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ITEM 1: COVER PAGE
Part 2A of Form ADV
The Brochure
2900 Warm Springs Rd.
Columbus, Georgia, 31904
(470) 745-5030
www.wealthintel.com
This Brochure provides information about the qualifications and business practices of Wealth
Intelligence, LLC (“WEALTH INTEL”). If you have questions about the contents of this Brochure,
please contact us at (470) 745-5030. The information in the Brochure has not been approved or verified
by the United States Securities and Exchange Commission (the “SEC”) or by any state securities
authority.
As reflected in this Brochure, WEALTH INTEL is a registered investment adviser under the Investment
Advisers Act of 1940, as amended. Registration with the SEC or with any state securities authority does
not imply any certain level of skill or training.
Additional information about WEALTH INTEL is also available on the SEC’s website
at www.adviserinfo.sec.gov.
You can search this site by a unique identifying number, known as a CRD number.
The CRD number for WEALTH INTEL is 333253.
The date of this Brochure is September 4, 2025
WEALTH INTEL ADV Part 2 – September 2025
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ITEM 2: MATERIAL CHANGES
This page will discuss the material changes made to the Wealth Intelligence, LLC Form ADV Part 2A
(“Brochure”) since our Annual Amendment filing on February 14, 2025.
•
•
In September 2025, Torian Johnson replaced Alfredo Gonzalez as Chief Compliance Officer.
In July 2025, WEALTH INTEL engaged in a contract to add Charles Schwab & Co., Inc. as custodian of
assets under management.
WEALTH INTEL ADV Part 2 – September 2025
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ITEM 3: TABLE OF CONTENTS
Item 1: Cover Page …………………………………………………………………………………
1
Item 2: Material Changes ..................................................................................................................
2
Item 3: Table of Contents .................................................................................................................
3
Item 4: Advisory Business ...............................................................................................................
4
(A) Firm Description ………………………………………………...………...................
(B) Types of Advisory Services ………………………………………...………………...
(1) Wealth Management Advisory Services Program ………..………………………
(2) Wealth Management and Investment Advisory Services Program ....……………
(3) Business Consulting……………………..……………………………………….
(4) Family Office Service.……………………………………………………………
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(C) Pooled Investment Vehicles ………………………………………………………….
(D) Retirement Plans and Individual Retirement Accounts………………………………
Item 5: Fees and Compensation ...................................................................................................….
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Item 6: Performance Based Fees and Side-by-Side Management.....................................………...
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Item 7: Types of Clients ..................................................................................................................
10
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ............................................
(A) Investment Philosophy and Strategies ………………………………………………
(B) Risks of WEALTH INTEL Investment Programs and Strategies……………………
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Item 9: Disciplinary Information ......................................................................................................
12
Item 10: Other Financial Industry Activities and Affiliations ..........................................................
12
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ….
12
Item 12: Brokerage Practices ............................................................................................................
13
Item 13: Review of Accounts ............................................................................................................
13
Item 14: Client Referrals and Other Compensation.............................................................………
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Item 15: Custody……………………………………........................................................................
14
Item 16: Investment Discretion ...........................................................................................……...
14
Item 17: Voting Client Securities ......................................................................................................
14
Item 18: Financial Information .........................................................................................................
14
WEALTH INTEL ADV Part 2 – September 2025
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ITEM 4: ADVISORY BUSINESS
(A) Firm Description
Wealth Intelligence, LLC (“WEALTH INTEL”) is an integrated wealth management organization
providing multi-generational financial services. WEALTH INTEL provides comprehensive wealth
management, for individuals, families, businesses, and institutions, including private foundations and
family entities. WEALTH INTEL also provides family office services, including financial planning,
consulting, expense management, bill pay, concierge services, philanthropic management, tax
compliance/tax return preparation to individuals, investment limited partnerships, pension and profit-
sharing plans, trusts, estates, charitable organizations, corporations and business entities.
• Wealth Intelligence is solely owned by Bryan Oglesby.
• Wealth Intel filed its initial application to become registered as an investment adviser in
September 2024
WEALTH INTEL’s officers are as follows:
Bryan Oglesby
Torian Johnson
Alfredo Gonzalez
Chief Executive Officer &
Chief Compliance Officer
Strategic Compliance Officer
Additional information about WEALTH INTEL is available on the Internet at www.adviserinfo.sec.gov.
You can search this site by a unique identifying number, known as a CRD number. The CRD number for
WEALTH INTEL is 333253.
(B) Types of Advisory Services
WEALTH INTEL offers its clients four basic types of advisory service programs: (1) comprehensive
Wealth Management Advisory Services (“WMAS”) Program providing a wide range of financial, risk
management and investment advisory services; (2) comprehensive Wealth Management and Investment
Advisory Services (“WMIAS”) program providing, on a non-discretionary, non-custodial basis,
financial oversight, asset allocation strategies and investment advisory services; (3) Business
Consulting; and (4) Family Office Services (“FOS”) to ultra-high-net worth families. These programs
are described in detail below:
(1) Wealth Management Advisory Services Program
WEALTH INTEL’s Wealth Management Advisory Services program is a comprehensive financial, risk
management and investment advisory program that bundles together certain services as described below.
As a participant in the WMAS Program, each WMAS client is entitled to utilize the full range of such
services, as needed from time to time. The foundation of the WMAS Program is its broad-based,
independent, and comprehensive approach to financial management. The following services are
included in this Program:
(a) Financial, Estate Planning, and Consulting
WEALTH INTEL works with each WMAS client to develop a comprehensive financial/estate planning
and investment program for the client and all “Covered Client Parties” based on the client’s individual
WEALTH INTEL ADV Part 2 – September 2025
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financial needs, objectives, and circumstances.1 As part of the planning process, WEALTH INTEL
reviews background information and existing estate and investment documentation as needed to create
the program. WEALTH INTEL then coordinates and documents such relationships with third-party
service providers (including investment managers, custodians, attorneys, and other professionals) as
may be required to implement the program. On an ongoing basis throughout the term of the client’s
WMAS agreement, WEALTH INTEL consults with and makes recommendations to the client with
respect to the program components, as well as with respect to the handling of such investment, tax, cash
flow, risk management and estate planning matters and issues as may need to be addressed from time to
time.
The nature of WEALTH INTEL’s role and comprehensive annual services in developing and
implementing a financial/estate planning and investment program will vary from client to client.
However, in all cases, the services will include a comprehensive annual review of the client’s financial,
estate, tax, risk management and philanthropic affairs. Based on this annual review, WEALTH INTEL
will develop a checklist of action items to be accomplished to address any issues or desired changes in
the client’s program. WEALTH INTEL will meet with the client periodically throughout the term of the
client’s WMAS agreement to provide updates on progress in making any required changes to the client’s
program.
As part of WEALTH INTEL’s estate planning review and consultation services, WEALTH INTEL
coordinates and oversees the services of the client’s legal and accounting professionals. WEALTH
INTEL meets with such professionals as needed to ensure that the client’s financial/estate planning and
investment program is properly implemented and documented.
(b) Investment Advisory and Portfolio Management Services
WEALTH INTEL provides each WMAS client with investment advisory, management, and reporting
services. Client accounts are managed on either a discretionary or non-discretionary basis, principally
using a team of third-party investment managers and funds. WEALTH INTEL’s main role is to act as a
“manager of managers” for these accounts.
Portfolio allocations are guided by the objectives of the client as stated with their “Investment
Objective” statement (i.e., aggressive growth, growth, moderate growth, conservative, principal
stability), considering the client’s tolerance for risk and volatility.
Recommendations for each client are incorporated into a written “Investment Objective” for the client.
WEALTH INTEL then assists the client in creating the portfolio, monitors the investments and
periodically reports to the client on its performance. The client’s Investment Objective is reviewed
periodically and updated as needed to reflect any changes in the client’s financial needs, objectives, and
circumstances.
1 For each client entering into a WMAS Advisory agreement with WEALTH INTEL, “Covered Client Parties” means
all of the following: (a) the spouse and minor children of the client (provided that the client’s spouse authorizes
WEALTH INTEL in writing to act for him/her); (b) any trust, partnership, corporation or other entity controlled by or
benefiting the client or his/her spouse or minor children, provided it was formed for a purpose related to their estate,
financial, investment or family planning (e.g., not a for-profit operating business); (c) any child of the client or the
client’s spouse who is between 18 and 25 years old and is a full-time student (provided that such child authorizes
WEALTH INTEL in writing to act for him/her); and (d) other related persons and entities as WEALTH INTEL agrees
in writing to cover.
WEALTH INTEL ADV Part 2 – September 2025
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Any client can restrict the types of investments that are included in such clients’ portfolios. Clients retain
individual ownership of all securities and non-securities, which are custodied with independent third-
party custodians. As part of its services, WEALTH INTEL assists each of its clients in the establishment
and monitoring of these separate custody accounts. WEALTH INTEL does not receive any portion of
the fees charged by any custodian for its services.
(c) Tax Planning and Coordination
WEALTH INTEL provides each WMAS client with access to comprehensive tax planning, reporting
and compliance services. Partnering with our network of professionals, a trusted 3rd party prepares
and/or reviews all tax returns for the client and generally makes payments from the client’s accounts
to cover all estimated and final tax liabilities.
(d) Insurance and Risk Management
WEALTH INTEL consults with each WMAS client with respect to and provides the client with assistance
in obtaining and monitoring insurance appropriate for the client’s lifestyle, including life, health, and
casualty insurance. WEALTH INTEL also advises clients about loans, mortgages, and other financing
arrangements. As part of this service, WEALTH INTEL works directly with lenders to negotiate terms
and document the client’s loans.
(e) Trustee Services
If the use of a third-party trustee (whether an institutional trustee or an individual trustee) is needed for a
WMAS client, WEALTH INTEL will assist the client in establishing criteria and selecting such a
trustee. Under certain circumstances, a Member may agree to act as an individual trustee for client
accounts. If an institutional trustee is desired, WEALTH INTEL will perform searches for various
institutional trustees and will recommend which institutional trustees may be appropriate to meet the
client’s needs. Factors considered in making such recommendations include account size, risk tolerance,
the client’s opinion, and the investment philosophy of the institutional trustee. WEALTH INTEL does
not receive any referral compensation from any selected institutional trustee. If WEALTH INTEL
determines that a trustee is performing inadequately, then WEALTH INTEL will recommend that the
client change trustees and will assist the client in selecting a new replacement trustee.
(f) Lifestyle Management
If desired by a WMAS client, WEALTH INTEL may connect clients with a trusted 3rd party network
professional to provide various additional services generally categorized as “Lifestyle
Management” services, including bill paying and individualized cash flow management services.
Certain of these services may require additional fees or costs, charged by the trusted partner, which will
be passed along to the client.
(g) Donor Advised Funds
WEALTH INTEL has a long history of supporting our WMAS clients’ philanthropic programs. Among
the services available are investment management services for private charitable foundations, assistance
in planning and structuring private charitable gifting programs (such as structured gifts, grantor retained
annuity trusts and charitable lead annuity trusts), and administrative, regulatory and tax management
WEALTH INTEL ADV Part 2 – September 2025
Page 6
services. Certain of these services may require additional fees or costs, which will be agreed upon in
writing by the client and Wealth Intel.
(2) Wealth Management and Investment Advisory Services Program
WEALTH INTEL’s Wealth Management and Investment Advisory Services Program (the
“WMIAS Program”) is a comprehensive financial and investment advisory program, similar to the
WMAS Program, except WEALTH INTEL, on a non-discretionary, non-custodial basis, will monitor
and report on client accounts, not manage. With that distinction in mind, the abovementioned WMAS
Program services (see Item 4(B)(1)(a)-(g) above) are also offered to clients in the WMIAS Program.
(3) Business Consulting
WEALTH INTEL also provides business advisory consulting services. WEALTH INTEL members
,employees, and network partners have the skills, experience, and knowledge of different aspects of
business, legal, and market forces. After listening to our client’s concerns, we identify, analyze, and
solve business issues by planning and executing business strategies consistent with a client’s overall
financial needs, obligations, and circumstances. WEALTH INTEL provides tax, legal, or accounting
advice through our network of qualified CPAs and attorneys.
(4) Family Office
WEALTH INTEL provides family office services, including financial planning, consulting, expense
management, bill pay, concierge services, philanthropic management, tax strategies, investment limited
partnerships, pension and profit- sharing plans, trusts, estates, charitable organizations, corporations and
business entities.
WEALTH INTEL advises private family clients by delivering tailored family-centric wealth management
services and solutions which are customized to address each family’s wealth dynamic. These tailored services
are based on a comprehensive understanding of each client’s unique circumstances, asset base, interests and
financial goals. WEALTH INTEL will assist clients in determining the client’s investment needs and
objectives, as well as risk tolerance through the use of an asset optimization model for asset allocation and
research on investment managers and investments. Clients are permitted to place reasonable restrictions on
investing in certain securities and may also request that WEALTH INTEL refrain from recommending
affiliated private investment funds to them. In addition to the family office services to ultra-high-net worth
families, WEALTH INTEL also provides investment management services on a discretionary or non-
discretionary basis to institutional investors and foundations.
Whether a client relationship is discretionary or non-discretionary, our services may often include family
office services, as further described below. However, clients may retain us for only our investment advisory
services, with no family office service component (e.g., institutional or private foundations). Multi-
generational families will typically hire WEALTH INTEL for both investment advisory services and a broad
range of family office services.
(C) Pooled Investment Vehicles
WEALTH INTEL uses an array of limited liability companies (“WEALTH INTEL Pooled Investment
Vehicles”) to facilitate investment by its advisory clients in various types of programs, including
publicly traded securities, private equity, venture capital and alternative investment programs. WEALTH
WEALTH INTEL ADV Part 2 – September 2025
Page 7
INTEL, WEALTH INTEL Pooled Investment Vehicles and/or the Members may also be limited
partners, general partners, members, or managers of such WEALTH INTEL Pooled Investment
Vehicles. (Please refer to the disclosure in Item 11 of this Brochure for information on WEALTH
INTEL’s policies and procedures for instances where either WEALTH INTEL and/or any Members may
have a personal interest in client transactions.) In many cases these WEALTH INTEL Pooled
Investment Vehicles provide access to investment funds and managers that otherwise would not be open
to individuals because of high investment account minimums, high fees, fund closure to new investors,
or other reasons.
Each WEALTH INTEL Pooled Investment Vehicle pays the fees and expenses associated with such
Vehicle's investments and business activities, including legal, accounting, custody, and third-party
investment management fees. WEALTH INTEL does not receive any investment management or
advisory fees from any WEALTH INTEL Pooled Investment Vehicle. WEALTH INTEL is, however,
entitled to be reimbursed for expenses incurred for any accounting and tax services provided to, as well
as some manager diligence costs, for such Vehicles.
(D) Retirement Plans and Individual Retirement Accounts
WEALTH INTEL provides investment advice on either a non-discretionary or discretionary basis. The written
Advisory Agreement that we enter into with the Plan sponsor specifies the capacity in which we have been
engaged:
•
•
If a Plan sponsor selects non-discretionary investment advice, we would serve by providing
investment advice within the meaning of section §3(21)(A)(ii)of the Employee Retirement Income
Security Act of 1974 ("ERISA") with respect to the specific investments we recommend to you in
connection with our services to the Plan, and only to the extent that our investment recommendations
are actually implemented by the Plan sponsor.
If the Plan sponsor selects discretionary investment advice, we serve as an investment manager for the
Plan within the meaning of ERISA § 3(38). Our fiduciary investment responsibilities are limited to
those of an investment manager.
We are making investment recommendations to you regarding your retirement plan account or individual
retirement account as fiduciaries within the meaning of Title I of the Employee Retirement Income Security
Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way
we make money or otherwise are compensated creates some conflicts with your financial interests, so we
operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours.
Under this special rule’s provisions, WEALTH INTEL must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put WEALTH INTEL’s financial interests ahead of the client’s when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that WEALTH INTEL gives advice that is in the best
interest of the client;
• Charge no more than is reasonable for services provided by AWA; and
• Give the client basic information about conflicts of interest.
ITEM 5: FEES AND COMPENSATION
WEALTH INTEL ADV Part 2 – September 2025
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(A) General Investment Advisory / Portfolio Management Services
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: Clients will be charged as a percentage of assets under
management with us, according to the schedule set forth in the client management agreement between us
and the client, provided, however, that the annual fee would not exceed two percent (2%); or
• Flat Monthly or Annual Fees: Clients will be charged at an agreed upon flat annual fee, paid monthly, or
flat monthly fee depending on the scope and complexity of the client’s needs.
• Fixed or Hourly Financial Planning Fee: Clients will be charged an agreed upon fixed or hourly fee
based on the complexity of your situation and the services provided. Our fees are negotiable at our sole
discretion.
The annual fee being charged to the client will be set forth and identified in an agreement between our
firm and that client. We retain the ability to negotiate other fee schedules depending on the size of the
account, type of account, the level of client service required and other factors we consider relevant,
including timing of client relationship.
Minimum account size is 2,000,000 and WEALTH INTEL in its sole discretion, may negotiate or waive
its stated account minimum or charge a lesser management fee based upon certain criteria (e.g.,
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, pre-existing client, account retention, pro bono
activities, etc.).
For the fee charged as a percentage of assets under management, fees are charged quarterly in advance.
When the Account is incepted, the Advisory Fee is billed for the remainder of the current billing period
and is based on the initial contribution. The initial payment will become due in full on the date of
Account inception. Subsequent quarterly Advisory Fees will be calculated based on the Account Value
as of the last business day of the previous calendar quarter and will become due the following business
day. Cash and assets which are invested in shares of mutual funds, exchange traded funds, annuities we
manage, individual securities, collective trusts, unit investment trusts alternative investments, limited
partnerships, and/or closed-end funds shall be included in the calculation of the value of the client's
assets under management with us for purposes of computing our fee. Although we do not typically
utilize margin in our strategies, a client's margin balance is typically included when calculating assets
under management. This will be in addition to any margin interest being paid by the client.
In the event of termination of this account termination, Wealth Intel will refund to Client the prorated
portion of the Advisory Fee for the quarter of termination. All fees due under the advisory agreement at
termination will be deducted from Client’s Account before assets are delivered from the Account. Upon
termination, the Client’s brokerage account will no longer be assessed the Advisory Fee and any
transaction effected subsequent to such termination will be assessed a customary brokerage commission
based on the custodians standard commission schedule. Please note, custodial fee’s such as transfer or
closing fees, are passed on to clients. Wealth Intel does not share in, or collect revenue from custodial
fees
WEALTH INTEL ADV Part 2 – September 2025
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The custodian sends the client a statement, at least quarterly, indicating the amount of our fees and all
amounts disbursed from the account to our firm for our management fees. We have internal controls that
seek to verify that the custodian is withdrawing fees accurately in accordance with your agreement,
however, we strongly encourage clients independently verify the accuracy of the fee calculation, as the
custodian will not verify the calculation. If a client does not have sufficient cash in the account(s) to
cover the payment of fees, some or all of the securities held by the client will be liquidated in order to
pay the fees.
The custodian is responsible for sending the client account statements, clients will not receive an
account statement or a fee invoice from us. Asset-based fees are always subject to the management
agreement between the client and WEALTH INTEL, and we generally retain the right to amend our fee
schedule with 30 days prior written notice to the client.
(B) Financial Planning and Financial Consulting Services
For clients who retain our firm for its investment advisory services, there is generally no charge for financial
planning services. Other clients who retain the firm solely for financial planning or financial consultation will
be charged fees based on the nature of the services being provided, who is providing the services and the
complexity of the client's circumstances. Financial planning fees are generally calculated and charged on a flat
fee basis from $2,500 to $50,000 per engagement. If a client terminates financial planning services after we
have begun the work but before completion, we will charge a termination fee equal to the hours then spent on
your services at a rate outlined in the client’s agreement executed prior to our financial professional
commencing planning. Financial planning fees and the termination fee are negotiable. We will reduce or waive
the financial planning fees and/or termination fee in certain circumstances.
We provide you with an exact fee quote before you authorize us to begin our work. The specific financial
planning fee being charged to the client will be set forth and identified in an agreement between us and each
client. We will withdraw financial planning fees from a client's bank account only with the prior consent of the
client.
Although the length of time it will take to provide a financial plan or financial consultation depends on each
client's personal situation, we will provide a timing estimate at the start of the planning relationship. For those
who will be charged for financial planning or financial consultation, we will invoice the client for the services,
and the fees will generally be due and payable upon delivery of the completed financial plan to the client or
completion of the services, as applicable.
Your financial professional will update your financial plan upon request or when your objectives or financial
situation change. If a financial plan is updated, the fee will be dependent on the nature of the update. Again,
this fee will be set forth and identified in an agreement between yourself and the firm.
In some circumstances, the financial plan could require the services of a specialist such as an insurance
specialist, attorney, or tax accountant since we do not provide any legal or accounting advice. Our firm will
recommend third-party service providers when we feel it is appropriate and, in the client’s best interest, but
the client is under no obligation to use any service provider recommended by our firm. Fees for specialists
will be negotiated between the client and specialist directly under a separate engagement.
WEALTH INTEL ADV Part 2 – September 2025
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(C) Fees and Compensation for Business Consulting
The fee range for business consulting is set in whole on a fixed fee basis and is negotiated with the
client.
(D) Billing of Fees
All fees and expenses are billed quarterly, in advance (unless otherwise specified in the advisory
agreement). The billed fees are generally deducted directly from client accounts after each quarterly
billing; however, clients may elect to pay fees directly after receipt of their quarterly billing statement.
For those clients who are billed in advance, any payment of fees are subject to a refund in the event of
termination of an account prior to the end of a quarterly billing period for which payment has been
made, with the amount of the refund being determined on a prorated basis.
(E) Brokerage and Transaction Costs
See “Item 12: Brokerage Practices” below.
(F) Other General Information on WEALTH INTEL Fees and Compensation
WEALTH INTEL’s sole sources of revenue are the fees it receives from its clients and expense
reimbursement payments it receives from WEALTH INTEL Pooled Investment Vehicles. Neither
WEALTH INTEL nor any of its employees or the Members receive, directly or indirectly, any other type
of compensation or commission related to the sale of securities or other investment products.
Furthermore, WEALTH INTEL does not receive any “soft dollar benefits” from any third party in
connection with securities transactions of its clients or pooled investment vehicles.
Under certain circumstances, WEALTH INTEL fees and account minimums may be negotiable. WEALTH
INTEL may waive account minimum requirements at WEALTH INTEL’s discretion.
WEALTH INTEL has varied legacy fee schedules and arrangements it honors for relationships which
predate this disclosure brochure. Additionally, WEALTH INTEL may manage portfolio accounts of
employees’ family and close friends. These portfolio accounts may be waived an advisory fee or may
be charged a discounted fee.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
Neither WEALTH INTEL nor any of its Members or employees receives, directly or indirectly, any
performance- based fees related to WEALTH INTEL client accounts or WEALTH INTEL Pooled
Investment Vehicle accounts.
WEALTH INTEL ADV Part 2 – September 2025
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ITEM 7: TYPES OF CLIENTS
WEALTH INTEL generally provides investment advice to the following types of clients:
Individuals
•
• High net worth individuals
• Trusts, estates, or charitable organizations
• Small business including corporations and other business entities
You are required to execute a written agreement with WEALTH INTEL specifying the particular
advisory services in order to establish a client arrangement with our firm. Legacy client agreements pre-
dating our effective date as an Independent Registered Investment Advisor remain in place.
Minimum Investment Amounts Required and Minimum Fees Charged for Financial Planning
WEALTH INTEL requires a minimum of $2,000,000 for our asset management services. To reach this account
minimum, clients can aggregate all household accounts. Exceptions may be granted to this minimum at the
discretion of the Firm.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES
AND RISK OF LOSS
(A) Methods of Analysis
WEALTH INTEL Wealth uses the following methods of analysis in formulating investment advice:
Charting - This is a set of techniques used in technical analysis in which charts are used to plot price
movements, volume, settlement prices, open interest, and other indicators, in order to anticipate future
price movements. Users of these techniques, called chartists, believe that past trends in these indicators can
be used to extrapolate future trends.
Charting is the most subjective analysis of all investment methods since it relies on proper interpretation of
chart patterns. The risk of reliance upon chart patterns is that the next day's data can always negate the
conclusions reached from prior days' patterns. Also, reliance upon chart patterns bears the risk of a certain
pattern being negated by a larger, more encompassing pattern that has not shown itself yet.
Cyclical – This method analyzes the investments sensitive to business cycles and whose performance is
strongly tied to the overall economy. For example, cyclical companies tend to make products or provide
services that are in lower demand during downturns in the economy and in higher demand
WEALTH INTEL ADV Part 2 – September 2025
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during upswings. Examples include the automobile, steel, and housing industries. The stock price of a
cyclical company will often rise just before an economic upturn begins and fall just before a downturn
begins.
Investors in cyclical stocks try to make the largest gains by buying the stock at the bottom of a business cycle,
just before a turnaround begins.
While most economists and investors agree that there are cycles in the economy that need to be respected,
the duration of such cycles is generally unknown. An investment decision to buy at the bottom of a business
cycle may actually turn out to be a trade that occurs before or after the bottom of the cycle. If done before the
bottom, then downside price action can result prior to any gains. If done after the bottom, then some upside
price action may be missed. Similarly, a sell decision meant to occur at the top of a cycle may result in
missed opportunity or unrealized losses.
Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value and
intrinsic growth potential by examining related economic, financial, and other qualitative and quantitative
factors. Fundamental analysts attempt to study everything that can affect the security's value and growth,
including macroeconomic factors (like the overall economy and industry conditions) and individually
specific factors (like the financial condition and management of a company). The end goal of performing
fundamental analysis is to produce a value that an investor can compare with the security's current price in
hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or
short). Fundamental analysis is considered to be the opposite of technical analysis.
Fundamental analysis is about using real data to evaluate a security's value and growth potential. Although
most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any
type of security.
The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach
is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with
one another in their impact on the investment in question. It is possible for those market forces to point in
different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation
may be wrong and could therefore lead to an unfavorable investment decision.
Technical – This is a method of evaluating securities by analyzing statistics generated by market
activity, such as past prices and volume. Technical analysts do not attempt to measure a security's
intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity.
Technical analysts believe that the historical performance of stocks and markets are indications of
future performance.
Technical analysis is even more subjective than fundamental analysis in that it relies on proper
interpretation of a given security's price and trading volume data. A decision might be made based on a
historical move in a certain direction that was accompanied by heavy volume; however, that heavy
WEALTH INTEL ADV Part 2 – September 2025
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volume may only be heavy relative to past volume for the security in question, but not compared to the
future trading volume. Therefore, there is the risk of a trading decision being made incorrectly since future
trading volume is an unknown. Technical analysis is also done through observation of various market
sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of
bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment
advantageously. When most traders are bullish, then there are very few traders left in a position to buy the
security in question, so it becomes advantageous to sell it ahead of the crowd.
When most traders are bearish, then there are very few traders left in a position to sell the security in
question, so it becomes advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment
technical measures is that a very bullish reading can always become more bullish, resulting in lost
opportunity if the money manager chooses to act upon the bullish signal by selling out of a position. The
reverse is also true in that a bearish reading of sentiment can always become more bearish, which may result
in a premature purchase of a security.
To conduct analysis, WEALTH INTEL gathers information from financial newspapers, magazines and websites,
inspection of corporate activities, research materials prepared by others, corporate rating services, timing
services, annual reports, prospectuses and filings with the SEC, and company press releases.
Investment Strategies
As indicated in Item 4, most clients are placed in a model overseen by a financial professional of our firm. The
model includes a number of asset classes, including equities, both domestic and international, exchange traded
funds, mutual funds, fixed income, and commodities, amongst others. More often than not, models are built
and managed internally. At times, WEALTH INTEL utilizes sub-advisers or platform providers to implement
models. All trading for accounts in these programs will generally be conducted by the third-party investment
adviser or platform provider.
Individual clients can request one-off scenarios as needed. Investment strategies and advice will vary
depending upon each client's specific financial situation. We manage households and accounts on a goals based
approach so not every account is diversified. Certain accounts will potentially be more heavily weighted in
one sector versus another account in order to diversify the household as a whole or to take advantage of certain
tax advantages in having particular types of investments in certain types of accounts. As such, we determine
investments and allocations based upon the client's predefined objectives, risk tolerance, time horizon,
financial horizon, financial information, liquidity needs, and other various suitability factors. The restrictions
and guidelines set by the client will also affect the composition of the portfolio.
Risk of Loss
Investing involves a risk of loss. Clients should be prepared to bear investment loss, including the loss of the
original principal. Clients should never presume that future performance of any specific investment or
investment strategy will be profitable. Further, there are varying degrees of risk depending on different types of
investments. Clients should know that all investments carry a certain degree of risk ranging from the variability
of market values to the possibility of permanent loss of capital. Although portfolios seek
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principal protection, asset allocation and investment decisions are not guaranteed to achieve this goal in all
cases. There is no guarantee a portfolio will meet a target return or an investment objective.
Risks to capital include, but are not limited to, changes in the economy, market volatility, company results,
industry sectors, accounting standards and changes in interest rates. Investments are generally subject to risks
inherent in governmental actions, exchange rates, inflation, deflation, and fiscal and monetary policies. Market
risks include changes in market sentiment in general and styles of investing. Diversification will not protect an
investor from these risks and fluctuations.
Market Risk – Either the stock market, or the value of an individual company, goes down resulting in a
decrease in the value of client investments. This is also referred to as systemic risk.
Equity (stock) market risk – Common stocks are susceptible to general stock market
fluctuations and to volatile increases and decreases in value as market confidence in and perceptions
of their issuers change. If you held common stock, or common stock equivalents, of any given issuer,
you would generally be exposed to greater risk than if you held preferred stocks and debt obligations
of the issuer.
Private Equity (PE) Risk - PE investment strategies are highly dependent on a PE manager’s ability
to identify attractive opportunities, provide the necessary capital, and then work with the target
companies to deploy that capital over time in ways that will foster long-term growth. To be effective,
managers must be able to take a long view with investor capital, taking perhaps months to identify
the right opportunities and planning their exit strategy sometimes years in advance. For such
practices to be effective, PE funds will generally incorporate “lock-up” periods during which investors
may not withdraw any of their capital. While shares can generally be sold to other investors during
this time, the lack of formal secondary markets hinders PE investors from finding potential buyers.
In addition, exits may involve IPOs or acquisitions, which take a great deal more time to implement
than sales of public shares on an exchange. For these reasons, investors in PE have an illiquidity risk
that differs considerably from public equity funds. In cases where limited secondary sales
opportunities may exist, investors may have to accept discounted returns in order to obtain liquidity
for their shares prior to their fund issuing distributions. Private equity investments involve a high
degree of risk and may result in partial or total loss of capital. By their nature, alternative investments
are complex, speculative investment vehicles and are only suitable for qualified investors who have
sufficient knowledge and experience to understand the risks involved.
Company Risk. When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and
can be reduced through appropriate diversification. There is the risk that the company will perform
poorly or have its value reduced based on factors specific to the company or its industry. For
example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
Liquidity Risk: the risk that a particular investment may be difficult to purchase or sell and that a
fund may be unable to sell illiquid (non–marketable) securities at an advantageous time or price.
Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond
and be unable to make payments. Further, individuals who depend on set amounts of
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periodically paid income face the risk that inflation will erode their spending power. Fixed- income
investors receive set, regular payments that face the same inflation risk.
Inflation Risk: Also referred to as purchasing power risk, is the risk that inflation will undermine the real value of
cash �lows made from an investment. Inflation risk affects all investments but most can be seen most prevalently
in the bond markets.
ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also
incur brokerage costs when purchasing ETFs.
Management Risk – Your investment with our firm varies with the success and failure of our
investment strategies, research, analysis and determination of portfolio securities. If our investment
strategies do not produce the expected returns, the value of the investment will decrease.
Margin Risk - When you purchase securities, you may pay for the securities in full or borrow part
of the purchase price from your account custodian or clearing firm. If you intended to borrow funds
in connection with your Account, you will be required to open a margin account, which will be
carried by the clearing firm. The securities purchased in such an account are the clearing firm’s
collateral for its loan to you.
If those securities in a margin account decline in value, the value of the collateral supporting this
loan also declines, and as a result, the brokerage firm is required to take action in order to maintain
the necessary level of equity in your account. The brokerage firm may issue a margin call and/or sell
other assets in your account.
It is important that you fully understand the risks involved in trading securities on margin, which
are applicable to any margin account that you may maintain, including any margin account that may
be established as part of the Asset Management Agreement established between you and FWG
Investments and held by the account custodian or clearing firm.
These risks include the following:
• You can lose more funds than you deposit in your margin account.
• The account custodian or clearing firm can force the sale of securities or other assets in your account.
• The account custodian or clearing firm can sell your securities or other assets without contacting
you.
You are not entitled to choose which securities or other assets in your margin account may be liquidated
or sold to meet a margin call. The account custodian or clearing firm may move securities held in your cash
account to your margin account and pledge the transferred securities. The account custodian or clearing
firm can increase its “house” maintenance margin requirements at any time and they are not required to
provide you advance written notice. You are not entitled to an extension of time on a margin call.
Alternative Investments – Our portfolio holdings are typically traded on U.S. exchanges; however non-
U.S. investments, currency and commodity investments may contain additional risks associated with
government, economic, political or currency volatility.
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Emerging Markets – Where justified by the investment analysis outlined above, investment either indirectly or
directly in emerging markets may be included in a portfolio. Emerging markets can experience high volatility
and risk in the short term.
Derivatives Risk- The use of derivatives is a highly specialized activity that involves a variety of risks in
addition to and greater than those associated with investing directly in securities, including the risk that: the
party on the other side of a derivative transaction will be unable to honor its financial obligation; leverage
created by investing in derivatives may result in losses to the portfolio; derivatives may be difficult or
impossible for the portfolio to buy or sell at an opportune time or price, and may be difficult to terminate or
otherwise offset; derivatives used for hedging may reduce or magnify losses but also may reduce or eliminate
gains; and the price of commodity - linked derivatives may be more volatile than the prices of traditional
equity and debt securities.
ITEM 9: DISCIPLINARY INFORMATION
Neither WEALTH INTEL nor any of its Managing Board or Members have been involved in, or
subjected to, any legal or disciplinary events that would be material to a client’s or prospective client’s
evaluation of the firm’s advisory business or the integrity of its management.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES
AND AFFILIATIONS
WEALTH INTEL Wealth is not a registered broker-dealer, commodity firm, commodity trading advisor,
or futures commission merchant, and does not have an application to register for any of the same
pending. In addition, our firm does not recommend investment products in which it receives any form of
compensation from the separate account manager or investment product sponsor.
Some of our firm’s financial professionals are also licensed insurance agents for unaffiliated third
parties, and recommend insurance products to clients, such as life, disability and long-term care
insurance products. These products are separate and distinct from investment advisory services offered
through WEALTH INTEL, and the firm professional will receive a commission or fees as a result of the
sale of insurance related products. A conflict of interest therefore exists as these commissionable sales
creates an incentive to recommend products based on compensation earned rather than need. In no event
is any client obligated, contractually or otherwise, to use the services of any licensed insurance agent
acting in such capacity or to purchase products or services through said individual.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN
CLIENT TRANSACTIONS AND PERSONAL TRADING
WEALTH INTEL has adopted a Code of Ethics expressing the firm's commitment to ethical conduct.
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WEALTH INTEL’s Code of Ethics describes the firm's fiduciary duties and responsibilities to clients.
Summarizing these duties and responsibilities, WEALTH INTEL is a fiduciary that has a duty of
undivided loyalty to its clients and an obligation to act at all times with the utmost integrity on the
clients’ behalf.
Among other things, the firm’s Code of Ethics sets forth WEALTH INTEL’s practice of supervising the
personal securities transactions of its employees and Members. Individuals associated with WEALTH
INTEL may buy or sell securities for their personal accounts that are identical to or different than those
recommended to clients. In addition, such individuals may have interests or positions in securities and
Pooled Investment Vehicles which may also be recommended to clients. However, it is the explicit
policy of WEALTH INTEL that no person employed by WEALTH INTEL shall prefer his or her own
interest to that of an advisory client or make personal investment decisions based on the investment
decisions of advisory clients.
To supervise compliance with its Code of Ethics, WEALTH INTEL requires that all employees and
Members associated with WEALTH INTEL provide annual securities holdings reports and quarterly
transaction reports to the firm's Chief Compliance Officer. WEALTH INTEL requires such persons to
also receive approval from the Chief Compliance Officer prior to investing in any IPOs or third-party
private placements (limited offerings).
Moreover, WEALTH INTEL requires that all employees and Members must act in accordance with all
applicable Federal and State regulations governing registered investment advisory practices. WEALTH
INTEL’s Code of Ethics further includes the firm's policy prohibiting the use of material non-public
information. Any individual not in observance of the above may be subject to discipline.
WEALTH INTEL will provide a complete copy of its Code of Ethics to any client or prospective client
upon request to the Chief Compliance Officer at WEALTH INTEL’s principal address.
ITEM 12: BROKERAGE PRACTICES
While WEALTH INTEL has discretionary investment authority over certain of its clients’ accounts,
WEALTH INTEL generally does not have discretion to determine the broker-dealers used for such
accounts or the commission rates to be paid to such broker-dealers, as the investments in such accounts
are managed principally by third-party investment managers.
For clients in need of brokerage or custodial services, and depending on client circumstances and needs,
WEALTH INTEL may recommend the use of one of several broker-dealers.
In recommending a broker-dealer, the factors considered by WEALTH INTEL include the broker
dealer's ability to provide professional services, WEALTH INTEL’s experience with the broker-dealer,
the broker-dealer's reputation, the broker-dealer's quality of execution services and costs of such
services, among other factors. Clients are not under any obligation to effect trades through any
recommended broker-dealer; and each client is free to select any broker-dealer of his or her choice. If
the client directs WEALTH INTEL to use a specific broker- dealer, WEALTH INTEL will not be
responsible for obtaining best execution for any directed brokerage transactions. WEALTH INTEL does
not receive any payments, products, research or other “soft dollar” consideration from any broker-dealer
or agent selected to execute client transactions.
ITEM 13: REVIEW OF ACCOUNTS
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Accounts are monitored continuously and on an ongoing basis by our financial professionals. We conduct
these reviews through various means, including telephone calls, in-person meetings, overall strategy
reviews, and/or the review of monthly and quarterly statements. Reviews are based on objectives and
parameters established by clients, which are generally memorialized through their client management
agreements and Investment Policies. More frequent reviews can also be triggered by a change in the
client's investment objectives or risk tolerance, tax considerations, large deposits or withdrawals, large
purchases or sales, loss of confidence in investment or fund managers, or changes in the economy or
financial markets.
Our compliance personnel will also monitor managed and supervised accounts on an ongoing basis to
ensure that the advisory services provided to clients are consistent with the clients' circumstances.
Depending on the nature of the engagement, some financial plans will not be reviewed until after the plan
is delivered. The frequency of plan review will be dependent on the agreement terms. If deemed necessary
it will be reviewed quarterly, yearly or some other determinate amount of time. Those reviews will revisit
the initial plan and determine if any adjustments need to be made to the objectives. Financial planning, by
its nature, does require periodic review. At times we will use software and other tools to assist in generating
a financial plan.
With respect to managed accounts, investment advisory clients receive standard account statements from
the independent, qualified custodian of their accounts no less frequently than quarterly. The account
statements received from the custodian and/or broker-dealer are the official records of the client's
account(s).
No on-going financial planning reports are provided for financial planning clients unless a financial plan
update or additional services are requested. Your firm professional will update a plan as needed and when
objectives or financial situation change.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
WEALTH INTEL does not receive any type of economic benefit from third parties for providing
investment advice or other advisory services to WEALTH INTEL clients. WEALTH INTEL also does not
directly or indirectly compensate any person for client referrals.
ITEM 15: CUSTODY
We generally have the ability to directly debit advisory and other fees from client accounts, unless the
client specifies otherwise. As part of this billing process, the independent, qualified custodian of the
client's account(s) is advised of the amount of the advisory or other fee to be deducted from the client's
account(s). The client will receive account statements from the custodian holding the account(s) at least
quarterly. These statements will show all transactions within the account during that reporting period,
including the amount of advisory or other fees debited from the client's account(s). Because the
custodian does not calculate the amount of the fees to be deducted, it is important for clients to carefully
review their account statements to verify the accuracy of the fee calculation, among other things.
A client should contact us directly if he/she believes there is an error or has a question regarding an
account statement.
This ability to deduct our fees from a client's account(s) causes us to exercise limited custody over these
accounts under applicable law. We do not have, and will not take, physical custody of any clients' funds,
securities or assets. Clients' funds, securities and assets will be held with a bank, broker-dealer or
independent, qualified custodian.
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ITEM 16: INVESTMENT DISCRETION
When a client hires us to provide discretionary investment advisory services, we have the authority to
place trades, buy and sell securities on the client's behalf, determine the amount of the securities to buy
and sell, and determine the nature and type of securities to buy and sell without obtaining a client's
consent or approval prior to each transaction. In some cases, we will have the authority to hire and fire
third-party money managers. Clients who give us discretionary authority will give our firm a limited
power of attorney and/or trading authorization forms to make the above decisions on the client's behalf.
In certain situations, Clients have the ability to limit our authority by giving us written instructions,
restrictions and guidelines via email communication or other written instructions. For example, a client
might specify that their accounts’ assets not be invested in a specific industry or security, or that a
certain security not be liquidated. Clients can change such instructions, restrictions and guidelines by
providing us with written instructions. The most current written instructions will control. We will accept
such limitations provided they are reasonable and do not unreasonably interfere with the management of
your account. We will accept such instructions via text message or similar instant messaging methods.
If the client enters into a non-discretionary arrangement with our firm for investment advisory, portfolio
management services, or retirement plan consulting, we will be obligated to obtain the client's approval
prior to the arranging or execution of any transactions in the account(s). With such an arrangement, the
client has the unrestricted right to decline to implement advice provided by us on a non-discretionary
basis. If you do not grant us discretionary authority over your accounts, we are limited to make periodic
recommendations to you regarding which securities to be purchased or sold and the size of the
transactions. You will ultimately be responsible for implementation of those recommendations and the
timing of the transaction.
ITEM 17: VOTING CLIENT SECURITIES
Regardless of whether we have discretion over a client's account(s), we will not vote proxies on behalf
of any client or respond to any legal notices or class action claims on behalf of a client.
We will instruct the qualified, independent custodian to forward all proxy materials, legal notices and
class action information to the client to review and make his or her own informed decision on how to
vote. In the event we receive the proxy material, we will forward them directly to the client by mail or
by electronic mail (if the client has authorized electronic communication).
ITEM 18: FINANCIAL INFORMATION
WEALTH INTEL has never filed for bankruptcy and is not aware of any financial condition that is
reasonably likely to impair its ability to meet its contractual commitments to its clients.
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