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Item 1 Cover Page
We Financial Group LLC
Firm CRD# 298549
Form ADV Part 2A – Disclosure Brochure
April 16, 2026
447 Sutter Street, Suite 506 - 1943
San Francisco, CA 94108
Phone: 415-994-9767
www.wefinancialgroup.us
This brochure provides information about the qualifications and business practices of We Financial
Group LLC. If you have any questions about the contents of this brochure, please contact us at (415) 994
9767.
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. Registration as a registered investment
advisor does not imply a certain level of skill or training.
Additional information about We Financial Group LLC, CRD #298549 also is available on the SEC’s website
at www.adviserinfo.sec.gov.
Item 2 Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an
Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information
about advisory personnel of We Financial Group.
We Financial Group believes that communication and transparency are the foundation of its relationship
with clients and will continually strive to provide its clients with complete and accurate information at
all times. We Financial Group encourages all current and prospective clients to read this Disclosure
Brochure and discuss any questions you may have with us. And of course, we always welcome your
feedback.
Material changes: We Financial Group LLC has updated its principal place of business address. Please see
Item 1 for details.
Future Changes
From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations and routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if
a material change occurs in the business practices of We Financial Group.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov.
Item 3 Table of Contents
Item 1 Cover Page
1
Item 2 Material Changes
2
Item 3 Table of Contents
3
Item 4 Advisory Business
4
Item 5 Fees and Compensation
7
Item 6 Performance-Based Fees and Side-by-Side Management
9
Item 7 Types of Clients
9
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
9
Item 9 Disciplinary Information
15
Item 10 Other Financial Industry Activities and Affiliations
15
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
16
Item 12 Brokerage Practices
17
Item 13 Review of Accounts
20
Item 14 Client Referrals and Other Compensation
21
Item 15 Custody
23
Item 16 Investment Discretion
23
Item 17 Voting Client Securities
23
Item 18 Financial Information
23
Item 4 Advisory Business Description of Advisor Firm.
We Financial Group is a Limited Liability Company that was formed as of April 12, 2018, and is registered
as an Investment Adviser with the Securities Exchange Commission as of January 2025. Registration does
not imply a certain level of skill or training. The principal owner of the firm is Guillaume Decalf, President.
The firm offers financial consulting and discretionary investment advisory services to individuals. For a
more complete description of these services see Item 4B.
Types of Advisory Services
Investment Management Services
We are in the business of managing investment portfolios. 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 may
also review and discuss a client’s prior investment history, as well as family composition and background.
For further information please refer to Items 8 and 16 of this brochure.
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 tax considerations. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors. Unmanaged client
assets will not be included in the management fee calculation. For further information please refer to
Item 5 of this brochure.
Investment Management Services - Selection of Other Advisers
When suitable for the client, We Financial Group may direct clients to third-party investment advisers
(outside managers/sub-advisers). Before selecting other advisers for clients, We Financial Group will
verify that all recommended advisers are properly registered notice filed or exempt in the states where
We Financial Group is recommending the adviser to clients. We Financial Group and the client will work
together to develop an investment strategy that aligns with the client’s IPS, while the third-party adviser
actively trades, rebalances accounts, and manages tax-loss harvesting. In addition, annual due diligence
is executed to ensure outside managers are in compliance with all contractual provisions between We
Financial Group and its clients.
SEEDS INVESTOR LLC (CRD # 308909/SEC # 801-124693)
When suitable for clients, We Financial Group will recommend Seeds Investor LLC to manage assets. Seeds
was started in 2019 by Zach and Michael Conway, financial advisors who needed technology and tools
necessary to serve a fast-evolving client base. Seeds Investor is a Registered Investment Advisor ("RIA"),
located in the State of New York. Seeds provides investment advisory and related services for clients
nationally. Seeds will maintain all applicable registration and licenses as required by the various states in
which Seeds conducts business, as applicable. Seeds renders individualized responses to persons in a
particular state only after complying with all regulatory requirements, or pursuant to an applicable state
exemption or exclusion.
SyntheticFi LLC (CRD # 330200/SEC # 801-129765)
We Financial Group may also recommend SyntheticFi products when suitable for clients. SyntheticFi is an
SEC-Registered Investment Advisor located in the State of California and primarily focuses on the use of
options as an alternative borrowing strategy. SyntheticFi will maintain all applicable registration and
licenses as required by the various states in which SyntheticFi conducts business, as applicable.
Estate Planning
We offer Estate Planning services for our clients to assist with general information as it applies to reviews
of existing plans, gathering information needed to provide outside firms in the creation of documents,
and updating existing plans for clients.
The fees associated with estate planning related services are separate and in addition to your ongoing
financial planning or advisory fees and are disclosed in Item 5. Depending on the client's needs and desires
for estate planning document review, preparation, or updates, we will engage with EncorEstate Plans, a
third-party scrivener service, or estate planning attorneys.
Financial Planning
We provide financial planning services on topics such as retirement planning, risk management, college
savings, cash flow, debt management, work benefits, and estate and incapacity planning. Financial
planning is a comprehensive 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 or an electronic 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 any or all of the following areas of concern. The client and
advisor will work together to select the specific areas to cover. These areas may include, but are not
limited to, the following:
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
the desired amount.
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.
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.
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.
Educational Workshops
We provide educational seminar sessions involving personal finance and investing. Topics may include
issues related to general financial planning, educational funding, estate planning, retirement strategies, and
various other current economic or investment topics. Our workshops are educational in nature and do not
involve the solicitation of insurance or investment products.
Clients Tailored Services and Client Imposed Restrictions
We Financial Group will tailor its advisory services to its client’s individual needs based on meetings and
conversations with the client. If clients wish to impose certain restrictions on investing in certain
securities or types of securities, the Advisor will address those restrictions with the client to have a clear
understanding of the client’s requirements.
Wrap Fee Programs
We Financial Group does not provide portfolio management services to wrap fee programs.
Assets Under Management
As of December 31, 2025, We Financial Group has $127,435,763 in discretionary assets under
management and no non-discretionary assets under management. Assets under management are
referred to third-party investment advisers with the exception of 401ks.
Item 5 Fees and Compensation
Method of Compensation and Fee Schedule and Client Payment of Fees
Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing
the investment advisory contract, the investment advisory contract may be terminated by the client
within five (5) business days of signing the contract without incurring any advisory fees (without penalty).
How we are paid depends on the type of advisory service we are performing. Please review the fee and
compensation information below.
Investment Management Services
Our standard advisory fee is based on the market value of the assets under management and is calculated
as follows:
$5,000 + 0.7% of the AUM with a maximum of 2%.
The annual fee of $5,000 + 0.7% is prorated and paid in arrears on a quarterly basis. The advisory fee is
a tiered fee and is calculated by assessing the percentage rates using the predefined levels of assets as
shown in the above chart and applying the fee to the account value based on the average daily balance
of the account during the previous quarter. No increase in the annual fee shall be effective without
agreement from the client by signing a new agreement or amendment to their current advisory
agreement. Clients with multiple accounts will automatically be combined and billed as a household to
receive a lower tiered fee schedule. We Financial Group and its third party may recommend stocks,
bonds, mutual funds or Exchange traded funds. Unmanaged or static client assets will not be included in
the Adviser’s management fee calculation. For partial billing periods the fee will be prorated based upon
the number of days the account was open during the billing period. All advisory fees are negotiable.
Lower fees for comparable services may be available from other sources.
Advisory fees are directly debited from client accounts, or the client may choose to pay by electronic
transfer. For fees paid by electronic funds transfer, we use an independent 3rd party payment processor
in which the client can securely input their banking information and pay their fee. We do not have access
to the client’s banking information at any time. The client will use their own secure portal in order to
make payments. Accounts initiated or terminated during a calendar quarter will be charged a prorated
fee based on the amount of time remaining in the billing period. An account may be terminated with
written notice at least 30 calendar days in advance. Should the client terminate the relationship with the
Adviser before We Financial Group completes the client’s written financial plan or analysis, We Financial
Group will deliver completed portions of any documents to the client. Since fees are paid in arrears, no
rebate will be needed upon termination of the account.
Note: For clients invested in ultra short-term bonds or equivalent, instead of being charged the
investment management fee listed above, there is a fixed fee of 0.50% applied to the account. The assets
will be segregated into a separate account for the purposes of fee administration. Please see Item 8
below for risks associated with this security. Clients engaged in CitizenMint’s services will be charged an
additional flat fee of $400.
Clients engaging in SyntheticFi’s box spread loan are charged an additional fee of 0.2%. Total client fees
will not exceed 3% of assets under management when a third-party investment adviser is used.
Estate Planning (EncorEstate Plans)
The fees for estate planning will be determined based on the complexity of the planning services
needed.
Trust-based Plan: $1,990 (Deeds transfer may have additional fees).
The fees may be negotiable in certain cases, will be agreed to at the start of the engagement, and are
due at when the questionnaire is sent to the lawyers. We Financial Group will not bill an amount
above $500.00 more than 6 months or more in advance. This service may be terminated with 30
days’ notice. Upon termination of any agreement, the fee will be prorated and any unearned fee will
be refunded to the Client. Clients are not required to utilize any third-party products or services that
we may recommend, and they can receive similar services from other professionals at a similar or
lower cost.
Financial Planning (Hourly) - We Plan
Financial Planning will generally be offered on an hourly basis, at a fee up to $400 per hour paid in
arrears. At the conclusion of each hour working, an invoice is generated and provided to the client.
We Financial Group will not bill an amount above $500.00 more than 6 months or more in advance.
Fees for this service may be paid by electronic funds transfer. Fees for this service are negotiable.
Hourly fees are directly debited from client accounts, or the client may choose to pay by electronic
transfer. For fees paid by electronic funds transfer, we use an independent 3rd party payment
processor in which the client can securely input their banking information and pay their fee. We do
not have access to the client’s banking information at any time. The client will use their own secure
portal in order to make payments. Fees will be paid through “one- time payment” requests for each
billing period.
This service may be terminated with 30 days’ notice. Should the client terminate the engagement with
We Financial Group prior to the completion of the client’s written financial plan, the portion of the plan
that has been completed will be delivered to the client and no additional fees will be charged. Clients
that receive investment management services will receive financial planning at no additional cost.
Lower fees for comparable services may be available from other sources.
Educational Workshops
While certain webinar may be complimentary, workshop attendees may be assessed a fee ranging
from $50 to $50,000. Frequently these sessions will be paid by an event sponsor, such as an employer
or an association. The workshop fee, if any, will be announced in advance and will be determined by
the length of the event, the number and expertise of the presenters involved, and whether or not
educational materials are being provided. Payment is typically on the first day of the scheduled
workshop, unless the sponsor is to be invoiced based on an attendance roster.
Additional Client Fees Charged
All fees paid to We Financial Group for investment advisory services are separate and distinct from the
expenses charged by ETF or mutual funds. These fees and expenses are described in each fund’s
prospectus. These fees will generally include a management fee and other fund expenses. We Financial
Group and its Adviser or investment adviser representatives 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.
At no time will We Financial Group accept or maintain custody of a client’s funds or securities except
for authorized fee deduction. Client is responsible for all custodial, securities and brokerage execution
fees charged by the custodian and executing broker-dealer. The Advisors fee is separate and distinct
from the custodian and execution fees. See Item 12 Brokerage Practices, for further information of
brokerage and transaction costs.
Prepayment of Client Fees
There is no prepayment of client fees in any services listed above.
External Compensation for the Sale of Securities to Clients
Not applicable to We Financial Group or its supervised person.
Item 6 Performance-Based Fees and Side-by-Side Management
We Financial Group does not charge performance-based fees and therefore does not engage in side-by-
side management. This question is not applicable.
Item 7 Types of Clients and Minimum Account Size
We Financial Group services individuals and high net worth individuals.
We Financial Group does not require a minimum account size. Exceptions can be made on a case-by-case basis.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and
Investment Strategies
The Advisor utilizes fundamental, technical or cyclical analysis techniques in formulating investment
advice or managing assets for clients.
Fundamental analysis of businesses involves analyzing its financial statements and health, its
management and competitive advantages and its competitors and markets. Fundamental analysis is
performed on historical and present data but with the goal of making financial forecasts. There are
several possible objectives; to conduct a company stock valuation and predict its probable price
evolution; to make a projection on its business performance; to evaluate its management and make
internal business decisions and to calculate its credit risk. The risk assumed is that the market will fail to
reach expectations of perceived value.
Technical analysis is a method of evaluating securities by relying on the assumption that market data,
such as charts of price, volume and open interest can help predict future (usually short-term) market
trends. Technical analysis assumes that market psychology influences trading in a way that enables
predicting when a stock will rise or fall. The risk is that markets do not always follow patterns and relying
solely on this method may not work long term.
Cyclical analysis of economic cycles is used to determine how these cycles affect the returns of an
investment, an asset class or an individual company’s profits. Cyclical risks exist because the broad
economy has been shown to move in cycles, from periods of peak performance followed by a downturn,
then a trough of low activity. Between the peak and trough of a business or other economic cycle,
investments fall in value to reflect the uncertainty surrounding future returns as compared with the
recent past. The risks with this strategy are two-fold 1) the markets do not always repeat cyclical patterns
and 2) if too many investors begin to implement this strategy, it changes the very cycles they are trying
to take advantage of.
The investment strategies the Advisor will implement include long term purchases of securities held at
least for one year; short term purchases for securities sold within a year; trading of securities sold within
30 days, and short sales.
Clients need to be aware that investing in securities involves risk of loss that clients need to be prepared
to bear.
Investment Strategy and Method of Analysis Material Risks
The methods of analysis and investment strategies followed by We Financial Group are utilized across all
of the Advisors clients, as applicable. One method of analysis or investment strategy is not more
significant than the other as the Advisor is considering the client’s portfolio, risk tolerance, time horizon
and individual goals. However, the client should be aware that with any trading that occurs in the client
account, the client will incur transaction and administrative costs.
Security Specific Material Risks
The Advisor does primarily recommend that clients invest in exchange listed securities and/or mutual
funds. Every type of investment, including mutual funds, involves risk. Risk refers to the possibility
that you will lose money (both principal and any earnings) or fail to make money on an investment. A
fund's investment objective and its holdings are influential factors in determining how risky a fund is.
Reading the prospectus will help you to understand the risk associated with that particular fund.
Generally speaking, risk and potential return are related. This is the risk/return trade- off. Higher risks
are usually taken with the expectation of higher returns at the cost of increased volatility. While a
fund with higher risk has the potential for higher return, it also has the greater potential for losses or
negative returns. The school of thought when investing in mutual funds suggests that the longer your
investment time horizon is the less affected you should be by short-term volatility. Therefore, the
shorter your investment time horizon, the more concerned you should be with short- term volatility
and higher risk. Additionally, many investments require clients to be classified as accredited investors.
Accredited Investor status is described as follows:
A person or couple must meet one of the following specifications to be considered an accredited
investor:
●
Individual income of $200,000, or joint income of $300,000 for the last two years and expect
to earn the same amount or more in the current year
● Joint or individual net worth is above $1 million, excluding the primary residence
●
Individual is a general partner, executive officer, director or combination of these for the
entity issuing the unregistered securities.
Below is a list of some of the risks to consider when investing.
Call Risk. The possibility that falling interest rates will cause a bond issuer to redeem—or call—its high-
yielding bond before the bond's maturity date.
Country Risk. The possibility that political events (a war, national elections), financial problems (rising
inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a
country's economy and cause investments in that country to decline.
Credit Risk. The possibility that a bond issuer will fail to repay interest and principal in a timely manner.
Also called default risk.
Currency Risk. The possibility that returns could be reduced for Americans investing in foreign securities
because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk.
Income Risk. The possibility that a fixed-income fund's dividends will decline as a result of falling
overall interest rates.
Industry Risk. The possibility that a group of stocks in a single industry will decline in price due to
developments in that industry.
Inflation Risk. The possibility that increases in the cost of living will reduce or eliminate a fund's
real inflation-adjusted returns.
Interest Rate Risk. The possibility that a bond fund will decline in value because of an increase in
interest rates.
Leverage Risk. The possibility that using borrowed capital to increase investment exposure may
amplify both gains and losses. Leverage can magnify the effects of market movements, leading to
greater volatility and the potential for significant losses, even with small adverse changes in market
conditions.
Manager Risk. The possibility that an actively managed mutual fund's investment adviser will fail to
execute the fund's investment strategy effectively resulting in the failure of stated objectives.
Market Risk. The possibility that stock fund or bond fund prices overall will decline over short or even
extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and
other periods when prices fall.
Principal Risk. The possibility that an investment will go down in value, or "lose money," from the
original or invested amount.
Other general risks to consider when investing are:
Asset Class Risk. Securities in your portfolio(s) or in underlying investments such as mutual funds may
underperform in comparison to the general securities markets or other asset classes.
Concentration Risk. To the extent that We Financial Group recommends portfolio allocations that are
concentrated in a particular market, industry or asset class, your portfolio is susceptible to loss due to
adverse occurrences affecting that market, industry, or asset class.
Equity Securities Risk. Equity securities are subject to changes in value that are attributable to market
perception of a particular issuer or general stock market fluctuations that affect all issuers. Investments
in equity securities are more volatile than other types of investments.
Growth Securities Risk. Growth companies are companies whose earnings growth potential appears to
be greater than the market, in general, and whose revenue growth is expected to continue over an
extended period. Stocks of growth companies or “growth securities” have market values that are more
volatile than those of other types of investments. Growth securities typically do not pay a dividend, which
helps cushion stock prices in market downturns and reduce potential losses.
Issuer Risk. Your account’s performance depends on the performance of individual securities in which
your account invests. Any issuers performing poorly, causing the value of its securities to decline. Poor
performance is caused by poor management decisions, competitive pressures, changes in technology,
disruptions in supply, labor problems or shortages, corporate restructurings, fraudulent disclosures, or
other factors. Changes to the financial condition or credit rating of an issuer of those securities causes
the value of the securities to decline.
Management Risk. The performance of your account is subject to the risk that our investment
management strategy will not produce the intended results.
Market Risk. Your account will lose money over short periods due to short-term market movements and
over longer periods during market downturns. The value of a security declines due to general market
conditions, economic trends, or events that are not specifically related to the issuer of the security or to
factors that affect a particular industry or industries. During a general downturn in the securities markets,
multiple asset classes are negatively affected.
Political Risk. Government decisions can damage the value of your investments. Changes to social
security, benefits law, and tax law impact your financial decisions. Any foreign investments are impacted
by the decision of their local governments.
Market Trading Risks. Your investment account faces numerous market trading risks, including the
potential lack of an active market for investments held in your account and losses from trading in
secondary markets.
Passive Investment Risk. We Financial Group uses a passive investment strategy that is not actively
managed where we do not attempt to take defensive positions in declining markets.
larger market capitalizations
Larger Company Securities Risk. Securities of companies with
underperform securities of companies with smaller and mid-sized market capitalizations in certain
economic environments. Larger, more established companies might be unable to react as quickly to new
competitive challenges, such as changes in technology and consumer tastes. Some larger companies are
unable to grow at rates higher than the fastest growing smaller companies, especially during extended
periods of economic expansion.
Short Selling Risk. Short selling is highly risky. Short selling stocks generate unlimited losses while the
upside is capped, as the price of a stock can in theory rise infinitely but cannot drop below zero. Over the
long term, stock prices overall tend to rise rather than fall. As a result, short selling is against the overall
direction of the market. Shorting stocks also involves using borrowed money, which creates leverage
risk. This strategy is also subject to the risk of inaccurate timing. Even if the price of a stock falls
substantially eventually, the price could rise in the near term, leading to losses for the short sellers.
Tax Loss Harvesting. Tax-loss harvesting involves certain risks, including, among others, the risk that the
new investment could have higher costs than the original investment and could introduce portfolio
tracking error into your accounts.
Liquidity Risk. A security is not able to be sold at the time desired without adversely affecting the price.
Regulatory Risk. Changes in government regulations adversely affect the value of a security. An insufficiently
regulated industry or market might also permit inappropriate practices that adversely affect an investment.
Smaller Company Securities Risk. Securities of companies with smaller market capitalizations,
historically, tend to be more volatile and less liquid than larger company stocks. Smaller companies have
no or relatively short operating histories or be newly public companies. Some of these companies have
aggressive capital structures, including high debt levels, or are involved in rapidly growing or changing
industries and/or new technologies, which pose additional risks.
Small Firm Risk. We Financial Group is reliant on research from Wall Street’s leading firms—including
hedge funds—to help us in our investment decisions. In addition, we do not have the financial resources
that other, larger firms have to invest in market data systems or industry consultants to provide insight
on specific companies or industries in which we invest.
Exchange-Traded Funds (ETFs). ETFs are investment companies that are legally classified as open-end
mutual funds or UITs. However, they differ from traditional mutual funds, in particular, in that ETF shares
are listed on a securities exchange. Shares can be bought and sold throughout the trading day like shares
of other publicly traded companies. ETF shares trade at a discount or premium to their net asset value.
This difference between the bid price and the ask price is often referred to as the “spread.” The spread
varies over time based on the ETF’s trading volume and market liquidity and is generally lower if the ETF
has a lot of trading volume and market liquidity and higher if the ETF has little trading volume and market
liquidity. Although many ETFs are registered as an investment company under the Investment Company
Act of 1940 like traditional mutual funds, some ETFs, in particular those that invest in commodities, are
not registered as an investment company.
Exchange-Traded Notes (ETNs). An ETN is a senior unsecured debt obligation designed to track the total
return of an underlying market index or other benchmark. ETNs are be linked to a variety of assets, for
example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are
listed on an exchange and can be bought or sold throughout the trading day. However, an ETN is not a
mutual fund and does not have a net asset value; the ETN trades at the prevailing market price. Some of
the more common risks of an ETN are as follows. The repayment of the principal, interest (if any), and
the payment of any returns at maturity or upon redemption are dependent upon the ETN issuer’s ability
to pay. In addition, the trading price of the ETN in the secondary market is adversely impacted if the
issuer’s credit rating is downgraded. The index or asset class for performance replication in an ETN may
or may not be concentrated in a specific sector, asset class or country and therefore carry specific risks.
It is important to note that no methodology or investment strategy is guaranteed to be successful or
profitable. Investing in securities involves the risk of loss that clients should be prepared to bear.
BOXX ETF: The Alpha Architect 1-3 Month Box ETF (the “Fund”) seeks to provide investment results that,
before fees and expenses, equals or exceeds the price and yield performance of an investment that tracks
the 1-3 month sector of the United States Treasury Bill market. Alpha Architect 1-3 Month Box ETF (the
“Fund”) is an actively managed exchange-traded fund (“ETF”) whose investment objective is to provide
investment results that, before fees and expenses, equal or exceed the price and yield performance of
an investment that tracks the 1-3 month sector of the United States Treasury Bill market. To do so, the
principal investment strategy of the Fund will be to utilize an exchange-listed options strategy called a
box spread (“Box Spread”). In order to accomplish its investment goals, the Fund may utilize either
standard exchange listed options or FLexible EXchange® Options (“FLEX Options”) or a combination of
both.
In general, an option contract is an agreement between a buyer and seller that gives the purchaser of
the option the right to buy or sell a particular asset at a specified future date at an agreed upon price,
commonly known as the “strike price.” In the case of a “call option”, the purchaser has the right to buy
the particular asset and the seller of a “call option” has the obligation to deliver the particular asset at
the strike price. In the case of a “put option”, the purchaser has the right to sell the particular asset and
the seller of a “put option” has the obligation to deliver the particular asset at the strike price. A Box
Spread is the combination of a synthetic long position coupled with an offsetting synthetic short position
through a combination of options contracts on an equity security or an equity index at the same
expiration date. The synthetic long consists of buying a call option and selling a put option on the same
security or index where the call option and put option share the same strike and expiration date (a
“Synthetic Long”).
When purchasing a Box Spread, the Synthetic Long will have a strike price that is less than the strike price
for the Synthetic Short. The difference between the strike prices of the Synthetic Long and the Synthetic
Short will determine the expiration value (or value at maturity) of the Box Spread. The synthetic short
consists of buying a put option and selling a call option on the same security or index with the same
expiration date as the synthetic long but using a different strike price (a “Synthetic Short”). When
purchasing a Box Spread, the Synthetic Long will have a strike price that is less than the strike price for
the Synthetic Short. The difference between the strike prices of the Synthetic Long and the Synthetic
Short will determine the expiration value (or value at maturity) of the Box Spread. An important feature
of the Box Spread construction process is the elimination of risk tied to underlying market movements
associated with the underlying option’s security or equity index. As displayed in the diagram below, the
Box Spread return stays constant no matter how low or how high the underlying option’s security or
equity index price moves. Once the Box Spread is initiated, its return from the initiation date of such Box
Spread through its expiration date will generally not change.
Item 9 Disciplinary Information
Clients need to be aware that neither We Financial Group nor its management person have had any legal or
disciplinary events, currently or in the past.
Item 10 Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration
We Financial Group is not a broker-dealer nor is its management person a registered
representative of a broker- dealer.
Futures or Commodity Registration
We Financial Group does not have an application pending as a futures commission merchant, commodity
pool operator, or a commodity trading advisor, or as an associated person of the foregoing entities.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
We Financial may recommend that clients receive money coaching services provided by The Savvy Life.
We Financial does not receive compensation for referring clients to this third party, and clients are not
obligated to use the services of The Savvy Life.
We Financial Group does not currently have any other relationships or arrangements that are material to
its advisory business or clients with either a broker-dealer, municipal securities dealer, or government
securities dealer or broker, investment company or other pooled investment vehicle (including a mutual
fund, closed-end investment company, unit investment trust, private investment company or “hedge
fund” and offshore fund, futures commission merchant, commodity pool operator, or commodity trading
advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance
company or agency, pension consultant, real estate broker or dealer or sponsor of syndicator of limited
partnerships.
Recommendation or Selection of Other Investment Advisers and Conflicts of Interest
As referenced in Item 4 of this brochure, We Financial Group recommends Clients to Outside Managers to
manage their accounts. In the event that we recommend an Outside Manager, please note that we do not
share in their advisory fee. Our fee is separate and in addition to their compensation (as noted in Item 5)
and will be described to you prior to engagement. You are not obligated, contractually or otherwise, to use
the services of any Outside Manager we recommend. Additionally, We Financial Group 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
Code of Ethics Description
We Financial Group has adopted as an industry best practice a Code of Ethics. We Financial Group has
adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all managers, officers, and
employees of the adviser. In addition, the Code of Ethics governs personal trading by each employee of We
Financial Group deemed to be an Access Person and is intended to ensure that securities transactions
effected by Access Persons of We Financial Group are conducted in a manner that avoids any conflict of
interest between such persons and clients of the adviser or its affiliates. We Financial Group collects and
maintains records of securities holdings and securities transactions effected by Access Persons. These
records are reviewed to identify and resolve conflicts of interest. We Financial Group maintains a code of
ethics and they will provide a copy to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest
We Financial Group does not currently have any material financial interest involving its recommendations
to clients therefore this question is not applicable.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
We Financial Group and/or its investment advisory representative from time-to-time purchase or sell
products that they recommend to clients. This practice presents a conflict where, because of the
information the Adviser has, the Adviser or its related person are in a position to trade in a manner that
adversely affect clients (e.g., place their own trades before or after client trades are executed in order to
benefit from any price movements due to the clients’ trades). In addition to affecting the Adviser’s or its
related person’s objectivity, these practices by the Adviser or its related person also harm clients by
adversely affecting the price at which the clients’ trades are executed. To mitigate this conflict, We
Financial Group and/or its investment advisory representative have a fiduciary duty to put the interests
of their clients ahead of their own. The Adviser has adopted the following procedures in an effort to
minimize such conflicts: The Adviser requires its related persons/access persons to preclear all
transactions in their personal accounts with the Chief Compliance Officer, Guillaume Decalf, who may
deny permission to execute the transaction if such transaction will have any adverse economic impact
on one of its clients. All of the Adviser’s related persons are required to disclose their securities
transactions on a quarterly basis and holdings on an annual basis. All of the Adviser’s related persons are
also required to provide broker confirmations of each transaction in which they engage and a monthly
certification of such transactions. Trading in employee accounts will be reviewed by the Chief Compliance
Officer and compared with transactions for the client accounts. Also, the investment advisory
representative is required to adhere to We Financial Group’ Code of Ethics as outlined above in Item
11A.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and
Conflicts of Interest
See the response to Item 11C above.
Item 12 Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
We Financial Group will recommend Schwab to be used based on execution and custodial services offered,
cost, quality of service and industry reputation. The Advisor will consider factors such as commission
price, speed and quality of execution, client management tools, and convenience of access for both the
Advisor and client in making its suggestion.
Charles Schwab & Co., Inc.
Advisor participates in Schwab’s institutional customer program and recommends Schwab to Clients for
custody and brokerage services. Schwab Institutional is a division of Schwab member FINRA/SIPC.
Schwab is an independent and unaffiliated SEC- registered broker-dealer.
There is no direct link between Advisor’s participation in the program and the investment advice it gives
to its clients, although Advisor receives economic benefits through its participation in the program that
are typically not available to Schwab. These benefits include the following products and services
(provided without cost or at a discount): receipt of duplicate Client statements and confirmations;
research related products and tools; consulting services; access to a trading desk serving Advisor
participants; access to block trading (which provides the ability to aggregate securities transactions for
execution and then allocate the appropriate shares to Client accounts); the ability to have advisory fees
deducted directly from Client accounts; access to an electronic communications network for Client order
entry and account information; access to mutual funds with no transaction fees and to certain
institutional money managers; and discounts on compliance, marketing, research, technology, and
practice management products or services provided to Advisor by third party vendors.
Schwab pays for business consulting and professional services received by Advisor’s related persons.
Some of the products and services made available by Schwab through the program benefit Advisor but
may not benefit its client accounts. These products or services can assist advisors in managing and
administering accounts, including accounts not maintained at Schwab. Other services made available by
Schwab are intended to help advisors manage and further develop its business enterprise. The benefits
received by Advisor or its personnel through participation in the program do not depend on the amount
of brokerage transactions directed to Schwab. As part of its fiduciary duties to clients, Advisor endeavors
at all times to 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 conflict of interest that can
indirectly influence the Advisor’s choice of Schwab for custody and brokerage services.
The products and services described above are provided as part of the overall relationship with Schwab.
While as a fiduciary, the Advisor endeavors to act in its clients’ best interests, the receipt of these benefits
creates a conflict of interest because the firm’ recommendation that clients custody their assets at the
custodian based, in part, on the benefits and of the foregoing products and services and not solely on the
nature, cost or quality of custody or brokerage services provided.
Interactive Brokers
Securities transactions may also be executed through Interactive Brokers, member FINRA/SIPC/NYSE.
Interactive Brokers maintains custody of our clients’ assets and effects securities transactions for our
investment management client accounts. The commissions charged by Interactive Brokers are
competitive with similarly situated retail broker-dealers offering the same variety of securities to clients.
Research and Other Soft Dollar Benefits.
We Financial Group receives proprietary research services or other products as a result of
recommending Schwab which results in the client paying higher commissions than those obtainable
through other brokers. If the Advisor does receive such products or services, it will follow procedures
which ensure compliance with Section 28(e) of the Securities Exchange Act of 1934 or applicable
state securities rules.
We also receive soft dollar benefits by nature of our relationship with Interactive Brokers. Interactive
Brokers offers products or services other than execution that assist our firm in managing and
administering client accounts. These may include software and other technology that provides access
to client account data (such as trade confirmations and account statements), facilitate trade
execution (and allocation of aggregated trade orders for multiple client accounts), facilitate payment
of our fees from clients’ accounts, and assist with back-office functions, record keeping and client
reporting. These services may be used to service all or a substantial number of client accounts,
including accounts not maintained at Interactive Brokers.
The firm seeks to obtain the most favorable net results for clients’ price, execution quality, services, and
commissions. Although the firm seeks competitive commission rates, it will pay commissions on behalf
of clients which may be higher than those available from other brokers in order to receive other services.
The firm enters into such transactions so long as it determines in good faith that the amount of
commission paid was reasonable in relation to the value of the brokerage and research services provided
by the broker. The services considered in this determination of reasonableness include (1) advice, either
directly or through publications or writing, as to the value of securities, the advisability of investing in,
purchasing or selling securities, and the availability of securities or purchasers or sellers of securities; (2)
analysis and reports concerning issuers, industries, securities, economic factors and trends, portfolio
strategy, and the performance of accounts; or (3) effecting securities transactions and performing
functions incidental thereto. Such research furnished by broker-dealers are used to service any or all of
We Financial Group’s clients and used in connection with accounts other than those that pay
commissions to the broker-dealers providing the research. In particular, third-party research provided by
broker-dealers used to benefit all of the firm’s clients. This creates a conflict of interest in that the firm
has an incentive to select or recommend a broker- dealer based on its interest in receiving the research or
other products or services, rather than on the clients’ interest in receiving most favorable execution.
Charles Schwab PCRA
We offer Personal Choice Retirement Accounts (PCRA) through Schwab Advisor Services. PCRAs are
retirement accounts of participants who have been allowed to move a portion of their retirement plan
assets to a self-directed account to be managed separately by We Financial Group via an asset
management agreement.
A PCRA account could benefit those inside of a Schwab-custodial retirement plan who are seeking a
wider range of investments and more active account management. A plan participant can engage We
Financial Group to implement customizable and personal allocations, as well as provide ongoing
professional investment and planning advice.
Brokerage for Client Referrals
We Financial Group does not receive client referrals from any broker-dealer or third party as a result
of the firm selecting or recommending that broker-dealer to clients.
Directed Brokerage
We Financial Group recommends that all clients use Schwab for execution and/or custodial services.
Schwab is recommended based on criteria such as, but not limited to, reasonableness of commissions
charged to the client, tools and services made available to the client and the Advisor, and convenience
of access to the account trading and reporting. The client will provide authority to We Financial Group
to direct all transactions through that broker-dealer in the investment advisory agreement.
As an investment advisory firm, We Financial Group has a fiduciary duty to seek best execution for
client transactions. While best execution is difficult to define and challenging to measure, there is
some consensus that it does not solely mean the achievement of the best price on a given
transaction. Rather, it appears to be a collective consideration of factors concerning the trade in
question. Such factors include the security being traded, the price of the trade, the speed of the
execution, apparent conditions in the market, and the specific needs of the client. We Financial
Group’s primary objectives when placing orders for the purchase and sale of securities for client
accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2)
size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. We
Financial Group may not necessarily pay the lowest commission or commission equivalent as specific
transactions involve specialized services on the part of the broker.
Your assets must be maintained in an account at a custodian, generally a broker dealer (Percent) or bank.
We consider a wide range of factors, including:
• 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 the 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, 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 prices
• Reputation, financial strength, security and stability
• Dedicated service team and local personnel
• Prior service to us and our clients
• Availability of other products and services that benefit us, as discussed below
We Financial Group will allow clients to direct brokerage at the Advisor’s sole discretion. Clients need to
be aware that if they direct We Financial Group to a particular broker-dealer for execution We Financial
Group will be unable to achieve most favorable execution of client transactions. Directing brokerage costs
clients more money than if We Financial Group were to execute transactions at the broker-dealer where
it has an established relationship. The client pays higher brokerage commissions because We Financial
Group is not able to aggregate orders to reduce transaction costs or the client receives less favorable
prices.
Aggregating Securities Transactions for Client Accounts
We Financial Group combines orders into block trades when more than one account is participating in the
trade in Schwab. This blocking or bunching technique must be equitable and potentially advantageous for
each such account (e.g., for the purposes of reducing brokerage commissions or obtaining a more
favorable execution price). Block trading is performed when it is consistent with the duty to seek best
execution and is consistent with the terms of We Financial Group’s investment advisory agreements.
Equity trades are blocked based upon fairness to clients, both in the participation of their account, and in
the allocation of orders for the accounts of more than one client. Allocations of all orders are performed
in a timely and efficient manner. All managed accounts participating in a block execution receive the
same execution price (average share price) for the securities purchased or sold in a trading day. Any
portion of an order that remains unfilled at the end of a given day will be rewritten on the following day
as a new order with a new daily average price to be determined at the end of the following day. Due to
the low liquidity of certain securities, broker availability can be limited. Open orders are worked until
they are completely filled, which can span the course of several days. If an order is filled in its entirety,
securities purchased in the aggregated transaction will be allocated among the accounts participating in
the trade in accordance with the allocation statement. If an order is partially filled, the securities will be
allocated pro rata based on the allocation statement. We Financial Group could allocate trades in a
different manner than indicated on the allocation statement (non-pro rata) only if all managed accounts
receive fair and equitable treatment.
Item 13 Review of Accounts
Investment advisory client accounts are monitored on an ongoing basis and formal client reviews are
conducted at least annually. Client accounts and Financial Plans or written reports are reviewed by
Guillaume Decalf, President. The nature of the review is to determine if the client account is still in line
with the client’s stated objectives.
Financial Plans or written reports, once prepared and delivered to the client are not reviewed again
unless the client requests a financial plan or written report be updated.
The client is encouraged to notify the Advisor and Investment Advisor Representative if changes occur in
his/her personal financial situation that might materially affect his/her investment plan.
The client will receive written statements no less than quarterly from the custodian. In addition, the
client will receive other supporting reports from mutual funds, asset managers, trust companies or other
custodians, insurance companies, broker-dealers and others who are involved with client accounts.
We Financial Group does not provide written reports to clients.
Item 14 Client Referrals and Other Compensation
Economic Benefits Provided from External Sources and Conflicts of Interest
We Financial Group receives non-economic benefits from Schwab in the form of support products and
services. The products and services are not based on particular investment advice that would otherwise
create a conflict of interest.
Charles Schwab & Co., Inc.
The firm participates in Schwab’s institutional customer program and may recommend Schwab for
custody and brokerage services. There is no direct link between participation in the program and the
investment advice given, although the firm receives economic benefits through its participation in the
program that are typically not available to Schwab retail investors. These benefits include the following
products and services (provided without cost or at a discount): receipt of duplicate Client statements and
confirmations; research related products and tools; consulting services; access to a trading desk serving
the firm participants; access to block trading (which provides the ability to aggregate securities
transactions for execution and then allocate the appropriate shares to Client accounts); the ability to
have advisory fees deducted directly from client accounts; access to an electronic communications
network for order entry and account information; access to mutual funds with no transaction fees and
to certain institutional money managers; and discounts on compliance, marketing, research, technology,
and practice management products or services provided to the firm by third party vendors. Schwab may
also have paid for business consulting and professional services received by the firm’s related persons.
Some of the products and services made available by Schwab through the program may benefit the firm
but may not benefit its Client accounts. These products or services may assist the firm in managing and
administering accounts, including accounts not maintained at Schwab. Other services made available by
Schwab are intended to help the firm manage and further develop its business enterprise. The benefits
received by the firm or its personnel through participation in the program do not depend on the amount
of brokerage transactions directed to Schwab. As part of its fiduciary duties to clients, the firm endeavors
at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of
economic benefits by the firm or its related persons in and of itself creates a potential conflict of interest
and may indirectly influence the firm’s choice of Schwab for custody and brokerage services.
We Financial Group also receives soft dollar benefits as disclosed in Item 12.
Advisory Firm Payments for Client Referrals
We Financial Group does not currently have any such arrangements therefore this question is not applicable.
Item 15 Custody
If a client authorizes We Financial Group to instruct the custodian to deduct advisory fees directly
from the assets under management, We Financial Group is deemed to have limited custody.
Under state regulations, We Financial Group is deemed to have custody of client assets if you authorize
us to instruct the qualified custodian to deduct our advisory fees directly from your account. The qualified
custodian utilized by We Financial Group maintains actual custody of your assets. The client will receive
written statements no less than quarterly from the custodian. The custodian will send a quarterly
statement to the client and the Advisor will also send a quarterly invoice to the client, at the same time
the Advisor sends an invoice to the custodian, outlining the fee calculation and the amount withdrawn
from the client account. We Financial Group encourages clients to carefully review/compare their
account statements and firm invoice for any inaccuracies. Any discrepancies should be immediately
brought to the firm’s attention.
Item 16 Investment Discretion
We Financial Group has discretion over the selection and number of securities to be bought or sold in
client accounts without obtaining prior consent or approval from the client for each transaction.
However, these purchases or sales will be subject to specified investment objectives, guidelines, or
limitations previously set forth by the client and agreed to by We Financial Group.
Discretionary authority will only be provided upon full disclosure to the client. The granting of such
authority will be evidenced by the client’s execution of an Investment Advisory Agreement containing all
applicable limitations to such authority. All discretionary trades made by We Financial Group will be in
accordance with each client’s investment objectives and goals.
Item 17 Voting Client Securities
We Financial Group will not vote, nor advise clients how to vote, proxies for securities held in client
accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. Also, We
Financial Group cannot give any advice or take any action with respect to the voting of these proxies. The
client and We Financial Group agree to this by contract. Clients will receive proxy solicitations from their
custodian and/or transfer agent.
Item 18 Financial Information
Balance Sheet
We Financial Group does not require or solicit prepayment of more than $1,200 in fees per client, six months
or more in advance, therefore a Balance Sheet is not included with this Brochure.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients
We Financial Group has discretionary authority over client accounts and is not aware of any financial
condition that will likely impair its ability to meet contractual commitments to clients. If We Financial
Group does become aware of any such financial condition, this brochure will be updated and clients will
be notified.
Bankruptcy Petitions During the Past Ten Years
Not applicable to We Financial Group.