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Wealth Effects LLC
Form ADV Part 2A – Disclosure Brochure
Effective: February 13, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Wealth Effects LLC (“Wealth Effects” or the “Advisor”). If you have any questions about the content of
this Disclosure Brochure, please contact the Advisor at 617-465-2560.
Wealth Effects is a registered investment advisor with the U.S. Securities and Exchange Commission. The
information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange
Commission (“SEC”) or by any state securities authority. Registration of an investment advisor does not imply any
specific level of skill or training. This Disclosure Brochure provides information about Wealth Effects to assist you in
determining whether to retain the Advisor.
Additional information about Wealth Effects and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 315244.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com/
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 the Advisory
Persons of Wealth Effects. For convenience, the Advisor has combined these documents into a single disclosure
document.
Wealth Effects believes that communication and transparency are the foundation of its relationship with clients and
will continually strive to provide you with complete and accurate information at all times. Wealth Effects encourages
all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with
the Advisor.
Material Changes
The following material changes have been mande to this Disclosure Brochure since the last annual amendment
filing on January 29th, 2025:
• The Advisor now offers Retirement Plan Advisory Services. Please see Items 4 and 5 for additional
information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
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 by searching with the Advisor’s firm name or CRD# 315244. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 617-797-4276.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents ..................................................................................................................................... 3
Item 4 – Advisory Services .................................................................................................................................... 4
A. Firm Information ................................................................................................................................................................ 4
B. Advisory Services Offered ............................................................................................................................................... 4
C. Client Account Management ........................................................................................................................................... 6
D. Wrap Fee Programs ........................................................................................................................................................ 6
E. Assets Under Management ............................................................................................................................................. 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services.............................................................................................................................................. 6
B. Fee Billing........................................................................................................................................................................ 7
C. Other Fees and Expenses .............................................................................................................................................. 7
D. Advance Payment of Fees and Termination ................................................................................................................... 7
E. Compensation for Sales of Securities ............................................................................................................................. 8
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8
Item 7 – Types of Clients ....................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8
A. Methods of Analysis ........................................................................................................................................................ 8
B. Risk of Loss ..................................................................................................................................................................... 9
Item 9 – Disciplinary Information ........................................................................................................................ 10
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 10
A. Code of Ethics ............................................................................................................................................................... 10
B. Personal Trading with Material Interest ......................................................................................................................... 10
C. Personal Trading in Same Securities as Clients ........................................................................................................... 11
D. Personal Trading at Same Time as Client .................................................................................................................... 11
Item 12 – Brokerage Practices ............................................................................................................................ 11
A. Recommendation of Custodian[s] ................................................................................................................................. 11
B. Aggregating and Allocating Trades ............................................................................................................................... 12
Item 13 – Review of Accounts ............................................................................................................................. 12
A. Frequency of Reviews ................................................................................................................................................... 12
B. Causes for Reviews ...................................................................................................................................................... 12
C. Review Reports ............................................................................................................................................................. 12
Item 14 – Client Referrals and Other Compensation ........................................................................................ 12
A. Compensation Received by Wealth Effects .................................................................................................................. 12
B. Compensation for Client Referrals ................................................................................................................................ 13
Item 15 – Custody ................................................................................................................................................. 13
Item 16 – Investment Discretion ......................................................................................................................... 13
Item 17 – Voting Client Securities ....................................................................................................................... 13
Item 18 – Financial Information ........................................................................................................................... 13
Form ADV Part 2B – Brochure Supplement ....................................................................................................... 14
Privacy Policy ....................................................................................................................................................... 16
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 3
Item 4 – Advisory Services
A. Firm Information
Wealth Effects LLC (“Wealth Effects” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the
Commonwealth of Massachusetts. Wealth Effects was founded in June 2021 and is owned and operated by
William A. Liberti (Chief Executive Officer and Chief Compliance Officer). This Disclosure Brochure provides
information regarding the qualifications, business practices, and the advisory services provided by Wealth Effects.
B. Advisory Services Offered
Wealth Effects offers investment advisory services to individuals, high net worth individuals, trusts, estates,
retirement plans, and businesses (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Wealth Effects’ fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Wealth Management Services
Wealth Effects provides customized wealth management services for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary investment management services
and a broad range of comprehensive financial planning. These services are listed below.
Investment Management Services – Wealth Effects provides discretionary investment management services.
Wealth Effects works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. Wealth Effects will then construct an
investment portfolio primarily consisting of individual stocks, exchange-traded funds (“ETFs”), mutual funds, bonds,
or option contracts to meet the needs of its Clients. The Advisor may retain other types of investments from the
Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as
identified between the Advisor and the Client
Wealth Effects’ investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Wealth Effects will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by
the Advisor.
Wealth Effects evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Wealth Effects may recommend, on occasion, redistributing investment allocations to diversify
the portfolio. Wealth Effects may recommend specific positions to increase sector or asset class weightings. The
Advisor may recommend employing cash positions as a possible hedge against market movement. Wealth Effects
may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses,
business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the
position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 4
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
At no time will Wealth Effects accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services – Wealth Effects provides a variety of financial planning and consulting services to
Clients as part of its wealth management services. Services are offered in several areas of a Client’s financial
situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a
formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and
objectives. This planning or consulting may encompass one or more areas of need, including but not limited to,
investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of
a Client’s financial situation.
A financial plan Id for, or financial consultation rendered to the Client will usually include general recommendations
for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made
that the Client start or revise their investment programs, commence or alter retirement savings, establish education
savings and/or charitable giving programs.
Wealth Effects may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
Wealth Effects provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Oversight (ERISA 3(21))
• Plan Participant Enrollment and Education Tracking
•
•
• Ongoing Investment Recommendation and Assistance
These services are provided by Wealth Effects serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 5
Plan Sponsor is provided with a written description of Wealth Effects’s fiduciary status, the specific services to be
rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Wealth Effects to provide investment advisory services, each Client is required to enter into an
agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – Wealth Effects, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Wealth Effects will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Wealth Effects will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
•
Investment Management and Supervision – Wealth Effects will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Wealth Effects does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by Wealth Effects.
E. Assets Under Management
As of December 31, 2025, Wealth Effects manages $472,000,000 in Client assets, all of which is managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid monthly, in advance of each month, pursuant to the terms of the wealth
management agreement. Wealth management fees are based on the market value of assets under management at
the end of the prior calendar month. Wealth management fees range up to 1.50% annually based on several factors,
including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall
relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio
restrictions and other complexities may be charged a higher fee.
The wealth management fee in the first month of service is prorated from the inception date of the account[s] to the
end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
Wealth Effects will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the
Custodian’s valuation to ensure accurate billing
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 6
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00% annually, typically
payable at the end of billing period, pursuant to the terms of the retirement plan advisory agreements. Retirement plan
advisory fees may be negotiable depending on the size and complexity of the Plan.
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at the beginning of the] respective month. The amount due is calculated by applying the
monthly rate (annual rate divided by 12) to the total assets under management with Wealth Effects at the end of the
prior calendar month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting
deduction of the wealth management fee. It is the responsibility of the Client to verify the accuracy of these fees as
listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide
written authorization permitting advisory fees to be deducted by Wealth Effects to be paid directly from their
account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided
by the Custodian.
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan,
depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Wealth Effects, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, as applicable. Currently, the Advisor’s recommended Custodian does not
charge securities transaction fees for ETF and equity trades in a Client’s account, provided that the account meets
the terms and conditions of the Custodian’s brokerage requirements. However, the Custodian’s fees are subject to
change at their discretion and typically charge for mutual funds and other types of investments. The fees charged
by Wealth Effects are separate and distinct from these custody and execution fees.
In addition, all fees paid to Wealth Effects for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for
the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of Wealth
Effects, but would not receive the services provided by Wealth Effects which are designed, among other things, to
assist the Client in determining which products or services are most appropriate for each Client’s financial situation
and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by
Wealth Effects to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for
additional information.
D. Advance Payment of Fees and Termination
Wealth Management Services
Wealth Effects may be compensated for its wealth management services in advance of the month in which services
are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance
written notice to the other party. The Client may also terminate the wealth management agreement within five (5)
business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur
charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by
the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the
effective date of termination to the end of the month. The Client’s wealth management agreement with the Advisor is
non-transferable without the Client’s prior consent.
Retirement Plan Advisory Services
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 7
Wealth Effects is typically compensated for its services at the end of the billing period, after retirement plan advisory
services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing
advance written notice to the other party. The Client may also terminate the retirement plan advisory agreement within
five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client
will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
payable by the Client. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the
Client’s prior consent.
E. Compensation for Sales of Securities
Wealth Effects does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the wealth management fees noted above.
Insurance Agency Affiliation
Certain Advisory Persons are licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person may earn commission-based compensation for selling insurance products,
including insurance products offered to Clients. Insurance commissions earned by the Advisory Person are
separate and in addition to investment advisory fees. This practice presents a conflict of interest as an Advisory
Person who is also an insurance professional will have an incentive to recommend insurance products to the Client
for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are under no
obligation, contractual or otherwise, to purchase insurance products through any Advisory Person affiliated with the
Advisor. Please see Item 10 below.
Item 6 – Performance-Based Fees and Side-By-Side Management
Wealth Effects does not charge performance-based fees for its wealth management services. The fees charged by
Wealth Effects are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client.
Wealth Effects does not manage any proprietary investment funds or limited partnerships (for example, a mutual
fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
Wealth Effects offers wealth management services to individuals, high net worth individuals, trusts, estates,
retirement plans, and businesses. Wealth Effects generally does not impose a minimum relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Wealth Effects primarily employs a fundamental and technical analysis methods in developing investment
strategies for its Clients. Research and analysis from Wealth Effects are derived from numerous sources, including
financial media companies, third-party research materials, Internet sources, and review of company activities,
including annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with
a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment,
it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in
the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors
these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Advisor’s review process are included below in Item 13 – Review of Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 8
trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk
in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if
the trend will eventually reoccur, there is no guarantee that Wealth Effects will be able to accurately predict such a
reoccurrence.
As noted above, Wealth Effects generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. Wealth Effects will typically hold all or a portion of a security for more than a year, but may hold
for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Wealth
Effects may also buy and sell positions that are more short-term in nature, depending on the goals of the Client
and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Wealth Effects will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client’s account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond’s time to maturity, and the coupon
rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than
was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that
exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk
associated with purchasing a debt instrument which includes the possibility of the company defaulting on its
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 9
repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the
company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity
Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts
are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory, or disciplinary events involving Wealth Effects or its management persons.
Wealth Effects values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the
requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor
or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov
by searching with the Advisor’s firm name or CRD# 315244.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliation
As noted in Item 5, certain Advisory Persons are licensed insurance professionals. Implementations of insurance
recommendations are separate and apart from one’s role with the Advisor. As an insurance professional, the Advisory
Person will receive customary commissions and other related revenues from the various insurance companies whose
products are sold. Advisory Persons are not required to offer the products of any particular insurance company.
Commissions generated by insurance sales do not offset investment advisory fees. This presents a conflict of interest
in recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by the Advisor or Advisory Persons.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Wealth Effects has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with Wealth Effects (“Supervised Persons”). The Code
was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each
Client. Wealth Effects and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each
Client. It is the obligation of Wealth Effects’s Supervised Persons to adhere not only to the specific provisions of the
Code, but also to the general principles that guide the Code. The Code covers a range of topics that address
employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at 617-797-
4276.
B. Personal Trading with Material Interest
Wealth Effects allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Wealth Effects does not act as principal in any transactions. In addition, the
Advisor does not act as the general partner of a fund, or advise an investment company. Wealth Effects does not
have a material interest in any securities traded in Client accounts.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 10
C. Personal Trading in Same Securities as Clients
Wealth Effects allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by Wealth Effects requiring reporting of personal securities trades by its Supervised Persons for review by
the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the
misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Wealth Effects allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards.
At no time will Wealth Effects, or any Supervised Person of Wealth Effects, transact in any security to the
detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Wealth Effects does not have discretionary authority to select the broker-dealer/custodian for custody and
execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client
assets and authorize Wealth Effects to direct trades to the Custodian as agreed upon in the wealth management
agreement. Further, Wealth Effects does not have the discretionary authority to negotiate commissions on behalf of
Clients on a trade-by-trade basis.
Where Wealth Effects does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian
recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not
recommended by Wealth Effects. However, the Advisor may be limited in the services it can provide if the
recommended Custodian is not engaged. Wealth Effects may recommend the Custodian based on criteria such as,
but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and
its reputation and/or the location of the Custodian’s offices.
Wealth Effects will generally recommend that Clients establish their account[s] with Fidelity Clearing and Custody
Solutions and related divisions of Fidelity Investments, Inc. (collectively “Fidelity”), a FINRA-registered broker-
dealer and member SIPC. Fidelity will serve as the Client’s “qualified custodian”. The Advisor maintains an
institutional relationship with Fidelity, whereby the Advisor receives economic benefits from Fidelity. Please see
Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. Wealth Effects does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian.
Please see Item 14 below.
2. Brokerage Referrals - Wealth Effects does not receive any compensation from any third party in connection
with the recommendation for establishing an account.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 11
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Wealth Effects will place
trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are
traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any
security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a
security into one Client account from another Client’s account[s]). Wealth Effects will not be obligated to select
competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction
costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in 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 the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. Wealth Effects will execute its transactions through the
Custodian as authorized by the Client. Wealth Effects may aggregate orders in a block trade or trades when
securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading
day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold
by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or
other written statement. This must be done in a way that does not consistently advantage or disadvantage any
particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons and periodically
reviewed by Mr. William Liberti, Chief Compliance Officer of Wealth Effects. Formal reviews are generally
conducted at least annually or more frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify Wealth Effects if changes occur in the
Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may
be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also
provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Wealth Effects
Wealth Effects is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment
product. Wealth Effects does not receive commissions or other compensation from product sponsors, broker-dealers
or any un-related third party. Wealth Effects may refer Clients to various unaffiliated, non-advisory professionals (e.g.
attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its
Clients. Likewise, Wealth Effects may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform
Wealth Effects has established an institutional relationship with Fidelity to assist the Advisor in managing Client
account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Advisor receives access to
software and related support without cost because the Advisor renders investment management services to Clients
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 12
that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its
Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its
Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a
conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that
does not furnish similar software, systems support, or services.
Additionally, the Advisor has the following benefits from Fidelity: financing services, receipt of duplicate Client
confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional
participants; access to block trading which provides the ability to aggregate securities transactions and then
allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client
order entry and account information.
B. Compensation for Client Referrals
Wealth Effects does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have
custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have
adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
Item 16 – Investment Discretion
Wealth Effects generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to
by Wealth Effects. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of
such authority will be evidenced by the Client's execution of a wealth management agreement containing all
applicable limitations to such authority. All discretionary trades made by Wealth Effects will be in accordance with
each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Wealth Effects does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client
retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Wealth Effects, nor its management, have any adverse financial situations that would reasonably impair the
ability of Wealth Effects to meet all obligations to its Clients. Neither Wealth Effects, nor any of its Advisory
Persons, have been subject to a bankruptcy or financial compromise. Wealth Effects is not required to deliver a
balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more
for services to be performed six months or more in the future.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 13
Form ADV Part 2B – Brochure Supplement
for
William A. Liberti
CEO and Chief Compliance Officer
Effective: February 13, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
William A. Liberti (CRD# 1731862) in addition to the information contained in the Wealth Effects LLC (“Wealth
Effects” or the “Advisor”, CRD# 315244) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Wealth Effects Disclosure Brochure or this
Brochure Supplement, please contact us at 617-465-2560.
Additional information about Mr. Liberti is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1731862.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 14
Item 2 – Educational Background and Business Experience
William A. Liberti, born in 1961, is dedicated to advising Clients of Wealth Effects as the Chief Executive Officer and
Chief Compliance Officer. Mr. Liberti earned a Bachelors of Science in Aeronautical Engineering from Embry-
Riddle Aeronautical University in 1983. Mr. Liberti also attended Boston College Carroll School of Management for
a Masters in Finance in 1987. Additional information regarding Mr. Liberti’s employment history is included below.
Employment History:
Chief Executive Officer and Chief Compliance Officer, Wealth Effects LLC
Senior Vice President of Investments, Coburn & Meredith, Inc.
First Vice President of Investments, Smith Barney
07/2021 to Present
01/2006 to 07/2021
07/1987 to 01/2006
Item 3 – Disciplinary Information
There are no legal, civil, or disciplinary events to disclose regarding Mr. Liberti. Mr. Liberti has never been
involved in any regulatory, civil, or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Liberti.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. As previously noted, there are no
legal, civil, or disciplinary events to disclose regarding Mr. Liberti.
However, we do encourage you to independently view the background of Mr. Liberti on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
1731862.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Liberti is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Liberti’s role with Wealth Effects. As an insurance professional, Mr. Liberti will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Liberti is not required to offer the products of any particular insurance company. Commissions generated
by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Liberti or the Advisor. Mr. Liberti spends approximately 5% of his time per month in this capacity.
Item 5 – Additional Compensation
Mr. Liberti has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Liberti serves as the Chief Executive Officer and Chief Compliance Officer of Wealth Effects. Mr. Liberti can be
reached at 617-465-2560.
Wealth Effects has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Wealth Effects. Further, Wealth Effects is subject to
regulatory oversight by various agencies. These agencies require registration by Wealth Effects and its Supervised
Persons. As a registered entity, Wealth Effects is subject to examinations by regulators, which may be announced
or unannounced. Wealth Effects is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 15
Privacy Policy
Effective: February 13, 2026
Our Commitment to You
Wealth Effects LLC (“Wealth Effects” or the “Advisor”) is committed to safeguarding the use of personal information
of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in
our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. Wealth Effects (also referred to as "we", "our"
and "us”) protects the security and confidentiality of the personal information we have and implements controls to
ensure that such information is used for proper business purposes in connection with the management or servicing
of our relationship with you.
Wealth Effects does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management of
our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 16
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you
limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
Wealth Effects does not disclose, and does not intend to disclose,
personal information with non-affiliated third parties to offer you services.
Certain laws may give us the right to share your personal information with
financial institutions where you are a customer and where Wealth Effects
or the client has a formal agreement with the financial institution. We will
only share information for purposes of servicing your accounts, not
for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
Wealth Effects does not disclose and does not intend to disclose, non-
public personal information to non-affiliated third parties with respect to
persons who are no longer our Clients.
State-specific Regulations
Massachusetts
In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third
parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of
authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other
written consent by the Client, as appropriate and consistent with applicable laws and regulations.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at 617-465-2560.
Wealth Effects LLC
265 Franklin Street, Suite 1702, Boston, MA 02110
Phone: 617-465-2560
https://www.w-effects.com
Page 17