additional fee. A Client will be taken through
establishing their goals and values around money. Clients will be required to provide pertinent information to help
complete the following areas of analysis: net worth, cash flow, insurance, credit scores/reports, employee benefits,
retirement planning, insurance, investments, college planning, and estate planning. Once the Client's information is
reviewed, their plan will be built and analyzed, and then the findings, analysis and potential changes to their current
situation will be reviewed with the Client. Clients will receive a detailed financial plan designed to help achieve
Client’s stated financial goals and objectives. The plan and the Client's financial situation and goals will be
monitored throughout the year.
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When appropriate, we utilize the services of third-party investment advisers (“Outside Managers”) to assist with
the management of Client accounts. We assist Clients in selecting an appropriate allocation model, completing the
Outside Manager’s investor profile questionnaire, interacting with the Outside Manager and reviewing the Outside
Manager. Our review process and analysis of Outside Managers is further discussed in Item 8 of this Brochure.
Additionally, we will meet with the Client on a periodic basis to discuss changes in their personal or financial
situation, suitability, and any new or revised restrictions to be applied to the account.
Financial Planning Services
Financial planning involves an evaluation of a Client's current and future financial state by using currently known
variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial
planning is that through the financial planning process, all questions, information, and analysis will be considered
as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this service
will receive a written report, providing the Client with a detailed financial plan designed to achieve his or her stated
financial goals and objectives.
In general, the financial plan will address some or all of the following areas of concern. The Client and VWM will
work together to select specific areas to cover. These areas may include, but are not limited to, the following:
● Business Planning: We provide consulting services for Clients who currently operate their own business,
are considering starting a business, or are planning for an exit from their current business. Under this type
of engagement, we work with you to assess your current situation, identify your objectives, and develop a
plan aimed at achieving your goals.
● Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine
your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to
reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first
based on factors such as the interest rate of the debt and any income tax ramifications. We may also
recommend what we believe to be an appropriate cash reserve that should be considered for emergencies
and other financial goals, along with a review of accounts (such as money market funds) for such reserves,
plus strategies to save desired amounts.
● College Savings: Includes projecting the amount that will be needed to achieve college or other post-
secondary education funding goals, along with advice on ways for you to save the desired amount.
Recommendations as to savings strategies are included, and, if needed, we will review your financial picture
as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate).
● Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee,
are taking the maximum advantage possible of your employee benefits. If you are a business owner, we
will consider and/or recommend the various benefit programs that can be structured to meet both business
and personal retirement goals.
● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate
plan, which may include whether you have a will, powers of attorney, trusts, and other related documents.
Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing
appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you
consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may
provide you with contact information for attorneys who specialize in estate planning when you wish to hire
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an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between
you and your attorney with your approval or request.
● Financial Goals: We will help Clients identify financial goals and develop a plan to reach them. We will
identify what you plan to accomplish, what resources you will need to make it happen, how much time you
will need to reach the goal, and how much you should budget for your goal.
● Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care,
liability, home, and automobile.
● Investment Analysis: This may involve developing an asset allocation strategy to meet Clients’ financial
goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee
stock options, as well as assisting you in establishing your own investment account at a selected
broker/dealer or custodian. The strategies and types of investments we may recommend are further
discussed in Item 8 of this brochure.
● Retirement Planning: Our retirement planning services typically include projections of your likelihood of
achieving your financial goals, typically focusing on financial independence as the primary objective. For
situations where projections show less than the desired results, we may make recommendations, including
those that may impact the original projections by adjusting certain variables (e.g., working longer, saving
more, spending less, taking more risk with investments).
If you are near retirement or already retired, advice may be given on appropriate distribution strategies to
minimize the likelihood of running out of money or having to adversely alter spending during your
retirement years.
● Risk Management: A risk management review includes an analysis of your exposure to major risks that
could have a significant adverse impact on your financial picture, such as premature death, disability,
property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to
minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so
and, likewise, the potential cost of not purchasing insurance (“self-insuring”).
● Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part
of your overall financial planning picture. For example, we may make recommendations on which type of
account(s) or specific investments should be owned based in part on their “tax efficiency,” with the
consideration that there is always a possibility of future changes to federal, state or local tax laws and rates
that may impact your situation.
We recommend that you consult with a qualified tax professional before initiating any tax planning strategy,
and we may provide you with contact information for accountants or attorneys who specialize in this area
if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you
and your tax professional with your approval.
Financial Planning Services are offered via an Ongoing and/or a Project-Based engagement.
Ongoing Financial Planning. This service involves working one-on-one with a financial planner
(“planner”) over an extended period of time. Through this ongoing arrangement, Clients are expected to
collaborate with the planner to develop and assist in the implementation of their financial plan (the “plan”).
The planner will monitor the plan, recommend any appropriate changes and ensure the plan is up-to-date
as the Client’s situation, goals, and objectives evolve.
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Upon engaging the firm for financial planning, VWM is responsible for obtaining and analyzing all
necessary qualitative and quantitative information from the Client that is essential to understanding the
Client’s personal and financial circumstances; helping the Client identify, select, and prioritize certain
financial goals while understanding the effect that pursuing one goal may have on other potential goals;
assessing the Client’s current course of action and alternative courses of action to identify required changes
that provide the best opportunity for the client to meet their financial goals; developing & presenting
financial planning recommendations based on the aforementioned actions while including all information
that was required to be considered in preparing the recommendations; and ongoing monitoring of the
Client’s progress toward the goals and objectives that the recommendations are based around. These
components all require in-depth communication with the Client in order for the planner to establish a
financial plan and implementation strategy that provides the Client with the most appropriate options in
pursuing their established goals and objectives.
Project-Based Financial Planning. We provide project-based financial planning services on a limited
scope one-time engagement. Project-Based Financial Planning is available for Clients looking to address
specific questions or issues. The Client may choose from one or more of the above topics to cover or other
areas as requested and agreed to by VWM. For Project-Based Financial Planning, the Client will be
ultimately responsible for the implementation of the financial plan.
CCR Section 260.235.2 Disclosure
For Clients who receive our Financial Planning services, we must state when a conflict exists between the interests
of our firm and the interests of our Client. The Client is under no obligation to act upon our recommendation. If
the Client elects to act on any of the recommendations, the Client is under no obligation to effect the transaction
through our firm.
Client Tailored Services and Client Imposed Restrictions
We tailor the delivery of our services to meet the individual needs of our Clients. We consult with Clients initially
and on an ongoing basis, through the duration of their engagement with us, to determine risk tolerance, time horizon
and other factors that may impact the Clients’ investment and/or planning needs.
Clients are able to specify, within reason, any restrictions they would like to place as it pertains to individual
securities and/or sectors that will be traded in their account. All such requests must be provided to VWM in writing.
VWM will notify Clients if they are unable to accommodate any requests.
Retirement Account Advice
When VWM provides investment advice to Clients regarding Client’s retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security
Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we
make money creates some conflicts with Client’s interests, so we operate under a special rule that requires us to act
in your best interest and not put our interest 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 interest, 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
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● Give you basic information about conflicts of interest.
Wrap Fee Programs
We do not participate in wrap fee programs.
Assets Under Management
As of December 31, 2025, VWM has $143,077,574 in discretionary and $0 in non-discretionary assets under
management.
Item 5: Fees and Compensation
Please note, unless a Client has received this brochure at least 48 hours prior to signing an Advisory Contract, the
Advisory Contract may be terminated by the Client within five (5) business days of signing the Advisory Contract
without penalty.
How we are paid depends on the type of advisory services we perform. Below is a brief description of our fees,
however, you should review your executed Advisory Contract for more detailed information regarding the exact
fees you will be paying. No increase to the agreed-upon advisory fees outlined in the Advisory Contract shall occur
without prior Client consent. Please note, lower fees for comparable services may be available from other sources.
Wealth Management Services
The fee is based on a percentage of assets under management and is negotiable. The annualized fees for wealth
management services are based on the following fee schedule:
Assets Under Management
Annual Advisory Fee
$0 - $2,000,000
0.95%
$2,000,001 - $5,000,000
0.75%
$5,000,001 - $10,000,000
0.45%
$10,000,001 and Above
0.30%
The annual advisory fee is paid quarterly in advance based on the value of your account(s) as of the last day of the
previous quarter. The advisory fee is a blended tier. For example, for assets under management of $2,500,000, a
Client would pay 0.91%. The quarterly fee is determined by the following calculation: (($2,000,000 x 0.95%) +
($500,000 x 0.75%)) ÷ 4 = $5,687.50. Regardless of the fee calculation described above, the minimum quarterly
advisory fee shall be $1,500 (i.e., $6,000 annual fee 4).
In determining the advisory fee, we may allow accounts of members of the same household to be aggregated. VWM
relies on the valuation as provided by Client’s custodian in determining assets under management. Our advisory fee
is prorated for any partial billing periods occurring during the engagement, including the initial and terminating
billing periods. Clients may make additions or withdrawals from their account at any time; however, VWM reserves
the right to adjust our advisory fees on a pro-rata basis on account of any such cash-flow transactions.
If VWM utilizes an Outside Manager, the above fee schedule does not include the Outside Manager’s fee. The
Outside Manager’s advisory fees, billing schedule, and payment procedures are set forth in their separate written
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disclosure documents, advisory agreements, and/or the account opening documents of your account Custodian. At
no point will the combined annual advisory fee charged to the Client exceed 2% of assets under management.
Ongoing Financial Planning
We charge a recurring fixed fee for Ongoing Financial Planning. Fees are paid quarterly in advance, ranging from
$1,000 to $2,500. The fee range is dependent upon variables including the specific needs of the Client, complexity,
estimated time, research, and resources required to provide services to you, among other factors we deem relevant.
Fees are negotiable and the final agreed upon fee will be outlined in your Advisory Contract.
VWM collects an initial fee, no greater than $1,500. The initial fee covers the initial construction of the
comprehensive financial plan. This work will commence immediately after the fee is paid, and the length of time
required to complete and deliver the plan is dependent on several factors including the needs of the Client, the
Client’s ability to provide any necessary information and documentation, as well as the complexity of their financial
situation. Advisor may reduce or waive the initial fee at the Advisor’s discretion. At no time do we require
prepayment of $500 or more six months or more in advance of rendering the services.
Project-Based Financial Planning
We charge a fixed fee for Project-Based Financial Planning. Fixed fee rates range between $4,000 to $10,000. The
fee range is dependent upon variables including the specific needs of the Client, complexity, estimated time,
research, and resources required to provide services to you, among other factors we deem relevant. Fees are
negotiable and the final agreed upon fee will be outlined in your Advisory Contract. Fees are due upon completion
of the services. VWM will not bill an amount above $500 more than 6 months or more in advance of rendering the
services.
Fee Payment
For Wealth Management services, advisory fees are deducted from one or more account(s) held at an unaffiliated
third-party custodian, as directed by the Client. Please refer to Item 15 of this Brochure regarding our policy on
direct fee deduction. Clients may also pay by check.
For Financial Planning services, fees are paid by check.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may
be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties
such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic fund
fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange-traded
funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and
commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions,
fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending custodians for Client’s
transactions and determining the reasonableness of their compensation (e.g., commissions).
Clients may incur fees from third-party professionals such as accountants and attorneys that VWM may recommend,
upon Client request. Such fees are separate and distinct from VWM’s advisory fees.
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Terminations and Refunds
For Wealth Management services, the Advisory Contract may be terminated with written notice at least 30 calendar
days in advance. Upon termination of the Advisory Contract, a prorated refund will be provided to the Client.
For Ongoing Financial Planning, the Advisory Contract may be terminated with written notice at least 30 calendar
days in advance. In the event of early termination prior to the initial plan being delivered, fees will be prorated and
any unearned fees will be refunded to the Client. Upon termination, the fee will be prorated based on the percentage
of work completed by the Advisor and refunded to the Client.
For Project-Based Financial Planning services, this service is not an ongoing engagement, thus upon receipt of the
final fees, the Advisory Contract will automatically be terminated. Clients may terminate at any time provided
written notice. If fees are paid in advance, a prorated refund will be given, if applicable, upon termination of the
Advisory Contract for any unearned fee. For fees paid in arrears, Client shall be charged a pro-rata fee based upon
the percentage of the work done up to the date of termination.
Sale of Securities or Other Investment Products
Advisor and its supervised persons do not accept compensation for the sale of securities or other investment products
including asset-based sales charges or service fees from the sale of mutual funds.
Item 6: Performance-Based Fees and Side-By-Side Management
We do not offer performance-based fees and do not engage in side-by-side management.
Item 7: Types of Clients
We provide financial planning and investment management services to individuals, high net-worth individuals,
trusts and estates, donor-advised funds and small businesses.
We do not have a minimum account size requirement, but we do have a minimum quarterly fee. Please refer to Item
5 of this Brochure for more information on the minimum quarterly fee.
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Below is a brief description of our methods of analysis and primary investment strategies.
Methods of Analysis
Modern Portfolio Theory (MPT)
The underlying principles of MPT are:
●
Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected
return. Risk and investment return are related and an increase in risk requires an increased expected return.
● Markets are efficient. The same market information is available to all investors at the same time. The market
prices every security fairly based upon this equal availability of information.
● The design of the portfolio as a whole is more important than the selection of any particular security. The
appropriate allocation of capital among asset classes will have far more influence on long-term portfolio
performance than the selection of individual securities.
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●
●
Investing for the long-term (preferably longer than ten years) becomes critical to investment success
because it allows the long-term characteristics of the asset classes to surface.
Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio
risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition
to one another.
Use of Outside Managers: We may refer Clients to Third Party Investment Advisers or advisory programs
(“Outside Managers”). Our analysis of Outside Managers involves the examination of the experience, expertise,
investment philosophies, and past performance of the Outside Managers in an attempt to determine if that Outside
Manager has demonstrated an ability to invest over a period of time and in different economic conditions. We
monitor the Outside Manager's underlying holdings, strategies, concentrations, and leverage as part of our overall
periodic risk assessment. Additionally, as part of our due diligence process, we survey the Outside Manager's
compliance and business enterprise risks. A risk of investing with an Outside Manager who has been successful in
the past is that they may not be able to replicate that success in the future. In addition, we do not control the
underlying investments in an Outside Manager's portfolio. There is also a risk that an Outside Manager may deviate
from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our Clients.
Moreover, as we do not control the Outside Manager's daily business and compliance operations, we may be
unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies.
Investment Strategies
Asset Allocation
In implementing our Clients’ investment strategy, we begin by attempting to identify an appropriate ratio of equities,
fixed income, and cash (i.e. “asset allocation”) suitable to the Client’s investment goals and risk tolerance.
A risk of asset allocation is that the Client may not participate in sharp increases in a particular security, industry or
market sector. Another risk is that the ratio of equities, fixed income, and cash will change over time due to stock
and market movements and, if not corrected, will no longer be appropriate for the Client’s goals. We attempt to
closely monitor our asset allocation models and make changes periodically to keep in line with the target risk
tolerance model.
Passive Investment Management
Passive investing involves building portfolios that are composed of various distinct asset classes. The asset classes
are weighted in a manner to achieve the desired relationship between correlation, risk, and return. Funds that
passively capture the returns of the desired asset classes are placed in the portfolio. The funds that are used to build
passive portfolios are typically index mutual funds or exchange-traded funds.
Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio have
low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because
the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal).
In contrast, active management involves a single manager or managers who employ some method, strategy or
technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a
designated benchmark.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which you
should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other
investment or security. Material risks associated with our investment strategies are listed below.
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Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a
general market decline, reducing the value of the investment regardless of the operational success of the issuer’s
operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations
are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may
face a greater risk of business failure, which could increase the volatility of the Client’s portfolio.
Turnover Risk: Actively managed mutual funds tend to have a higher turnover rate than passive funds. A high
portfolio turnover would result in higher transaction costs and in higher taxes when shares are held in a taxable
account. These factors may negatively affect the account’s performance.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more
volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at
prices we consider reasonable or favorable or find buyers at any price.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below
par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest
rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most
other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your
investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may have
other risks.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or
restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse
effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay
the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors
can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are
priced at a discount from their face values and their values accrete over time to face value at maturity. The market
prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and maturity. In general,
market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the
time to a bond’s maturity, the greater its interest rate risk.
Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking
industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected
by downturns in the U.S. and foreign economies or changes in banking regulations.
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Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the
construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds.
However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return
to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries
the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk,
inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain
Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following
risks: (i) an ETF’s shares may trade at a market price that is above (premium) or below (discount) their net asset
value and an ETF purchased at a premium may ultimately be sold at a discount; (ii) trading of an ETF’s shares may
be halted if the listing exchange’s officials deem such action appropriate, the shares are delisted from the exchange,
or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock
trading generally. The Adviser has no control over the risks taken by the underlying funds in which the Clients
invest.
Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate
share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses,
many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an
underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use
of derivatives).
Item 9: Disciplinary Information
Criminal or Civil Actions
VWM and its management persons have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
VWM and its management persons have not been involved in administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
VWM and its management persons have not been involved in legal or disciplinary events that are material to a
Client’s or prospective Client’s evaluation of VWM or the integrity of its management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
Neither VWM or its management persons is registered, or have an application pending to register, as a broker-dealer
or a registered representative of a broker-dealer.
Other Affiliations
Neither VWM or its management persons is registered, or have an application pending to register, as a futures
commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the
foregoing entities.
Related Persons
Mark Albers holds a Certified Public Accountant (CPA) license. He does not have an accounting business and/or
affiliation and does not have signatory authority on client accounts.
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Recommendations or Selections of Other Investment Advisers
As referenced in Item 4 of this brochure, VWM may recommend Clients to Outside Managers to manage their
accounts. In the event that we recommend an Outside Manager, we do not share in their advisory fee. Our fee is
separate and in addition to their compensation (as noted in Item 5 of this brochure). In addition, you will be provided
a copy of the Outside Manager’s Form ADV 2A, Firm Brochure, which also describes the Outside Manager’s fee.
You are not obligated, contractually or otherwise, to use the services of any Outside Manager we recommend.
Moreover, VWM will only recommend an Outside Manager who is properly licensed or registered as an investment
adviser.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
As a fiduciary, our firm has a duty of utmost good faith to act solely in the best interests of each Client. Our Clients
entrust us with their funds and personal information, which in turn places a high standard on our conduct and
integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our
dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board
of Standards Inc., and accepts the obligation not only to comply with the mandates and requirements of all applicable
laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all
professional services and activities.
Code of Ethics Description
This Code of Ethics does not attempt to identify all possible conflicts of interest, and compliance with each of its
specific provisions will not shield our firm or its access persons from liability for misconduct that violates a fiduciary
duty to our Clients. A summary of the Code of Ethics' Principles is outlined below.
Integrity - Access persons shall offer and provide professional services with integrity.
●
● Objectivity - Access persons shall be objective in providing professional services to Clients.
● Competence - Access persons shall provide services to Clients competently and maintain the necessary
knowledge and skill to continue to do so in those areas in which they are engaged.
● Fairness - Access persons shall perform professional services in a manner that is fair and reasonable to
Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such
services.
● Confidentiality - Access persons shall not disclose confidential Client information without the specific
consent of the Client unless in response to proper legal process, or as required by law.
● Professionalism - Access persons conduct in all matters shall reflect the credit of the profession.
● Diligence - Access persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm
access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm
will provide a copy of its Code of Ethics to any Client or prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest
Neither our firm, its access persons, or any related person is authorized to recommend to a Client or effect a
transaction for a Client, involving any security in which our firm or a related person has a material financial interest,
such as in the capacity as an underwriter, adviser to the issuer, principal transaction, among others.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
Our firm and its “related persons” do invest in the same securities, or related securities, e.g., warrants, options or
futures, which we recommend to Clients.
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Trading Securities At/Around the Same Time as Client’s Securities
Because our firm and its “related persons” do invest in the same securities, or related securities, e.g., warrants,
options or futures, which we recommend to Clients, we have a policy to submit all Client trades first, and then
submit any trades for accounts of any “related person”.
Item 12: Brokerage Practices
Factors Used to Select Custodians
VWM does not have any affiliation with any custodian we recommend. Specific custodian recommendations are
made to the Client based on their need for such services. We recommend custodians based on the reputation and
services provided by the firm.
In recommending custodians, we have an obligation to seek the “best execution” of transactions in Client accounts.
The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether
the transaction represents the best qualitative execution, taking into consideration the full range of the custodian’s
services. The factors we consider when evaluating a custodian for best execution include, without limitation, the
custodian’s:
● Combination of transaction execution services and 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, bill
payment, etc.);
● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs),
etc.);
● 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 the prices;
● Reputation, financial strength, security and stability;
● Prior service to us and our clients.
With this in consideration, our firm uses Charles Schwab, an independent and unaffiliated SEC registered broker-
dealer firm and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor
Protection Corporation (“SIPC”) for most Client accounts. Our firm has also approved the use of Interactive
Brokers, an independent and unaffiliated SEC registered broker-dealer firm and member of FINRA and the SIPC,
in certain circumstances. We are not affiliated with Charles Schwab or Interactive Brokers.
Research and Other Soft-Dollar Benefits
We do not have any soft-dollar arrangements with custodians whereby soft-dollar credits, used to purchase products
and services, are earned directly in proportion to the amount of commissions paid by a Client. However, as a result
of being on their institutional platform, Charles Schwab may provide us with certain services that may benefit us.
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They
provide our Clients and us with access to their institutional brokerage services (trading, custody, reporting and
related services), many of which are not typically available to Schwab retail customers. Schwab also makes
available various support services. Some of those services help us manage or administer our Clients’ accounts,
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while others help us manage and grow our business. Schwab’s support services are generally available on an
unsolicited basis (we don’t have to request them) and at no charge to us. The benefits received by Advisor or its
personnel do not depend on the number of brokerage transactions directed to Schwab. As part of its fiduciary duties
to Clients, Advisor at all times must put the interests of its Clients first. Clients should be aware, however, that the
receipt of economic benefits by Advisor or its related persons in and of itself creates a potential conflict of interest
and may indirectly influence the Advisor’s choice of Schwab for custody and brokerage services. This conflict of
interest is mitigated as Advisor regularly reviews the factors used to select custodians to ensure our recommendation
is appropriate. Following is a more detailed description of Schwab’s support services:
1. 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.
2. Services that may not directly benefit you. Schwab also makes available to us other products and services
that benefit us but may not directly benefit you or your account. These products and services assist us in
managing and administering our Clients’ accounts. They include investment research, both Schwab’s own
and that of third parties. We may use this research to service all or a substantial number of our Clients’
accounts, including accounts not maintained at Schwab. 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
3. 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
● Consulting on technology, compliance, legal, and business needs
● Publications and conferences on practice management and business succession
4. Your brokerage and custody costs. For our Clients’ accounts that Schwab maintains, Schwab 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 ETFs) may not incur Schwab commissions or transaction fees.
Brokerage for Client Referrals
We receive no referrals from a custodian, broker-dealer or third party in exchange for using that custodian, broker-
dealer or third party.
Clients Directing Which Broker/Dealer/Custodian to Use
We do use specific custodians for Clients and do not allow Clients to direct which Broker/Dealer/Custodian to use.
Aggregating (Block) Trading for Multiple Client Accounts
Investment advisers may elect to purchase or sell the same securities for several clients at approximately the same
time when they believe such action may prove advantageous to clients. This process is referred to as aggregating
orders, batch trading or block trading. We do not engage in block trading. It should be noted that implementing
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trades on a block or aggregate basis may be less expensive for client accounts; however, it is our trading policy to
implement all client orders on an individual basis. Therefore, we do not aggregate or “block” client transactions.
Considering the types of investments we hold in advisory client accounts, we do not believe clients are hindered in
any way because we trade accounts individually. This is because we develop individualized investment strategies
for clients and holdings will vary. Our strategies are primarily developed for the long-term and minor differences
in price execution are not material to our overall investment strategy.
Outside Managers used by VWM may block Client trades at their discretion. Their specific practices are further
discussed in their ADV Part 2A, Item 12.
Item 13: Review of Accounts
Periodic Reviews
Mark Albers, Founder, Managing Member and CCO of VWM, will work with Clients to obtain current information
regarding their assets and investment holdings and will review this information as part of our financial planning
services. VWM does not provide specific reports to Clients, other than financial plans. Clients who engage us for
wealth management services will have their account(s) reviewed regularly on a quarterly basis by Mark Albers,
Founder, Managing Member and CCO. The account(s) are reviewed with regards to the Client’s investment policies
and risk tolerance levels.
Triggers of Reviews
Events that may trigger a special review would be unusual performance, addition or deletions of Client-imposed
restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per Client's
needs.
Review Reports
Clients will receive trade confirmations from the custodian(s) for each transaction in their accounts as well as
monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the
accounts, such as receipt of dividends and interest.
VWM does not provide written performance or holdings reports to Wealth Management Clients outside of what is
provided directly by their custodian as part of their account statements and reports available on-demand through the
performance-reporting client portal currently on the Advyzon platform.
Item 14: Client Referrals and Other Compensation
Compensation Received by Verus Wealth Management, LLC
VWM is a fee-only firm that is compensated solely by its clients. VWM does not receive commissions or other
sales-related compensation. Except as mentioned in Item 12 above, we do not receive any economic benefit, directly
or indirectly, from any third party for advice rendered to our clients.
Client Referrals from Solicitors
VWM does not, directly or indirectly, compensate any person who is not advisory personnel for Client referrals.
Item 15: Custody
VWM does not hold, directly or indirectly, Client funds or securities, or have any authority to obtain possession of
them. All Client assets are held at a qualified custodian.
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If VWM deducts its advisory fee from Client’s account(s), the following safeguards will be applied:
i.
ii.
The Client will provide written authorization to VWM, permitting us to be paid directly from Client’s
accounts held by the custodian.
The custodian will send at least quarterly statements to the Client showing all disbursements from the
accounts, including the amount of the advisory fee.
iii. VWM will send an itemized invoice to the Client at the same time it instructs the custodian to debit the
advisory fee.
VWM can establish standing letter of instructions or other similar asset transfer authorization
arrangements (“SLOA”) with qualified custodians in order for us to disburse funds to accounts
as specifically designated by the client. With a SLOA a client can typically authorize first-party
and/or third-party transfers. If transfers are third-party, VWM complies with each of
the requirements and conditions enumerated below:
1. The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
2. The client authorizes VWM, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or from
time to time.
3. The client’s qualified custodian performs appropriate verification of the instruction,
such as a signature review or other method to verify the client’s authorization and
provides a transfer of funds notice to the client promptly after each transfer.
4. The client can terminate or change the instruction to the client’s qualified custodian.
5. VWM has no authority or ability to designate or change the identity of the third party,
the address, or any other information about the third party contained in the client’s
instruction.
6. VWM maintains records showing that the third party is not a related party of SIM
or located at the same address as VWM.
7. The client’s qualified custodian sends the client, in writing, an initial notice confirming
the instruction and an annual notice reconfirming the instruction.
We urge you to carefully review custodial statements and compare them to the account invoices or reports that we
may provide to you and notify us of any discrepancies. Clients are responsible for verifying the accuracy of these
fees as listed on the custodian’s brokerage statement as the custodian does not assume this responsibility. Our
invoices or reports may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies of certain securities.
Item 16: Investment Discretion
For those Client accounts where we provide Wealth Management Services, VWM has discretionary authority and
limited power of attorney to determine the securities and the amount of securities to be bought or sold for a Client’s
account without having to obtain prior Client approval for each transaction. Investment discretion is explained to
Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client
will execute a Limited Power of Attorney, which will grant our firm discretion over the account(s). Additionally,
the discretionary relationship will be outlined in the Advisory Contract and signed by the Client. Clients may limit
our discretion by requesting certain restrictions on investments. However, approval of such requests are at the firm’s
sole discretion.
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If VWM has engaged an Outside Manager to assist with the management of Client’s portfolio, VWM has the
discretion to direct the Outside Manager to buy or sell securities for Client’s portfolio without obtaining prior Client
approval for each transaction.
Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2)
acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s
qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the
Client’s investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at
the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were
to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you
have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic
solicitation to vote proxies.
Item 18: Financial Information
We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our
clients, nor have we been the subject of any bankruptcy proceeding. We do not have custody of Client funds or
securities, except as disclosed in Item 15 above, or require or solicit prepayment of more than $1,200 in fees six
months or more in advance.
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