Overview
- Headquarters
- Osterville, MA
- Total Firm Assets
- $119 million
- Average High-Net-Worth Client Portfolio Size
- $1.3 million
- Minimum Account Size
- $250,000
Fee Structure
Primary Fee Schedule (WASHINGTON FINANCIAL GROUP, INC.)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $5,000,000 | 0.75% |
| $5,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $40,000 | 0.80% |
| $10 million | $65,000 | 0.65% |
| $50 million | $165,000 | 0.33% |
| $100 million | $290,000 | 0.29% |
Clients
- High-Net-Worth Share of Firm Assets
- 67.67%
- Number of High-Net-Worth Clients
- 61
- Total Client Accounts
- 710
- Discretionary Accounts
- 707
- Non-Discretionary Accounts
- 3
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 132369
Primary Brochure: WASHINGTON FINANCIAL GROUP, INC. (2026-06-22)
View Document Text
Item 1
WASHINGTON FINANCIAL GROUP, INC.
832 Main Street, 2nd Floor
Osterville, MA 02655
Tel: 508-420-8341
June 22, 2026
FORM ADV, PART 2A & 2B
INVESTMENT ADVISER REGISTRATION
Washington Financial Group, Inc., an S-Corporation, CRD No. 132369, is an investment adviser
registered with the United States Securities and Exchange Commission. Brokerage and investment
advisory services and fees differ, and it is important for you to understand those differences. Free
and simple tools are available to research firms and financial professionals at Investor.gov/CRS,
which also provides educational materials about broker-dealers, investment advisers, and
investing. If you have any questions about the contents of this brochure, please contact us at 508-
420-8341 and/or e-mail Humam K. Sirhal at sirhalh@washingtonfinancialgroup.us. The
information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about Washington Financial Group, Inc. (WFG) is also available on the
SEC’s website at www.adviserinfo.sec.gov.
Rev. 06-22-2026 SEC
Form ADV Part 2A.
SEC File Number:
Date:
06-22-2026
801-
Applicant:
Washington Financial
Group, Inc.
I.
Full name of applicant exactly as stated in item 1A of Part I of Form ADV:
Washington Financial Group, Inc.
IRS Empl. Ident. No.:
40-0017982
Item No.
Narrative
Item 2
There have been no material changes since the last amendment dated 03/24/2026.
In the past, WFG has offered or delivered a brochure, with information about its qualifications and
business practices, to clients on at least an annual basis. Pursuant to SEC rules, if there are
material changes to the Brochure, WFG will provide its clients with an amended Form ADV Part
A&B within 120 days of the close of its fiscal year. WFG, if necessary, will also provide clients at
other times during the year with an amended Form ADV Part A&B containing information about
any material changes.
WFG will provide you with a new Brochure, at any time, without charge.
Item 3
Item 1: Cover Page
Item 2: Material Changes
Item 3: Table of Contents
Item 4: Advisory Business
Item 5: Fees and Compensation.
Item 6: Performance-Based Fees and Side-By-Side Management
Item 7: Types of Clients
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Item 9: Disciplinary Information
Item 10: Other Financial Industry Activities and Affiliations
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12: Brokerage Practices
Item 13: Review of Accounts
Item 14: Client Referrals and Other Compensation
Item 15: Custody
Item 16: Investment Discretion
Item 17: Voting Clients Securities
Item 18: Financial Information
Item 19: Margin Agreement and Loan Consent.
Item 4. Advisory Business:
The terms Registered Investment Adviser Representative, Investment Adviser Representative,
Planner, Financial Planner, Adviser and Advisor, mentioned herein, are used interchangeably. The
“Registration” does not imply that as a Registered Investment Adviser Representative, the Adviser
has a level of professional competence, education or special training. However, it does indicate the
passage of Series 65 exam as mandated by the SEC.
Washington Financial Group, Inc.: Date of Legal Status: 04/19/2021
Humam Khalil Sirhal: President & CCO since 04/19/2021 & Registered Investment Adviser
Representative since 06/10/1997.
Rebecca Shirley Sirhal: Treasurer since 04/19/2021.
Humam K. Sirhal and Rebecca S. Sirhal are the owners of the Investment Advisory Business.
Laura Emily Sirhal: Accountant since June of 2019 & Registered Investment Adviser
Representative since 07/30/2020.
Humam Khalil Sirhal Outside Business Activities do not create a material conflict of interest with
clients.
Laura Emily Sirhal Outside Business Activities do not create a material conflict of interest with
clients.
In the course of developing a financial program for a client, the Applicant (named above and
referred herein to as the Adviser) must ascertain the client's financial objectives by interviewing the
client and by making pertinent inquires. Only after making this determination, is it possible for the
financial planner to devise a plan for the client, based upon the client's needs, as well as the
expertise of the planner in his knowledge of the multitude of potential investment and/or insurance
vehicles that are available.
The Adviser provides a variety of securities-related services which may include other incidental
investment advice. Also, the financial planner deals with Separately Managed Accounts programs
offered directly through the Adviser or through other introducing brokers and/or custodians. The
Adviser offers in-house portfolios that affect trades in mutual funds, open and closed-end, stocks,
bonds and REITs. In addition, the Adviser appoints Money Managers who trade in equities, bonds
and ADRs as per their investment style or sector orientation.
The Adviser may perform various techniques in analyzing investments for the advisory clients
which may include, but not limited to, a Risk Tolerance Analysis from third party providers.
The Adviser offers advice on matters concerned with financial and estate planning. Financial
planning typically involves providing a variety of services, principally advisory in nature, to
individuals or families regarding management of their financial resources based upon an analysis of
the client’s needs. Financial planning involves preparing a financial program for a client relating to
the client's financial circumstances and objectives. This information normally covers present and
anticipated assets and liabilities including, but not limited to, insurance, savings, investments,
anticipated retirement age and other employee benefits. The program developed for the client
usually includes general recommendations for a course of activity, or specific actions, to be taken by
the client. For example, recommendations may be made that the client obtain insurance or revise
existing coverages, establish an individual retirement account, increase or decrease funds held in
savings account, or invest funds in securities. The financial planner may develop tax or estate plans
for the client or refer the client to an accountant or attorney for these services. The provider of such
financial planning services, in most cases, assists the client in implementing the recommended
program by, among other things, making specific recommendations to carry out the general
recommendations of the program, or by selling to the client insurance products, securities, or other
investments. The financial planner may also review the client's program periodically and
recommend revisions. Persons providing such financial planning services use various compensation
arrangements. The financial planner may charge an overall fee for developing an individual program
for the client while in other cases he may charge a client an hourly fee. A fee based on a percentage
Item 4.
of assets under management is also a form of compensation for the financial planner. In some
instances, the financial planner may also be compensated, in whole or in part, by commission on the
sale to the client of insurance products, interest in real estate, securities (such as common stocks,
bonds, limited partnership, and mutual funds), or other investments.
Estate planning is more focused upon the accumulation and distribution of assets during the client’s
lifetime and the disposition of the remainder of the estate at death.
Estate planning concerns itself with the enhancement and maximization of the client's estate. It
begins with evaluating methods of asset accumulation by the client. Once assets have been
accumulated the estate planning process considers how best to conserve and increase those
accumulated assets. Estate planning also examines the eventual distribution of such assets and how
to best minimize settlement costs, create the liquidity needed to pay off any income and/or estate
taxes, and assist in accomplishing the personal lifelong financial objectives of the client.
The Adviser subscribes to a process based on dynamic asset allocation. The process starts with a
Risk Tolerance Analysis that produces an Asset and Funds Allocation (A&FA) which evolves into a
“Client Specific A&FA”. The Client Specific A&FA is an initial step that might be modified based
on market conditions, state of the economy and the Adviser’s overall assessment of whose sectors or
investment styles shall drive the market in the subsequent twelve to eighteen months. That would
result, even during the initial trading period in the portfolio, in the Adviser’s overweighting in
certain sectors and/or investment styles and/or cash and/or fixed income holdings. It should be noted
that the adviser believes that wealth accumulation is heavily weighted towards long-term investing
in equities. Accordingly, during the investment process, the client’s holdings might be mostly
positioned in equities versus fixed income instruments. The adviser believes that in most cases, but
not all, income should be derived from profit taking and/or dividends and/or capital gains
distributions of those equities.
The Adviser may select Third Party Advisers to assist in and/or implement his/her recommendations
in the Investment Management process. Third Party “Independent Advisers” need to subscribe to a
similar investment philosophy as that of Humam K. Sirhal in the manner in which the Adviser
manages portfolios based on a dynamic asset allocation model with over-weighting in certain
sectors and/or investment styles and/or cash and/or fixed income holdings that he/she believes that
they will be in-favor during the next twelve to eighteen months period. Other Third-Party Advisers
like Schwab Institutional and/or Envestnet, LLC are selected based on their market footprint which
includes, but not limited to, their experience history and reputation in managing assets. Clients who
are introduced to the Envestnet need to have certain net worth, seeking reduction in operating
expenses and/or management fees (compared to the mutual fund’s fees and expenses), looking to
access Money Manager for less than typical minimums, looking for tax efficient portfolios and,
above all, their investment strategies fit within the line-up of underlying Money Managers that are
introduced by those Advisers.
There are risks involved with each of the above-mentioned investment products. Some of those risks
are listed in Item 8 amongst the following:
Risks of closed-end Mutual Funds: Closed-ended funds are actively managed Mutual Funds that
raise a definite sum by an Initial Public Offering (IPO), after which no one can invest directly into
them (they are traded like stocks on a listed exchange). They typically concentrate on one industry,
geographic market or sector. Every Mutual fund has its own management and manager(s),
objectives, and strategy, so any two funds could have significant differences in their risks, price
volatility, and fees.
Liquidity Risk: In the case when closed-ended Mutual Funds are invested in equity, investing in the
long-term provides a better chance for greater returns. However, if you invest in it for a longer time
frame liquidity becomes an issue. Since closed-end Mutual Funds are actively managed it will work
when the stocks have enough liquidity. Even though being a listed security, there are no guarantees
that the underlying stocks will be liquid. Also, in the case of closed-end Mutual Funds, an investor
can redeem their units only at the maturity date but can sell them through the exchange if required.
Item 4.
Concentration Risk: In case of equity mutual funds, it can be very risky if all the portfolio is
concentrated toward a single sector or market cap. If the fund invests in a specific sector the returns
on the portfolio will solely depend on that sector; in case it performs well, the returns will be good
and vice versa. In order to mitigate concentration risk, it is important to have the portfolio invest in
funds that diversify across various sectors or between various market caps. That way, if one
underperforms the other will be able to counter-balance it.
As of 12-31-2025, the Adviser had under management $118,984,583.00 in discretionary assets and
$57,608.00 in non-discretionary assets.
Business Activities Time spent on each Activity (% Annually)
0 %
Estate Planning
1 %
Financial Planning
Investment Services 95 %
1 %
Insurance Services
3 %
Construction Management
Item 5.
Fees and Compensation:
On the subject of compensation for the Adviser, it is imperative that the client be advised of, and
understand, the financial relationship between planner and client. There are four methods to
compensate the Adviser. The first two methods involve (1) compensation based on an hourly fee
and/or (2) compensation based on a flat fee. The services associated with (1) & (2) include, but are
not limited to, providing asset allocation proposals and/or insurance proposals and/or a
comprehensive financial plan analysis and/or a comprehensive estate plan analysis and/or
investment advice and/or administrative services and/or consultation services involving time and
resources spent by the Adviser. Flat fees typically range from $1,000 to $10,000 annually,
depending on the scope of the service, with one-time financial plans often bearing a cost of $1,000
to $3,000. Ongoing comprehensive services could cost $2,000 to $9,000+ per year, which includes
but not limited to budgeting, investment or tax planning. Costs may vary greatly by complexity (i.e.
basic budgeting vs. estate planning). Even with flat fees pricing, additional investment advisory fees
for managing the portfolio’s assets can still apply. Hourly and/or flat fees are billed after services
are rendered.
In the event that the Adviser decides to waive his/her fee for any or part of the services mentioned
above, the client will be advised of this in writing.
The third method (3) involves compensation that is based on a percentage of assets under
management payable to the Adviser for the management of the client portfolio(s) and/or assets,
including but not limited to, securities-based insurance products. The Adviser bills in arrears. Please
note that this third form of compensation also includes the case when the financial planner enters
into solicitation agreements with other investment advisers who offer one or more services, such as
money management, asset allocation, or market timing to the public.
Under such agreements, compensation is provided to the Adviser in exchange for introducing
his/her client(s) to those advisory firms. Compensation is usually a fixed percentage of fees charged
by the non-affiliated entities to those client(s) who were introduced by the Adviser. The fees paid by
the client(s) are based on assets under management. Under those arrangements, the financial planner
is paid as a solicitor and/or an agent. Solicitor’s or Agent’s fees are usually a fixed portion of the fee
charged by the introducing Investment Advisory firm(s) and /or, in some cases, by the Broker-
Dealer firm.
Based on the Adviser’s sole and absolute discretion, the client shall be informed in writing
concerning the financial planner’s decision to waive and/or reduce any of the fees associated with
the above-mentioned forms of compensation. The Adviser reserves the right to negotiate such fees.
When fees are charged by the Financial Planner based on a percentage of assets under management,
the account size typically must satisfy the two hundred and fifty thousand dollars ($250,000)
minimum requirement. The financial planner does reserve the right to negotiate minimum account
Item 5.
size and annual fees if an account is below the required minimum. Typically, if the account does not
meet the minimum investment amount of $250,000, the fees will be the highest of 1% (Standard
Fee) annually, or a flat dollar amount as agreed upon between the Advisor and the client.
The account may be invested in insurance products (variable & fixed income instruments), interest
in real estate, securities (such as common stocks, bonds, limited partnership, no-load and loaded
mutual funds) and/or other miscellaneous investments offered through Custodians or firms who will
act as Custodian for the Adviser’s clients.
For non-discretionary accounts, the Adviser will consult with the clients prior to effecting any
transactions in their account(s).
Transactions in the clients’ accounts, generally, will be affected independently, unless the Adviser
decides to purchase or sell the same securities for several clients at approximately the same time.
The Adviser may (but is not obligated to) combine or “batch” such orders to obtain the best
execution, to negotiate more favorable commission rates or to allocate equitably among the financial
planner’s clients the differences in prices and commissions or other transaction costs that might have
been obtained had such orders been placed independently. Under this procedure, transactions will be
averaged as to price and transaction cost and will be allocated among the Adviser’s clients in
proportion to the purchase and sale orders placed for each client account on any given day. The
annual asset management fee charged shall not exceed 2.00% plus the custodian account annual fees
and/or not-in-house portfolio manager’s fees, when applicable. Following is the current “Standard
Fee Schedule”:
1.00% of assets under management up to $1,000,000.
0.75% of assets under management from $1,000,000 up to $5,000,000.
0.50% of assets under management from $5,000,000 up to $10,000,000.
0.25% of assets under management in excess of $10,000,000.
The client authorizes payment of the fees directly to the Adviser from the account upon presentation
of a letter of instruction or Advisory Agreement signed by the client and submitted to the custodian.
Fees are billed in arrears for each calendar quarter based upon the value of the portfolio (including
cash or its equivalent) (a) at inception, or (b) at the last day of the calendar quarter directly
proceeding the quarter to which such a fee relates to. Valuations on listed securities shall be the last
sale price, or if no sale occurred, then the mean between the bid and ask price. Unlisted securities
will be valued at the bid price and cash, if any, at principal amount. Securities, which do not have an
ascertainable market price, shall be valued at cost. In the event that this Agreement is terminated as
hereinafter provided, the portfolio shall be valued as of the later of the termination date or final
settlement date of all outstanding transactions. The final fee shall be paid by the Client based upon
that valuation and will be pro-rated from the beginning of the related quarter to such date. The
Adviser at his/ her own discretion may discount such a fee. Also, such predetermined and agreed
upon fee between the Financial Planner and the client may be offset and/or reduced by commissions
and 12(b)-1 distribution fees realized by the Adviser on commissionable products relating to client
investment portfolio under the Financial Planner’s management. Such an agreement relating to
offsetting and/or reducing the annual fees that are based on the clients’ assets under management
shall be executed in writing before entering into a commissionable transaction with the client. No
commissions, whether at placement (initial) or in the form of renewals, which are received from the
sale of insurance products (whether variable or fixed) shall offset or reduce the annual fees that are
based on the clients’ assets under management. However, managing the sub-accounts in a variable
or securities-based life insurance policy shall fall under the definition of “assets under management”
as noted herein. The Adviser may access the amount of idle cash in the client’s account(s) and
exclude such amount for the purpose of calculating the investment advisory fees.
The fourth (4) form of compensation is commissions realized from the sale of financial and/or
insurance products. In the event that a client decides to purchase commissionable financial
products and/or insurance products, the planner may, at his sole and absolute discretion, waive his
fees, either partially or totally, for the services rendered and explained herein. Also, the Adviser may
allow compensation realized from the sale of commissionable insurance products and/or 12(b)-1
distribution fees, if any, to reduce the flat fee and/or the hourly fee and/or the fees for assets under
Item 5.
management that would be otherwise payable to the financial planner for services rendered as
explained herein. Any action by the Adviser as such shall be relayed to the client in writing. There
shall be no refund of such credits to the client in the event of early termination of the Advisory
Agreement mentioned herein.
Financial and/or investment and/or insurance proposals and/or compensations shall include, but are
not limited to, sales presentation of products such as asset-based management and/or mutual funds
and/or annuities and/or life and health insurance including any securities-based life insurance
products and/or disability income insurance and/or securities and/or obligations.
Typically, no waiver of fee(s) shall be given to a client for the time spent by the adviser to produce a
financial plan analysis and/or an estate plan analysis and/or a summary of assets and/or any related
future projections and/or any life or health insurance proposals, including any securities-based life
insurance products, and/or disability income insurance. However, based on the financial planner’s
sole and absolute discretion, the client shall be informed in writing concerning the Adviser’s
decision to waive and/or reduce such fees in regard to this fourth form of compensation.
Terms of the Agreement:
The Client shall have the option to terminate the Agreement in its entirety, exercisable at the
Client’s sole option and without incurring any fee, for five days from the date of the Client’s signing
of this Agreement. Any investment action taken by the Adviser with respect to the account during
such five-day period in reliance upon this Agreement and prior to receipt of actual notice of the
Client’s exercise of this right of termination, shall be at the sole risk of the Client.
The agreement may be terminated for any reason by any party effective upon receipt of written
notice of such termination by the parties. If the Client is an individual, this Agreement shall be
terminated upon the Adviser’s receipt of written notice of death or legal incapacity of the Client
unless the account owner(s) have had a pre-determined distribution provisions for the account(s)
and/or had assigned a successor owner(s). Such pre-determined distribution provisions and/or the
existence of a successor owner(s) shall render this agreement in full force and effect until the
distributions are concluded and/or such successor owner(s) informs the Adviser in writing of such
termination. There will be no refund of any fees or portions of such fees paid by the client since fees
are charged by the Financial Planner for services rendered, i.e., in arrears. However, the client shall
be liable for fees that are due to the Adviser for services rendered during the quarter calculated on a
pro-rata basis (per day). For any fees that are paid in advance, the client(s) will be refunded any
unearned fees, calculated on a pro-rata basis, no later than the following quarterly billing cycle.
(1) A charge of $200.00 per hour to prepare a financial and/or estate plan analysis and $150.00 per
hour for all other advisory and administrative services plus expenses. Expenses include, but are not
limited to, postage charges, copying costs, and fees charged by others pertaining to each case. The
Adviser reserves the right to negotiate a dollar value cap when charging the Client on an hourly
basis.
(2) A flat fee to prepare a financial and/or estate plan analysis and to perform advisory and
administrative services. This fee is negotiable depending on the size and complexity of each case.
Other expenses, as per item (1) above, may be inclusive or exclusive of the flat fee depending on
size and
complexity of each case. The client shall be informed in writing concerning the Financial Planner's
decision to include or exclude such fees from the quoted flat fee.
(3) Compensation from commissions realized from the sale of financial and/or insurance products.
In the event that a client decides to purchase commissionable financial and/or insurance products,
the Financial Planner may, at his sole and absolute discretion, waive his fee, as referenced herein
under “Fees and Compensation”, either partially or totally before entering a commissionable
transaction with the client. Any action by the Financial Planner, as outlined above, shall be relayed
to the client in writing.
(4) A Fee based on a percentage of the Client’s Assets Under Management as per the Fee Schedule
listed in the Investment Advisory Agreement executed between the Financial Planner and the Client.
Item 5.
Clients must be aware that advisory fees paid to Washington Financial Group, Inc. and/or Humam
K. Sirhal are separate and distinct from fees and expenses paid to a mutual fund company (ies)
and/or an annuity company (ies) and/or limited partnership(s) and/or unit investment trusts and/or
other Investment Advisory firm(s) and/or Separately Managed Accounts manager(s) and/or Broker-
Dealer of record and/or Custodian of record. A description of the fees and expenses of mutual funds
and/or annuities and/or limited partnerships may be found in the prospectus for those investments.
By signing an Investment Advisory Agreement, the client(s) authorize(s) any such “Custodian(s)” to
pay Advisory Management fees directly to the Authorized agent(s) and/or Adviser(s). The client(s)
authorize(s) such Custodians to pay the Authorized agent(s) and/or Adviser(s) from his/her/their
account(s). Those Custodians may use the money from the core transactions in the account(s) and/or
cash in the account(s) to the extent necessary to pay such fees. The Custodians shall rely on the fee
calculation submitted by the Authorized agent(s) and/or Adviser(s) to them in order to process the
deduction from the client(s) account(s). The client(s) understands that it is his/her/their
responsibility to verify the accuracy of the fee calculation and that the Custodians will not determine
whether the fee is properly calculated. The client(s) indemnifies and hold the Custodians, including
the WFG and the Broker-Dealer of record, if any, and its directors, employees and control persons
harmless from all liabilities and costs, including attorney’s fees that the Custodian may incur by
relying upon the Authorized agent(s) and/or the Adviser(s) representations in regard to the above
authorization.
The Custodians and/or Authorized agent(s) and/or Adviser(s) and/or the client(s) may terminate any
fee deduction authorization at any time by giving written notice to the others, but such termination
shall not affect any obligation or liability arising prior to termination. This agreement may be
modified or amended only pursuant to a written agreement signed by the above-mentioned parties.
The Adviser accepts compensation for the sale of securities or other investment products from
mutual funds and/or annuity and/or limited partnership companies. For those accounts that are
bound by the Investment Advisory Agreement, the Adviser will credit back to the Client such
compensation, such as 12(b)-1, in order to alleviate any conflict of interest(s). However, additional
provisions apply to those accounts holding “Institutional Class” mutual fund shares, as follows: Any
Buy and/or Sell and/or Exchange trading charges necessary to implement the Adviser’s proposed
investment strategy will be charged to the client account(s) at the Adviser’s cost. Such charges
affect new deposit(s), new transfers-in, and existing holdings that are in cash and/or in securities
and/or in any accounts that hold such institutional class mutual fund shares. Institutional class
mutual fund shares, compared to Class A shares, are not subject to any “sales load”, do not pay “12-
b fees” and have a lower annual “Expense Ratio” cost. Any “Unsolicited” trading charges and trades
for “Tax Harvesting” for losses or gains shall also be charged, if applicable, separately to the client
at the Adviser’s cost. Those securities typically include, but are not limited to, open and/or closed-
end mutual funds, unit investment trusts, annuities, stocks and bonds. Certificate of Deposit ticket
charges, buy and sell, will also be charged to the Client at the Adviser’s cost.
Unsolicited securities that are held in the account shall be monitored, periodically, assessed and
shall fall under the definition of “assets under management” as explained herein, unless they are
explicitly excluded. If so excluded, the Adviser shall inform the Client in writing in regard to that
exclusion.
Mr. Humam K. Sirhal receives economic benefit from WFG, as noted in this Item.
When, and if applicable, Ms. Laura E. Sirhal might receive economic benefit from WFG as noted in
in this Item, including compensation realized from her accounting services that she provides to
WFG.
Appointments that are cancelled by the client and/or prospective client without 24-hour notice for
the Financial Planner shall be billed at the minimum charge of $150.00.
Item 6. Performance-Based Fees and Side-By-Side Management:
The Adviser does not accept and/or engage in Performance-Based Fees and/or Side-By-Side
Management of investible assets.
Item 7. Types of Clients:
The Adviser provides investment strategies and implementation of those strategies to a broad array
of individual clients and Trust accounts.
When fees are charged by the Financial Planner based on a percentage of assets-under-management,
the account size must preferably satisfy a minimum requirement of two hundred and fifty thousand
dollars ($250,000). The Adviser, however, does reserve the right to negotiate the minimum account
size down to any level.
Item 8.
Methods of Analysis, Investment Strategies and Risk of Loss:
The financial planner provides a variety of securities-related services which may include other
incidental investment advice; please refer to Item 4. Also, the financial planner deals with
Separately Managed Accounts programs offered directly through the Adviser or through other
introducing brokers and/or custodians.
The Adviser may perform various techniques in analyzing investments for advisory clients which
may include, but are not limited to, charting, fundamental analysis, technical analysis, cyclical
analysis, and dollar cost averaging. The client is advised that there is no guarantee, stated or implied,
that the client’s investment goals or objectives will be achieved. Investing in securities, including
but not limited to REITs, involves a risk of loss that clients should be prepared to bear. As a result of
this inherent risk the Adviser cannot represent, guarantee, or even imply that his/her services and
methods of analysis can accurately forecast future returns, accurately identify market highs and
lows, or protect investors from investment losses as a result of economic downturns and market
corrections.
All methods of analysis and investment strategies involve some material risks, including the risk of
loss. Some of the material risks involved in charting and technical analysis include the potential for
a lack of consideration given to the intrinsic value of specific investments. Technical analysis and
charting focus primarily on economic factors and market conditions, which may overlook variables
specific to a particular investment. Conversely, fundamental analysis generally focuses on more
specific variables, such as public companies’ financials, sales, earnings, debt, management, and
assets. As a result, fundamental analysis includes the risk of not taking into consideration the overall
state of the economy and markets. Cyclical analysis is also subject to material risks, which include
uncertainty over how long cycles will last, when they will peak and when they will reach a bottom.
The Adviser manages portfolios based on a dynamic asset allocation model with overweightings in
sectors or investment styles or cash positions that he/she believes will be in-favor during the next
twelve to eighteen months. Such holding periods combined with the asset allocation approach tend
to lessen risk and do not employ frequent trading. The Adviser employs the same process in electing
fund managers and Third-Party Managers (TPM). Such a method does not involve significant or
unusual risks and neither does it involve frequent trading of those mutual funds or TPM’s portfolios.
The Adviser’s method is still asset-allocation based.
In more details, the Adviser select those mutual fund managers or Third-Party Managers to allocate
into the clients’ portfolios based on the following:
1. Review of the Manager’s Firm Form ADV to include, but not limited to, material changes
to the firm’s Form ADV, current AUM and years of experience in managing assets.
2. Recent changes in the management of the portfolio.
3. Investment Style and/or Sector Orientation and any recent style shifts. Risk-Return
Statistics: Standard Deviation, Sharpe Ratio, Alpha, Up & Down Capture, Total Return to
included Best & Worse Quarters and Best and Worse Years.
4. Risk statistics: Active Return, Batting Average, Beta, Tracking Error, R Squared.
5. Performance: Year-to-Date Return, 1, 3, 5 & 10-years average and/or Since Inception.
Item 8.
6. Portfolio Characteristics:
For Equities: Average Market Cap, Adjusted Price/ Earnings Ratio, Return in Equity (1
yr.), Current Yield.
For Fixed Income: Average Coupon, Average Credit Quality, Average Effective Duration
and Average Effective Maturity.
7. Equity & Fixed Income Sector Distribution.
8. Fixed Income Maturity Distribution: 1-3 years, 3-5 years, 5-7 years and 7-10 years.
9. Fixed Income Credit Quality Distribution: AAA, AA, A, ….
10. Top Ten Holdings.
The Adviser relies heavily on the preliminary due diligence that is provided by Envestnet, LLC. and
Schwab Institutional in selecting the first tier of Third-Party Managers. Schwab and/or Envestnet
Portfolio Manager Selection & Evaluation methods shall be provided upon request.
The majority of investment recommendations made by the Adviser involve the use of mutual funds.
Investing in mutual funds involves material risks, including the risk of loss. Such material risk could
be the cost of sales charges, annual fees and other expenses that impair the fund’s performance.
Another risk is the potential for tax implications as a result of income and capital gains distributions.
Investors may have to pay taxes on these distributions even if the fund went on to perform poorly
after shares were purchased. Lack of control is also a risk that investors encounter. Investors and
Advisers typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor
can they directly influence which securities the fund manager buys and sells or the timing of those
trades.
Another risk is price uncertainty. Mutual fund investors face this risk because the price at which
shares are purchased and sold is based on the fund’s net asset value, which may not be calculated
until many hours after the transaction has already been processed. Clients should read a fund's
prospectus and shareholder reports to learn about its investment strategy and the potential risks. For
additional information on investing in mutual funds, we recommend reviewing the SEC’s Invest
Wisely, An Introduction to Mutual Funds, which can be found at the following Web site:
www.sec.gov/investor/pubs/inwsmf.htm#pitfalls
Some of the common risks that investors should consider prior to investing, in general, include, but
are not limited to:
Market risks: The prices of, and the income generated by, the common stocks, bonds, and other
securities that the client owns may decline in response to certain events taking place around the
world, including, but not limited to, those events directly involving the issuers, certain conditions
affecting the general economy, overall market changes, local, regional, or global political and social
and economic instability, governmental or governmental agency responses to economic conditions,
currency, interest rate, and commodities price fluctuations.
Company risks: When investing in stock positions, there is always a certain level of company or
industry-specific risk that is inherent in each investment. This is also referred to as “unsystematic
risk” and can be reduced through appropriate diversification. There is the risk that a company will
perform poorly or have its value reduced based on factors specific to that company or its industry.
For example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of that company may be reduced.
Options risks: Options on securities may be subject to greater fluctuations in value than an
investment in the underlying securities. Purchasing and writing put and call options are highly
specialized activities and entail greater than ordinary investment risks.
Credit risks: Debt securities are also subject to credit risk, which is the possibility that the credit
strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely
Item 8.
payments of principal and/or interest which might lead that security to go into default.
Foreign market risks: Investments in securities issued by entities based outside the United States
may be subject to the same risks described above but to a greater extent. Investments may also be
affected by currency controls, different accounting, auditing, financial reporting, disclosure, and
regulatory and legal standards and practices, expropriation (occurs when governments take away a
private business from its owners), changes in tax policy, greater markets volatility, different
securities market structures, higher transaction costs and various administrative difficulties such as
delays in clearing and settling portfolio transactions or in receiving payment of dividends.
Interest Rate Risk: This is a very common risk of debt Mutual Funds. As we know, a change in
interest rates leads to a change in bond prices. There is an inverse relationship between bond price
and Interest rate. Whenever Interest rates fall Bond Prices rise. Accordingly, an increase in Interest
rates reduces the Bond prices. The Interest Rate risk is associated with the fluctuation of Interest
Rate which typically changes the price of a Bond that an Investor is holding. An investor should be
aware, before investing in Debt mutual funds. The wrong prediction of Interest Rate fluctuation may
lead to a loss. For long-term investment, a falling interest rate typically will be very profitable for
debt mutual fund holders. Similarly, an increase in Interest rates will lead to a loss for long-term
debt mutual fund investors. In addition, falling interest rates may cause an issuer to redeem, “call,”
or refinance a security before its stated maturity date, which may result in having to reinvest the
proceeds in lower-yielding securities. Those risks may be heightened in connection with
investments in developing countries. Investments in securities issued by entities domiciled in the
United States may also be subject to many of these risks.
Your investments are not bank deposits and are not insured or guaranteed by the FDIC or any other
governmental agency, entity, or person, unless otherwise noted and explicitly disclosed as such, and
as such may lose value.
Item 9. Disciplinary Information:
As of the date of this Brochure, neither WFG nor any supervised person(s) have any legal, civil,
regulatory, or disciplinary events to disclose. We have not been involved in any criminal, civil
action, administrative enforcement proceedings, or arbitration claims related to past or present
“Client(s)” or “Prospective Client(s)." Please visit Investor.gov/CRS or the SEC’s Investment
Adviser Public Disclosure database at www.adviserinfo.sec,gov for free and simple search tools to
research our firm and our financial professionals.
Other Financial Industry Activities and Affiliations:
Item
10.
The Adviser and/or “associated persons” may recommend a Broker-Dealer for traditional brokerage
services. The Adviser and/or “associated persons” do not determine the commission rates.
The Adviser offers insurance products through various companies and may receive compensation.
The Financial Planner may also receive additional compensation in the form of 12(b)-1 distribution
fees as a result of the sale of certain investment company’s products to his/her advisory clients.
Those 12b (1) will be credited towards the advisory fees due by the client to the Adviser.
The Financial Planner may introduce clients to various investment advisers and timing services
firms and managers, who may use other investment strategies that shall be fully disclosed in the
sponsor’s offering material and disclosure documents.
The Financial Planner may accept incentive rewards except when prohibited by law, rules, or
regulations.
As of the date of this Brochure, neither the Adviser nor its Representative have any affiliation with a
Broker-Dealer. The Adviser and/or its Representatives have an affiliation with Charles Schwab &
Co., Inc., Envestnet Asset Management, Inc. Lincoln Financial Group and Guardian Life.
Code of Ethics:
Item
11.
Principles of the Code of Ethics:
To provide competent and customer-focused sales and services.
To engage in active and fair competition.
To maintain privacy of Client’s personal and financial information.
A copy of the “Code of Ethics” manual and any sub-sequent amendments, if any, had been provided
to each supervised person and its receipt had been acknowledged in writing.
PRINCIPLES OF ETHICAL MARKET CONDUCT
With respect to our principles of ethical market conduct in all matters affecting the sale of
individually sold life insurance, long -term care insurance and annuity products, WFG pledges:
ONE
To conduct business according to high standards of honesty and fairness and to render services to
our customers which under the same circumstances we would apply to, or we demand for ourselves.
TWO
To provide competent and customer-focused sales and service.
THREE
To engage in active and fair competition.
FOUR
To provide advertising and sales material that is clear as to purpose, honest and fair as to its content.
FIVE
To provide fair and expeditious resolution of customer complaints and disputes.
SIX
To maintain a system of supervision and review that is reasonably designed to achieve compliance
with those Principles of Ethical Market Conduct.
PRINCIPLE 1: Honesty and Fairness
To conduct business according to high standards of honesty and fairness and to render services to
our clients which in the same circumstances we would apply to, or demand for ourselves.
Code of Conduct
individual products or
those marketed on an
individual basis are
Insofar as
concerned, we will make reasonable efforts to determine the insurable needs and/or
financial objectives of each client, based upon relevant information obtained from the client.
We will enter into transactions which assist the client in meeting his/her insurable needs
and/or financial objectives.
We will implement policies and procedures to maintain compliance with all applicable
Statutes and Regulations by which WFG is bound by.
We will affirmatively seek, in cooperation with the client, regulators, and others, to improve
the practices for the sales and marketing of investments and insurance products and/or other
related services.
Remarks
It is our belief that suitability can best be determined by a fact-finding process and/or risk tolerance
analysis, and we strongly recommend the use of such fact finders to determine the client’s needs
Item
11.
and/or investment objectives.
Most regulating authorities and/or States require the delivery of acknowledgement forms prior to or
at the time of completing a fact-finding process and/or a risk tolerance analysis and/or the sale of
securities and/or sales of insurance products.
PRINCIPLE 2: Client Focus
To provide competent and customer-focused sales and services.
Code of Conduct
We will take actions reasonably designed to determine good character, business repute,
qualifications, and experience of our affiliated representatives.
We will take such actions reasonably designed to provide the client with the needed
information to affirm that our representatives have successfully completed state examination
requirements and are duly licensed and/or otherwise qualified under state law.
We will take such actions reasonably designed to provide the client with the needed
information to affirm that our representatives and their field supervisors are adequately
trained to focus on customers’ needs and objectives.
We will take such actions reasonably designed to provide the client with the needed
information to affirm that our representatives are knowledgeable about the proposed
products and the operation of those products.
We will take such actions reasonably designed to provide the client with the needed
information to affirm that our representatives and/or field supervisors receive continuing
education in compliance with applicable SEC, FINRA and State’s Securities and Insurance
laws & regulations.
We will take such actions reasonably designed to provide the client with easy and direct
access to our representatives.
When recommending or buying securities for the Clients, the Adviser always trades into the Client’s
account first and then into his/her or any “related person’s” account. Thus, the Adviser and/or the
“related person” are always buying at an “up-tic”. In compliance with its Fiduciary Duty and SEC
Rule 204A-1, the Adviser is mandated to trade into the client’s account ahead of the Firm’s
accounts. Mutual Funds trades are excluded.
As the date of this brochure, the Adviser had no participation or interest in client(s) transactions.
Brokerage Practices:
Item
12.
In selecting other Investment Advisory firm(s) and/or Separately Managed Accounts manager(s)
and/or Broker-Dealers and/or Custodian, the Adviser looks for reasonable and competitive
execution charges and fees.
The Adviser has no “Soft Dollar Arrangements”.
Item
13.
Review of Accounts:
Financial and Estate Planning Services:
Reviews: Reviews are conducted as per the mutual agreement between the Adviser and the client(s).
The Financial Planner, at his sole and absolute discretion, may charge, or not charge, the client a
lump sum fee or an hourly fee for such services.
Frequency: At the request of the client, or whenever a change in family and/or financial
circumstances occurs.
Item
13.
Levels: (1) Minor adjustments to the existing financial plan if the financial situation and/or family
circumstances did not change. (2) Revamp the whole plan if major changes occur.
Triggering Factors: Change in financial circumstances and/or objectives such as the death of a
spouse and/or re-marriage and/or disinheriting an existing beneficiary (ies) and/or adding new
beneficiary(ies) and/or establishing living/ irrevocable/ charitable trusts and/or attempting to
enhancing the estate by protecting against long term disabilities and/or re-calculating potential estate
and death inheritance taxes due to an increase or decrease in the estate net worth.
The reports to the client(s) for such reviews are done in writing following the personal interview(s).
Investment Services:
Reviews: Reviews are conducted as per the mutual agreement between the Adviser and the client(s).
The Financial Planner at his sole and absolute discretion may charge or not charge the client a lump
sum fee or an hourly fee for his services.
Frequency: At the request of the client or whenever a change in family and/or financial
circumstances occurs.
Triggering Factors: Change in financial circumstances and/or objectives such as the death of a
spouse and/or re-marriage and/or implementation of a gifting program and/or the need for more or
less income and/or bearish market conditions.
The reports to the client(s) for such reviews are done:
By telephone for funds which the Adviser has established for the client(s).
In person and/or by telephone and/or by writing for all other accounts as per the written
agreement between the Adviser and the client(s).
Reviewers: 1. Humam K. Sirhal, IAR
Client Referrals and Other Compensation:
Item
14.
A. Other than the normal, usual and traditional compensation from fees, commissions,
renewals and 12(b)-1s, there is no entity that provides any economic benefit to the Adviser
for providing investment advice or other advisory services to his/her clients.
B. The Adviser compensates clients with occasional gifts not exceeding $250.00 per person per
year.
C. The Adviser may provide reasonable entertainment to such a person provided that both the
Adviser and the recipient are present and there is a business purpose for the entertainment. It
is anticipated that the Adviser will not entertain the same person more than four times per
year or spend more than $250 per person on business meals on such occasions.
All other compensation schedules shall include a solicitation agreement that abides by U.S. SEC
regulations and rule 206(4)-3. As of the date of this brochure, the Adviser has no active “Solicitation
Agreements”.
Custody:
Item
15.
The Adviser has limited custody of the Clients’ accounts represented in his/her authority to
withdraw advisory fees from those accounts. Any withdrawals of such funds shall be made in
writing from the Adviser to the qualified custodian(s). Please refer to Section 5. A, B, C, & D sub-
section “Terms of Agreement” for more details.
The qualified custodians do send clients confirmation statements and/or monthly statements and/or,
at minimum, quarterly statements which clearly show the deduction of advisory fees from their
account(s).
Investment Discretion:
Item
16.
The Adviser will establish “Discretionary” accounts for a client after both parties execute an
Investment Advisory Agreement.
Voting Clients Securities:
Item
17.
The Adviser does not vote proxies. All proxy voting is the responsibility of the client. Clients
receive their proxies or other solicitations directly from the custodian and/or the transfer agent.
None of the voting proxies are forwarded by the Adviser.
Financial Information:
Item
18.
A. The Adviser does not require or solicit an in-advance payment of more than $500 in fees per
client for a period of six months or more.
B. The Adviser has no custody of Client’s funds or securities other than what has been outlined
in Section 15 of this brochure.
Margin Agreement and Loan Consent:
Item
19.
On the subject of Margin, it is imperative that the client be advised of, and understand, the financial
impact of borrowing funds on Margin. By executing a “Margin Agreement and Loan Consent” the
client agrees to borrow funds from the custodian at a, then, prevailing interest rate which is
calculated daily on a pro-rata basis. An example of those rates, as posted by TDA Institutional, were
as follows:
Margin interest rates vary due to the base rate and the size of the debit balance. When setting base rates,
Shwab Institutional considers indicators like commercially recognized interest rates, industry conditions
related to credit, the availability of liquidity in the marketplace, and general market conditions:
Debt Balance
$500,000+
$250,000 - $499,999.99
$100,000 - $249,999.99
$50,000 - $99,999.99
$25,000 - $49,999.99
$0 - $24,999.99
Margin rate
Base Rate + 0.075%
Base Rate + 0.075%
Base Rate + 0.325%
Base Rate + 0.375%
Base Rate + 1.325%
Base Rate + 1.825%
Effective rate
10.075%
10.075%
10.325%
10.375%
11.325%
11.825%
Base rate = 10.00%. Schwab's base rate was last changed on 12/12/2025 and is subject to change
without notice.
Interest is charged every day if there is a debit balance in the account. The interest is calculated by multiplying
the applicable interest rate by the debit balance, divided by 360 (Interest Rate x Margin Debit / 360 = Daily
Interest Charge). This interest amount is calculated daily and posted to the account on a monthly basis.
The Adviser might decide to raise the cash from Margin in order to provide the clients with the
requested cash and/or to pay investment advisory fees. Typically, that happens when it is
unfavorable to redeem holdings in the client’s account(s) due to market conditions. Also, the
Adviser might decide to buy securities on Margin for the short term. The Adviser strives to flatten
that margin balance as soon as possible and as he/ she deems it beneficial to do so.
Disclosure
All the required disclosures for Form ADV Part 2B Supplement are contained in the text of
this document