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Wealth Advisory Group, Inc.
1055 Westlakes Drive
Suite 130
Berwyn, Pennsylvania 19312
Telephone: 610.225.1000
Facsimile: 610.225.3036
Website: www.wagadvisors.com
October 30, 2025
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Wealth Advisory
Group, Inc. If you have any questions about the contents of this brochure, please contact us at
610.225.1000. 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 Wealth Advisory Group, Inc. is also available on the SEC's website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Wealth Advisory Group, Inc. is
122269.
Wealth Advisory Group, Inc. is a registered investment adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain level of
skill or training.
Item 2 Summary of Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure,
the adviser is required to notify you and provide you with a description of the material changes.
Since our last annual updating amendment dated March 27, 2025, we have not made material
changes to our Brochure:
Item 3 Table of Contents
Item 2 Summary of Material Changes ................................................................................. 2
Item 3 Table of Contents ..................................................................................................... 3
Item 4 Advisory Business .................................................................................................... 4
Item 5 Fees and Compensation .......................................................................................... 8
Item 6 Performance-Based Fees and Side-By-Side Management .................................... 12
Item 7 Types of Clients ..................................................................................................... 12
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................ 12
Item 9 Disciplinary Information .......................................................................................... 14
Item 10 Other Financial Industry Activities and Affiliations ................................................ 14
Item 11 Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading ........................................................................................................ 15
Item 12 Brokerage Practices ............................................................................................. 15
Item 13 Review of Accounts .............................................................................................. 19
Item 14 Client Referrals and Other Compensation ............................................................ 19
Item 15 Custody ................................................................................................................ 19
Item 16 Investment Discretion ........................................................................................... 20
Item 17 Voting Client Securities ........................................................................................ 21
Item 18 Financial Information ............................................................................................ 21
Item 19 Requirements for State Registered Advisers ........................................................ 21
Item 20 Additional Information .......................................................................................... 21
Item 4 Advisory Business
Description of Services and Fees
Wealth Advisory Group, Inc., a Pennsylvania based Corporation ("Wealth Advisory Group" or "we",
"our" and "us"), located in Berwyn, Pennsylvania, is an investment adviser registered with the United
States Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940 (the
"Advisers Act"). Wealth Advisory Group is wholly-owned by WIA Holdings, LLC. This section describes
our firm, and explains the types of advisory services that we offer, including investment consulting,
discretionary advisory, pre-retirement and financial planning services (together the "advisory
services").
Wealth Advisory Group was established in 1993, and provides investment advisory services to
corporations, institutions (including ERISA and other retirement accounts and certain pension and/or
Taft-Hartley plans), individuals, high net worth individuals, and charitable organizations. Currently, we
offer the following investment advisory services, which are personalized to each individual client:
• Portfolio Management Services
• Financial Planning Services
• Selection of Other Advisers
• Pension Consulting Services
• ERISA Plans – 3(21) & 3(38) Co-Fiduciary Investment Advisory Services
• Institutional Intelligent Portfolios® Platform
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to your
individual needs. As used in this brochure, the words "we", "our" and "us" refer to Wealth Advisory
Group, Inc. and the words "you", "your" and "client" refer to you as either a client or prospective client
of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this
brochure, our Associated Persons are our firm's officers, employees, and all individuals providing
investment advice on behalf of our firm.
Wealth Advisory Group, Inc.'s Ongoing Fee-Based Engagement Agreements
Silver Engagement - The Silver option provides you with a comprehensive and detailed written
financial plan of all of your investments and insurance plans including company provided employee
benefits. It also includes an annual planning review with an Associated Person of our firm. After this
review we will provide you with our observations and recommendations relative to asset performance
tracking, net worth statements, asset allocation and proactive coaching of your family wealth.
Gold Engagement -The Gold option provides you with all features of a Silver Engagement and
includes semi-annual financial planning reviews with an Associated Person of our firm. The opportunity
to meet twice a year affords more concentrated time to be spent on detailed financial issues such as
estate planning, tax planning, portfolio review and balancing, options strategy and insurance planning.
We focus on reviewing the progress from the prior meetings assuring continued progression toward
your financial objectives. You will receive an Investment Strategy Profile and asset allocation report
showing all of your financial assets, not just the investments in one account. The total household
wealth strategy is a proactive approach for planning with your own Family Wealth Advisor.
Platinum Engagement - The Platinum option gives you the opportunity to work consistently with a
trusted family advisor producing a high degree of confidence, trust and familiarity with the entire family.
All facets of wealth are discussed including private investment opportunities, estate and tax strategies
for maximum benefit, philanthropy and distribution strategies.
Investment Management
When needed, we provide discretionary continuous investment management services where the
investment advice provided is custom tailored to meet your individual needs and investment objectives.
Subject to any written guidelines, which you may provide, we will be granted discretion and authority to
manage your account. Accordingly, we are authorized to perform various investment functions, on your
behalf and at your expense, without further approval from you. Such functions include the
determination of the types and amounts of securities to be purchased and sold. We sometimes use
investment model portfolios that we have created in the course of managing your accounts. We may
also use model portfolios created by other advisors. Once the portfolio is constructed, we will provide
continuous supervision and re-optimization of the portfolio as changes in market conditions and your
circumstances may require.
Wealth Advisory Group, Inc.'s Other Services:
You may choose not to be a client of Wealth Advisory Group, Inc.'s ongoing services and still have
personalized or customized investment advisory or planning services performed by Associated
Persons of our firm. We can offer you various services, including financial consulting relating to estate
planning, business planning, employee benefit consulting, investment management services, and
pension consulting services.
Estate Planning - Individuals and families may want consult with us to on the financial aspects that
are involved in the creation of estate plans specifically as they pertain to wealth transfer and gifting
strategies. Many techniques are available for the reduction of estate and gift taxes and may involve the
utilization of various types of trusts. It should be noted that we are not attorneys and are not engaged
in the practice of law. We do not create estate plans but, rather, only consult on the financial concerns
involved therein.
Business Planning - Business owners face many challenges including business succession planning,
funding of buy-sell agreements, disability income continuation, and compensation strategies and
planning to attract, retain and reward employees. We will work with the business owner to design
solutions to these challenges.
Employee Benefit Consulting - Employers face the reality that the cost of benefits is ever increasing
and benefits consulting focuses on the plan design, employee contributions and insurance company
selection. We can help with an analysis of your current employee benefit plans and make observations
and recommendations which affect the net cost of benefits. Certain types of employee benefit services
can be provided through our affiliate, World Employee Benefits, a sub-division of World Insurance
Associates.
Pension Plan Investment Management Services - Companies need to design and administer
retirement plans for the benefit of their employees. Most companies offer qualified defined contribution
plans which require a diversified investment menu, enrollment and education, a plan custodian and
Third Party Administrator for record keeping and plan compliance. We will act as an investment advisor
to the Trustees of the plan by establishing the investment menu and providing investment monitoring,
at least annually, to review and make changes to the fund offerings. We can also serve as a 3(21) or
3(38) co-fiduciary to the Plan and provide certain fiduciary functions. A separate custodian and Third
Party Administrator will be selected by the company for their services, independent of our firm.
Retirement Plan Consulting Services - We provide retirement plan consulting services to employee
benefit plans, the plan sponsors and fiduciaries (collectively, the "Sponsor") based upon an analysis of
the needs of the plan. In general, these services may include an existing plan review, formation of an
investment policy statement, assisting the Sponsor in fund selection and investment options,
investment performance monitoring, risk management education, and/or ongoing
consulting. Additionally, we will offer the Sponsor assistance in setting up a relationship with a third
party administrator and processing enrollment forms. We may also offer communication and education
services to provide meaningful information regarding the retirement plan to its Participants. Information
provided to participants in the educational seminars will be limited to general, impersonal advice.
Retirement Plan Consulting services will be provided pursuant to the agreement entered into and
within the parameters set forth in the plan documents. Where the Sponsor engages our firm to provide
advice to participants on an individual basis, such advice will be limited to general retirement planning
issues, and fund selection and asset allocation of plan assets.
Plan Participants who wish to engage us for individualized financial planning or consulting services
outside the scope of the qualified plan may do so by executing a separate agreement, including
separate fees and fee payment arrangements, with us.
All accounts are regulated under ERISA. We will provide consulting services to the Sponsor and the
Participants as described above. The named Sponsor must make the ultimate decision as to retaining
our firm for pension consulting services. The Sponsor is free to seek independent advice about the
appropriateness of any recommended services for the plan.
Advisory Services to Retirement Plans and Plan Participants - As disclosed above, we offer
various levels of advisory and consulting services to employee benefit plans ("Plan") and to the
participants of such plans (“Participants”). The services are designed to assist plan sponsors in
meeting their management and fiduciary obligations to Participants under the Employee Retirement
Income Securities Act (“ERISA”). Pursuant to adopted regulations of the U.S. Department of Labor, we
are required to provide the Plan's responsible plan fiduciary (the person who has the authority to
engage us as an investment adviser to the Plan) with a written statement of the services we provide to
the Plan, the compensation we receive for providing those services, and our status (which is described
below).
Status - Our firm is registered as an investment adviser under the Investment Advisors Act of 1940
and we represent that we are not subject to any disqualification as set forth in Section 411 of ERISA. In
performing fiduciary services, we are acting as a fiduciary of the Plan as defined in Section 3(21) for
purposes of providing non-discretionary investment advice only, or Section 3(38) for purposes of
providing discretionary investment advice, under the Employee Retirement Income Security Act
(“ERISA”).
Selection of Other Advisers
As part of our investment advisory services, if appropriate and consistent with your needs, we will
recommend that you use the services of a third-party investment adviser ("TPA") to manage your
entire, or a portion of your, investment portfolio. After gathering information about your financial
situation and objectives, we will recommend that you engage a specific TPA or investment program.
Factors that we take into consideration when making our recommendation(s) include, but are not
limited to, the following: the TPA's performance, methods of analysis, fees, your financial needs,
investment goals, risk tolerance, and investment objectives. We will periodically monitor the TPA(s)'
performance to ensure its management and investment style remains aligned with your investment
goals and objectives.
Use of Sub-Advisers
As part of our portfolio management services, if appropriate and consistent with your needs, we will
use one or more sub-advisers to manage a portion of your account on a discretionary basis. The sub-
adviser(s) may use one or more of their model portfolios to manage your account. We will regularly
monitor the performance of your accounts managed by sub-adviser(s), and may hire and fire any sub-
adviser without your prior approval.
Wrap Fee Programs
Institutional Intelligent Portfolios® Platform
We offer an automated investment program (the “Program”) through which clients are invested in a
range of investment strategies we have constructed and manage, each consisting of a portfolio of
exchange-traded funds (“ETFs”) and a cash allocation. The client may instruct us to exclude up to
three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened by the
client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform
(“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to
independent investment advisors and an affiliate of CS&Co, to operate the Program. We are
independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co, or their
affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary
point of contact with respect to the Program. We are solely responsible, and Schwab is not
responsible, for determining the appropriateness of the Program for the client, choosing a suitable
investment strategy and portfolio for the client’s investment needs and goals, and managing that
portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which
consists of technology and related trading and account management services for the Program. The
Platform enables us to make the Program available to clients online and includes a system that
automates certain key parts of our investment process (the “System”). The System includes an online
questionnaire that helps us determine the client’s investment objectives and risk tolerance and select
an appropriate investment strategy and portfolio. Clients should note that we will recommend a
portfolio via the System in response to the client’s answers to the online questionnaire. The client may
then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the
recommended portfolio, but we then make the final decision and select a portfolio based on all the
information we have about the client. The System also includes an automated investment engine
through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and
tax-loss harvesting (if the client is eligible and elects).
The Program can be used in conjunction with other services offered by Wealth Advisory Group or as a
stand-alone service. Therefore, participants in the Program may or may not utilize the other services
described above depending on the type of engagement agreed to with Wealth Advisory Group.
We also offer Wrap Fee programs sponsored by Morningstar Investment Services, LLC and SEI
Securities, Inc.
Wrap Fee programs are a type of investment program that provides clients with access to several
money managers or mutual fund asset allocation models for a single fee that includes administrative
fees, management fees, and commissions. If you participate in one of the wrap fee programs
referenced above, you will pay our firm a single fee, which includes our money management fees,
certain transaction costs, and custodial and administrative costs. We receive a portion of the wrap fee
for our services. The overall cost you will incur if you participate in our wrap fee program may be higher
or lower than you might incur by separately purchasing the types of securities available in the program.
In general, we manage wrap fee accounts on a discretionary basis. Wrap fee accounts are typically
more appropriate for active accounts and are managed accordingly. We also manage non-wrap fee
accounts on either a discretionary or a non-discretionary basis, and may include a different investment
strategy in managing non-wrap accounts.
If you participate in a wrap fee program, we will provide you with a separate Wrap Fee Program
Brochure explaining the program and costs associated with the program. You should also review this
Part 2A thoroughly to evaluate any differences between the services we offer as wrap versus non-
wrap.
Types of Investments
We offer advice on investment company securities, such as mutual funds and ETFs; however we may
advise you on any type of investment, such as equities and fixed income securities, that we deem
appropriate based on your stated goals and objectives. We may also provide advice on any type of
investment held in your portfolio at the inception of our advisory relationship.
Assets Under Management
As of December 31, 2024, we manage $219,563,528 in client assets on a discretionary basis, and
$447,304,432 in client assets on a non-discretionary basis.
Item 5 Fees and Compensation
Wealth Advisory Group, Inc.'s Ongoing Fee-Based Engagement Agreements
Depending upon the type of advisory service to be provided, clients generally have a choice regarding
the manner in which fees will be calculated for such services. Options for calculating fees include the
following:
• Percentage of assets under management;
• Hourly charges;
• Flat Fees (As per the “metallic” engagement levels detailed directly below);
• Other retainer or service fees, or some combination of the above.
Note that when charging an asset-based fee (i.e., a percentage of the assets being managed) a
conflict of interest exists since the more assets there are in your account, the more you will pay in fees.
We therefore have an incentive to encourage you to increase the assets in your account or to invest in
riskier securities that offer the potential for higher growth. However, as a fiduciary, we are obligated to
act solely in your best interests and our focus is on providing you with investment advice that is
appropriate for you in light of your specific financial situation.
Silver Engagement - The Silver option annual fee is $1,000. Fee payments are due at the time of
engagement. The annual fee is renewable annually. Engagement fees may be further discounted at
the discretion of our firm. Clients may cancel within five business days of enrollment and receipt of our
Form ADV Part 2 for a full refund of any payment made. Thereafter, clients may only cancel by
submission of written notice to us. Engagement fees shall be refunded to the client on a pro-rata basis.
Gold Engagement -The Gold option annual fee is $2,500. Fee payments are due 50% at the time of
engagement, and the remaining 50% is due six months later. This annual fee is renewable annually.
Engagement fees may be further discounted at our discretion. Clients may cancel within 5 business
days of engagement and receipt of our Form ADV Part 2 for a full refund of any payment made.
Thereafter, clients may only cancel by submission of written notice to us. Engagement fees shall be
refunded to the client on a pro-rata basis.
Platinum Engagement - The Platinum option fee is either a flat fee not to exceed $6,000 per quarter,
or an asset-based fee based on the fair market value of the assets in your account as of the last
business day of the month in which the client enrolls and thereafter as of the last business day of each
billing period. The engagement fee for asset-based fees shall be determined on a client-by-client basis
but for new clients and new accounts for existing clients shall not exceed a maximum fee of 1.25% of
the assets under management. Platinum fees may be negotiable based upon the complexity and size
of the asset holdings. This engagement fee is renewable annually.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.
Investment Management Services - These services are performed and billed quarterly, in arrears,
based upon a percentage of assets under management. with fees for new clients and new accounts
opened for existing clients ranging from 1.25% to 0.20% annually1. On some occasions we also charge
flat fees in lieu of an asset-based fee. Typically, we will directly debit client accounts for the payment of
portfolio management fees. When we directly debit your account, payment of fees will be made by the
qualified custodian holding your funds and securities provided that the following requirements are met:
• You provide written authorization permitting the fees to be paid directly from your account held
by the qualified custodian. We do not have access to your funds for payment of fees without
your consent in writing.
• The qualified custodian agrees to send you and us a statement, at least quarterly, indicating all
amounts dispersed from the account including the amount of the advisory fee paid directly to
our firm.
We encourage you to carefully review the statement(s) you receive from the qualified custodian and
contact us if you have any questions.
In limited circumstances, upon request, we may agree to directly invoice you for advisory fees. In such
cases, fees will be payable as invoiced instead of a direct debit.
Clients may cancel within five business days of enrollment and receipt of our Form ADV Part 2 for a full
refund of any payment made. Thereafter, clients may only cancel by submission of written notice to us.
Engagement fees shall be refunded to you on a pro-rata basis.
It is understood that the Platinum engagement fee does not include the costs that will be paid by the
client for the execution or management of the assets by us or by an independent broker-dealer or
money manager, if applicable..
Wealth Advisory Group, Inc.'s Other Services:
Wealth Advisory Group, Inc.'s other Services will be performed at either an hourly rate, not to exceed
$350.00 per hour, or based upon a percentage of assets under management with fees ranging from
1.50% to 0.20%. Such fee shall be determined based upon the amount of assets and the level of
services provided, and whether we, or our Associated Persons receive compensation from another
investment advisor, money manager, or insurance broker for introducing or referring you to them.
1 We have at least one legacy client whose advisory fee for a single account exceeds 1.25%, but no new client
will be charged more than 1.25%.
The payment terms shall be determined on a case-by-case basis.
Estate Planning - Consulting advice is provided on an hourly basis.
Business Planning - Business Planning Services are billed on an hourly, or project, basis.
Employee Benefit Consulting - Employee Benefit Consulting is done on a project basis with hourly
billing.
Pension Consulting Services - The scope of these services, the fees, and the terms of the
agreement for these services will be negotiated on a case-by-case basis with each Sponsor. We may
be compensated based on an hourly fee, a flat fee, a fee based on percentage of assets, or a
combination of fee arrangements based on the complexity of the plan and the agreement with the
Sponsor. In any case, we will not have access to plan funds for payment of fees without written
consent. The terms regarding payment of fees, termination, and refunds will be clearly set forth in the
agreement executed between our firm and the Sponsor. We will not receive additional compensation
beyond the consulting fees for our pension consulting services.
Either our firm or the Sponsor may terminate the pension consulting agreement within five business
days of the date of acceptance without penalty. After the five-day period, either party may terminate
the pension consulting agreement by providing written notice to the other party. The Sponsor may
incur a charge for services rendered prior to such termination. If applicable, any unearned fees will be
refunded on a pro rata basis.
The fees charged are calculated as described above, and are not charged on the basis of a share of
capital gains upon, or capital appreciation of, the funds, or any portion of your funds.
Advisory Services to Retirement Plans and Plan Participants - The services we provide to your
Plan are described above, and in the service agreement that you have previously signed. Our
compensation for these services is negotiated on a case-by-case basis and detailed in the advisory
agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the
services we provide to the Plan or Participants.
Selection of Other Advisers
Our recommendations to use third-party investment advisers (“TPAs”) are included in our portfolio
management fee. We do not charge you a separate fee for the selection of other advisers nor will we
share in the advisory fee you pay directly to the TPA. Advisory fees that you pay to the TPA are
established and payable in accordance with the Form ADV Part 2 or other equivalent disclosure
document provided by each TPA to whom you are referred. You should review the recommended
TPA's brochure for information on its fees and services.
You will be required to sign an agreement directly with the recommended TPA(s). You may terminate
your advisory relationship with the TPA according to the terms of your agreement with the TPA. You
should review each TPA's brochure for specific information on how you may terminate your advisory
relationship with the TPA and how you may receive a refund, if applicable. You should contact the TPA
directly for questions regarding your advisory agreement with the TPA.
Use of Sub-Advisers
From time to time, we may utilize a sub-advisor to assist us in managing your account. We pay a
portion of our advisory fee to the sub-adviser(s) we use. In some circumstances, this can cause your
fee to be higher than it would be if we did not use a sub-advisor
Institutional Intelligent Portfolios® Platform
We charge clients a fee for our services as described below. Our fees are not set or supervised by
Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co as part of the
Program. Schwab does receive other revenues in connection with the Program.
We do not pay Schwab Performance Technologies ("SPT") fees for the Platform so long as we
maintain $100 million in client assets in accounts at CS&Co that are not enrolled in the Program. If we
do not meet this condition, then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the
value of our clients’ assets in the Program. This fee arrangement gives us an incentive to recommend
or require that our clients with accounts not enrolled in the Program be maintained with CS&Co This is
a conflict of interest, which we mitigate by assuring that the recommendation of Schwab as the
custodian use for our Clients’ advisory accounts remains suitable under all the circumstances.
Clients do not pay fees to SPT or brokerage commissions or other fees to CS&Co as part of the
Program. Schwab does receive other revenues in connection with the Program. Brokerage
arrangements are further described below in Item 12 Brokerage Practices.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses.
You will also incur transaction charges and/or brokerage fees when purchasing or selling securities.
These charges and fees are typically imposed by the broker-dealer or custodian through whom your
account transactions are executed. We do not share in any portion of the brokerage fees/transaction
charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur,
you should review all the fees charged by mutual funds, exchange traded funds, and others, which are
typically described in the prospectus. For information on our brokerage practices, please refer to the
Brokerage Practices section of this brochure.
Compensation for the Sale of Securities or Other Investment Products
Persons providing investment advice on behalf of our firm are registered representatives with BCG
Securities, Inc., a registered broker-dealer, and a member of the Financial Industry Regulatory
Authority and the Securities Investor Protection Corporation. In their capacity as registered
representatives, these persons will receive commission-based compensation in connection with the
purchase and sale of securities, including 12b-1 fees for the sale of investment company products.
Compensation earned by these persons in their capacities as registered representatives is separate
and in addition to our advisory fees. This practice presents a conflict of interest because persons
providing investment advice on behalf of our firm who are registered representatives have an incentive
to effect securities transactions for the purpose of generating commissions rather than solely based on
your needs. However, as part of our fiduciary duties to you, we endeavor at all times to put your
interests first. You are under no obligation, contractually or otherwise, to purchase securities products
through any person affiliated with our firm.
Persons providing investment advice on behalf of our firm are licensed as independent insurance
agents. These persons will earn commission-based compensation for selling insurance products,
including insurance products they sell to you. Insurance commissions earned by these persons are
separate and in addition to our advisory fees. This practice presents a conflict of interest because
persons providing investment advice on behalf of our firm who are insurance agents have an incentive
to recommend insurance products to you for the purpose of generating commissions rather than solely
based on your needs. However, as part of our fiduciary duties to you, we endeavor at all times to put
your interests first. You are under no obligation, contractually or otherwise, to purchase insurance
products through any person affiliated with our firm.
Item 6 Performance-Based Fees and Side-By-Side Management
Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a
client's account. We do not accept performance-based fees or participate in side-by-side management.
Side-by-side management refers to the practice of managing accounts that are charged performance-
based fees while at the same time managing accounts that are not charged performance-based fees.
Our fees are calculated as described in the Advisory Business section above, and are not charged on
the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory
account.
Item 7 Types of Clients
We offer investment advisory services to individuals, pension and profit sharing plans, trusts, estates,
charitable organizations, corporations, and other business entities.
In general, we do not require a minimum dollar amount to open and maintain an advisory account;
however, we have the right to terminate your Account if it falls below a minimum size which, in our sole
opinion, is too small to effectively manage.
Institutional Intelligent Portfolios® Platform
Clients eligible to enroll in the Program include individuals, IRAs, and revocable living trusts. Clients
that are organizations (such as corporations and partnerships) or government entities, and clients that
are subject to the Employee Retirement Income Security Act of 1974, are not eligible for the Program.
The minimum investment required to open an account in the Program is $5,000. The minimum
account balance to enroll in the tax-loss harvesting feature is $50,000.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our Methods of Analysis and Investment Strategies
We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
• Fundamental Analysis - involves analyzing individual companies and their industry groups, such
as a company's financial statements, details regarding the company's product line, the
experience and expertise of the company's management, and the outlook for the company's
industry. The resulting data is used to measure the true value of the company's stock compared
to the current market value.
• Long Term Purchases - securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
• Short Term Purchases - securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities'
short-term price fluctuations.
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined objectives,
risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various
suitability factors. Your restrictions and guidelines may affect the composition of your portfolio.
Fundamental Analysis - The risk of fundamental analysis is that information obtained may be incorrect
and the analysis may not provide an accurate estimate of earnings, which may be the basis for a
stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may
not result in favorable performance.
We may use short-term trading (in general, selling securities within 30 days of purchasing the same
securities) as an investment strategy when managing your account(s). Short-term trading is not a
fundamental part of our overall investment strategy, but we may use this strategy occasionally when
we determine that it is suitable given your stated investment objectives and tolerance for risk.
Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you continuously consult with a tax professional prior to and throughout the investing
of your assets.
Under IRS regulations, custodians and broker-dealers must report the cost basis of equities acquired
in client accounts on or after January 1, 2011. Your custodian will default to the FIFO (First-In First-
Out) accounting method for calculating the cost basis of your investments. You are responsible for
contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax
advisor believes another accounting method is more advantageous, please provide written notice to
our firm immediately and we will alert your account custodian of your individually selected accounting
method. Please note that decisions about cost basis accounting methods will need to be made before
trades settle, as the cost basis method cannot be changed after settlement.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
Recommendation of Particular Types of Securities
As disclosed under the Advisory Business section in this Brochure, we primarily recommend stocks,
ETFs and mutual funds however, we may recommend other types of investments as appropriate for
you since each client has different needs and different tolerance for risk. Each type of security has its
own unique set of risks associated with it and it would not be possible to list here all of the specific
risks of every type of investment. Even within the same type of investment, risks can vary widely.
However, in very general terms, the higher the anticipated return of an investment, the higher the risk
of loss associated with it.
Mutual funds are professionally managed collective investment systems that pool money from many
investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other
securities or any combination thereof. The fund will have a manager that trades the fund's investments
in accordance with the fund's investment objective. While mutual funds generally provide
diversification, risks can be significantly increased if the fund is concentrated in a particular sector of
the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows
money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than
balancing the fund with different types of securities. The returns on mutual funds will be reduced by the
costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy
into, , or sell out of , the funds typically charge other fees, such as 12b-1 fees, which can also reduce
returns. Mutual funds can also be "closed end" or "open end".
Item 9 Disciplinary Information
Wealth Advisory Group, Inc. has been registered and providing investment advisory services since
1993. Neither our firm nor any of our management personnel has any reportable disciplinary
information.
Item 10 Other Financial Industry Activities and Affiliations
WAG is a wholly owned subsidiary of WIA Holdings, LLC. WIA Holdings, LLC in turn is under the
common control and ownership of World Associates Holdings, LLC. Additionally, through a series of
other, affiliated, entities, Goldman Sachs & Co., LLC, has an indirect minority interest in World
Associates Holdings, LLC. Goldman Sachs & Co., LLC, is a FINRA broker-dealer (Member SIPC) and
SEC Registered Investment Adviser. Other affiliated businesses include: Pensionmark Securities, LLC
(“PSC”) and World Investments, Inc., FINRA broker dealers (Members SIPC); World Advisory
Services; World Investment Advisors, LLC; and, Financial Planning Concepts of America, Inc., all SEC
Registered Investment Advisers. WAG is also affiliated with: World Insurance Associates, LLC; Scotts
American, LLC; Keating, LLC; ESA Associates, LLC; FastComp, LLC; Hamond Safety Management,
LLC; Pacific Coast NCA Premium Finance, LLC; and World Insurance Programs, LLC, all insurance
agencies engaging in Life, Health, Long Term Care, Variable, and various other Insurance business.
As a result of Goldman Sachs’ affiliation, WAG has limited the available Goldman Sachs products it will
recommend to its clients. No incentives are provided to WAG or WAG Investment Advisor
Representatives to recommend Goldman Sachs products over other investment products.
WAG is also affiliated with other financial services companies, but does not have any shared business
dealings, operations, referral programs, clients, representatives, or premises with these other
companies, and has no reason to believe the firm’s relationship with them otherwise creates a conflict
of interest with WAG clients. A full list of WAG’s affiliates will be provided upon request.
Where appropriate, we may refer clients to one or more of the above-listed affiliated businesses for
service or products such as insurance or brokerage services, employee benefits, etc. In such cases, a
conflict of interest arises in that there exists a financial incentive for our parent company to refer clients
to those affiliates. Nevertheless, as a fiduciary, we are required to act in your best interests and any
referral we make are provided to clients with that obligation in mind. You are not obligated,
contractually or otherwise, to use the services of any business we recommend.
Persons providing investment advice on behalf of our firm are registered representatives with BCG
Securities, Inc, a registered broker-dealer, and a member of the Financial Industry Regulatory
Authority.
Persons providing investment advice on behalf of our firm are licensed as insurance agents. These
persons will earn commission-based compensation for selling insurance products, including insurance
products they sell to you. Insurance commissions earned by these persons are separate from our
advisory fees. Please see the Fees and Compensation section in this brochure for more information on
the compensation received by insurance agents who are affiliated with our firm.
We may recommend that you use a third party adviser ("TPA") based on your needs and suitability.
We will receive compensation from the TPA for recommending that you use their services. These
compensation arrangements present a conflict of interest because we have a financial incentive to
recommend the services of the third party adviser. We mitigate this conflict by assuring that any
recommended TPM will act in your best interest. You are not obligated, contractually or otherwise, to
use the services of any TPA we recommend.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our
goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties
of honesty, good faith, and fair dealing with you. All of our Associated Persons are expected to adhere
strictly to these guidelines. Persons associated with our firm are also required to report any violations
of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to
prevent the misuse or dissemination of material, non-public information about you or your account
holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any of our Associated Persons has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to
you or securities in which you are already invested. A conflict of interest exists in such cases because
we have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive. To mitigate this conflict of interest, it is our policy that neither our Associated Persons nor we
shall have priority over your account in the purchase or sale of securities.
Item 12 Brokerage Practices
We recommend that clients establish brokerage accounts with one or more broker-dealers including
but not limited to Schwab Institutional division of Charles Schwab & Co., Inc. ("Schwab Institutional"), a
registered broker-dealer, member SIPC/NYSE, to maintain custody of the client's assets and to effect
trades for their accounts. There will be transaction charges involved when purchasing or selling
securities. We do not share in any portion of the brokerage fees/transaction charges imposed by
Schwab Institutional. Additionally the commission/transaction fees charged by Schwab Institutional
may be higher or lower than those charged by other broker-dealer/custodians.
Schwab Institutional provides us with access to its institutional trading and operations services, which
are typically not available to Schwab retail investors. These services generally are available to
independent investment advisers at no charge to them so long as a total of at least $10 million of our
clients account assets are maintained at Schwab Institutional. Schwab Institutional services may
include research, brokerage, custody, access to mutual funds and other investments that are otherwise
available only to institutional investors or would require significantly higher minimum initial investments.
For our client accounts maintained in custody at Schwab, Schwab Institutional generally does not
charge separately for custody services but is compensated by account holders through commissions
and other transaction-related or asset-based fees for securities trades that are executed through
Schwab Institutional or that settle into Schwab accounts.
Schwab Advisor Services also makes available to us other products and services that benefit our firm
but not directly benefit our clients' accounts. Many of these products and services may be used to
service all or some substantial number of our client's accounts, including accounts not maintained at
Schwab.
Schwab's products and services that assist us in managing and administering clients' accounts include
software and other technology that (i) provide access to client account data (such as trade
confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade
orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate
payment of our fees from our clients' accounts; and (v) assist with back-office functions, recordkeeping
and client reporting.
We believe that Schwab Institutional provides the best services at reasonable commission rates. The
reasonableness of commissions is based on several factors, including the broker's ability to provide
professional services, competitive commission rates, volume discounts, execution price negotiations,
the broker's reputation, experience and financial stability of the broker or dealer, and the quality of
service rendered by the broker or dealer in other transactions.
Best execution is not measured solely by reference to commission rates. Paying a broker a higher
commission rate than another broker might charge is permissible if the difference in cost is reasonably
justified by the overall quality of the brokerage services offered.
Associated Persons of our firm, in their separate capacities as Registered Representatives and/or
insurance agents, will sell securities products and will receive additional compensation on the sale of
such products.
While our firm and our Associated Persons, as part of their fiduciary duty, endeavor to put your interest
first, you should be aware that receipt of additional compensation itself creates a potential conflict of
interest.
Institutional Intelligent Portfolios® Platform
Client accounts enrolled in the Program are maintained at, and receive the brokerage services of,
Charles Schwab & Co., Inc. (“CS&Co”), a broker-dealer registered with the Securities and Exchange
Commission and a member of FINRA and SIPC. While clients are required to use CS&Co as
custodian/broker to enroll in the Program, the client decides whether to do so and opens its account
with CS&Co by entering into a brokerage account agreement directly with CS&Co We do not open the
account for the client. If the client does not wish to place his or her assets with CS&Co, then we cannot
manage the client’s account through the Program. CS&Co may aggregate purchase and sale orders
for ETFs across accounts enrolled in the Program, including both accounts for our clients and accounts
for clients of other independent investment advisory firms using the Platform.
Schwab Advisor Services™ (formerly called Schwab Institutional) is Schwab’s business serving
independent investment advisory firms like us. Through Schwab Advisor Services, CS&Co provides us
and our clients, both those enrolled in the Program and our clients not enrolled in the Program, with
access to its institutional brokerage services — trading, custody, reporting, and related services —
many of which are not typically available to CS&Co retail customers. CS&Co also makes available
various support services. Some of those services help us manage or administer our clients’ accounts,
while others help us manage and grow our business. CS&Co’s support services described below are
generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The
availability to us of CS&Co’s products and services is not based on us giving particular investment
advice, such as buying particular securities for our clients. Here is a more detailed description of
CS&Co’s support services:
CS&Co’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. CS&Co’s services described in this
paragraph generally benefit the client and the client’s account.
CS&Co also makes available to us other products and services that benefit us but may not directly
benefit the client or its account. These products and services assist us in managing and administering
our clients’ accounts. They include investment research, both Schwab’s own and that of third parties.
We may use this research to service all or some substantial number of our clients’ accounts, including
accounts not maintained at CS&Co In addition to investment research, CS&Co also makes available
software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and account
statements);
• facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• provide pricing and other market data;
• facilitate payment of our fees from our clients’ accounts; and
• assist with back-office functions, recordkeeping, and client reporting.
CS&Co also offers other services intended to help us manage and further develop our business
enterprise. These services include:
• educational conferences and events;
• technology, compliance, legal, and business consulting;
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants, and insurance providers.
CS&Co may provide some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to us. CS&Co may also discount or waive its fees for some of these services or
pay all or a part of a third party’s fees. CS&Co may also provide us with other benefits such as
occasional business entertainment of our personnel.
Wealth Advisory Group utilizes the services offered by CS&Co to enhance and improve the services
offered to our clients.
The availability of services from CS&Co benefits us because we do not have to produce or purchase
them. We don’t have to pay for these services, and they are not contingent upon us committing any
specific amount of business to CS&Co in trading commissions or assets in custody. With respect to the
Program, as described above under Item 4 Advisory Business, we do not pay SPT fees for the
Platform so long as we maintain $100 Million in client assets in accounts at CS&Co that are not
enrolled in the Program. In light of our arrangements with Schwab, we have an incentive to
recommend that our clients maintain their accounts with CS&Co based on our interest in receiving
Schwab’s services that benefit our business rather than based on the client’s interest in receiving the
best value in custody services and the most favorable execution of transactions. This is a potential
conflict of interest. We believe, however, that our selection of CS&Co as custodian and broker is in the
best interests of our clients. It is primarily supported by the scope, quality, and price of CS&Co’s
services and not Schwab’s services that benefit only us. We have adopted policies and procedures
designed to ensure that our use of Schwab’s services is appropriate for each of our clients.
Directed Brokerage
In limited circumstances and at our sole discretion, you may instruct us to use one or more particular
brokers for the transactions in their accounts. If you want to direct us to use a particular broker should
understand that this may prevent us from effectively negotiating brokerage compensation on your
behalf and may also prevent us from obtaining the most favorable net price and execution. Moreover, if
you require that we direct brokerage you may incur additional costs for performance reporting. Thus,
when directing brokerage business, you should consider whether the commission expenses,
execution, clearance, and settlement capabilities that you will obtain through your broker are
adequately favorable in comparison to those that we would otherwise obtain for you.
We also recommend the brokerage and custodial services of BCG Securities, Inc, ("BCG") a registered
broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor
Protection Corporation. We believe that BCG provides quality execution services for you at competitive
prices. Price is not the sole factor we consider in evaluating best execution. We also consider the
quality of the brokerage services provided by BCG, including the value of research provided, the firm's
reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In
recognition of the value of research services and additional brokerage products and services BCG
provides, you may pay higher commissions and/or trading costs than those that may be available
elsewhere.
Persons providing investment advice on behalf of our firm who are registered representatives of BCG
will recommend BCG to you for brokerage services. These individuals are subject to applicable rules
that restrict them from conducting securities transactions away from BCG unless BCG provides the
representative with written authorization to do so. Therefore, these individuals are generally limited to
conducting securities transactions through BCG. It may be the case that BCG charges higher
transactions costs and/or custodial fees than another broker charges for the same types of services. If
transactions are executed though BCG, these individuals (in their separate capacities as registered
representatives of BCG) may earn commission-based compensation as result of placing the
recommended securities transactions through BCG. This practice presents a conflict of interest
because these registered representatives have an incentive to effect securities transactions for the
purpose of generating commissions rather than solely based on your needs. We mitigate this incentive
by adopting review processes that assure any recommendation of a brokerage product or service is in
the Client’s best interest. You may utilize the broker-dealer of your choice and have no obligation to
purchase or sell securities through such broker as, we recommend. However, if you do not use BCG,
we may not be able to accept your account. Please see the Fees and Compensation section in this
brochure for more information on the compensation received by registered representatives who are
affiliated with our firm.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Aggregated Trades
Transactions for each client generally will be effected independently, unless we decide to purchase or
sell the same securities for several clients at approximately the same time. We may, but are not
obligated to, combine multiple orders for shares of the same securities purchased for advisory
accounts we manage (this practice is commonly referred to as "aggregated trading"). We will then
distribute a portion of the shares to participating accounts in a fair and equitable manner. The
distribution of the shares purchased is typically proportionate to the size of the account, but it is not
based on account performance or the amount or structure of management fees. Subject to our
discretion regarding factual and market conditions, when we combine orders, each participating
account pays an average price per share for all transactions and pays a proportionate share of all
transaction costs on any given day. Accounts owned by our firm or persons associated with our firm
may participate in block trading with your accounts; however, they will not be given preferential
treatment.
Item 13 Review of Accounts
The Wealth Advisory Group, Inc. Engagement Agreements, Financial Planning, or Investment Advisory
Agreements with you will specify the reports, if any, that will be provided to you, including the type of
report and the frequency with which the reports will be presented to you. Reports, including investment
tracking reports, asset review or analysis reports, or net worth or portfolio valuation reports will be
periodically reviewed by the adviser representative assigned to your account.
You will receive trade confirmations and monthly or quarterly statements from your account
custodian(s).
Item 14 Client Referrals and Other Compensation
We receive an economic benefit from Schwab in the form of the support products and services it
makes available to us. These products and services, how they benefit us, and the related conflicts of
interest are described above under Item 12 Brokerage Practices. The availability to us of Schwab’s
products and services is not based on us giving particular investment advice, such as buying particular
securities for our clients.
As disclosed under the Fees and Compensation section in this brochure, persons providing investment
advice on behalf of our firm are licensed insurance agents, and are registered representatives with
BCG, a registered broker-dealer, and a member of the Financial Industry Regulatory Authority and the
Securities Investor Protection Corporation. For information on the conflicts of interest this presents,
and how we address these conflicts, please refer to the Fees and Compensation section.
Item 15 Custody
Your independent custodian will directly debit your account(s) for the payment of our advisory fees.
This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody
over your funds or securities. We do not have physical custody of any of your funds and/or securities.
Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified
custodian. You will receive account statements from the independent, qualified custodian(s) holding
your funds and securities at least quarterly. The account statements from your custodian(s) will
indicate the amount of our advisory fees deducted from your account(s) each billing period. You should
carefully review account statements for accuracy. If you have a question regarding your account
statement or if you did not receive a statement from your custodian, please contact us directly at the
telephone number on the cover page of this brochure.
Under government regulations, we are deemed to have custody of a client’s assets if the client
authorizes us to instruct CS&Co to deduct our advisory fees directly from the client’s account. This is
the case for accounts in the Program. CS&Co maintains actual custody of clients’ assets. Clients
receive account statements directly from CS&Co at least quarterly. They will be sent to the email or
postal mailing address the client provides to CS&Co Clients should carefully review those statements
promptly when received. We also urge clients to compare CS&Co’s account statements to the periodic
portfolio reports clients receive from us.
Wire Transfer and/or Check-Writing Authority and/or Standing Letter of Authorization
Our firm, or persons associated with our firm, may effect wire transfers from client accounts to one or
more third parties designated, in writing, by the client without obtaining written client consent for each
separate, individual transaction, or we may have signatory and check writing authority for client
accounts, as long as the client has provided us with written authorization to do so. Such written
authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such
third party wire transfers or to sign checks on a client's behalf has access to the client's assets, and
therefore has custody of the client's assets in any related accounts.
However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by
reason of having custody, as long as we meet the following criteria:
1. You provide a written, signed instruction to the qualified custodian that includes the third party’s
name and address or account number at a custodian;
2. You authorize us in writing to direct transfers to the third party either on a specified schedule or
from time to time;
3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a
transfer of funds notice to you promptly after each transfer;
4. You can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at the
same address as us; and
7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an
annual notice reconfirming the instruction.
We hereby confirm that we meet the above criteria.
Item 16 Investment Discretion
Before we can buy or sell securities on your behalf, you must first sign our Investment Management
agreement, a power of attorney, and/or trading authorization forms.
You will typically grant our firm discretion over the selection and amount of securities to be purchased
or sold for your account(s) without obtaining your consent or approval prior to each transaction. You
may specify investment objectives, guidelines, and/or impose reasonable conditions or investment
parameters for your account(s). For example, you may specify that the investment in any particular
stock or industry should not exceed specified percentages of the value of the portfolio and/or
restrictions or prohibitions of transactions in the securities of a specific industry or security. Please
refer to the Advisory Business section in this brochure for more information on our discretionary
management services.
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to
implement any advice provided by our firm on a non-discretionary basis.
Item 17 Voting Client Securities
We will not vote proxies on behalf of your advisory accounts unless our Agreement specifies
otherwise. At your request, we may offer you advice regarding corporate actions and the exercise of
your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for
exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we were to receive any written or electronic proxy materials, we would forward them directly to
you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we
would forward any electronic solicitation to vote proxies.
Item 18 Financial Information
We are not required to provide financial information to our clients because we do not:
• require the prepayment of more than $1,200 in fees and six or more months in advance, or
• take custody of client funds or securities, or
• have a financial condition that is reasonably likely to impair our ability to meet our commitments
to you.
Item 19 Requirements for State Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this
item.
Item 20 Additional Information
Your Privacy
We view protecting your private information as a top priority. Pursuant to applicable privacy
requirements, we have instituted policies and procedures to ensure that we keep your personal
information private and secure.
We do not disclose any non-public personal information about you to any non-affiliated third parties,
except as permitted by law. In the course of servicing your account, we share some information with
our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants,
and attorneys.
We restrict internal access to non-public personal information about you to employees, who need that
information in order to provide products or services to you. We maintain physical and procedural
safeguards that comply with regulatory standards to guard your non-public personal information and to
ensure our integrity and confidentiality. We will not sell information about you or your accounts to
anyone. We do not share your information unless it is required to process a transaction, at your
request, or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with
our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual
basis. Please contact our main office at the telephone number on the cover page of this brochure if you
have any questions regarding this policy.
Trade Errors
On infrequent occasions, an error may be made in your account. For example, a security may be
erroneously purchased for the account instead of sold. In these situations, we generally seek to rectify
the error by placing your account in a similar position as it would have been had there been no error.
Depending on the circumstances, various corrective steps may be taken, including among others
canceling the trade or adjusting an allocation.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.