Overview
- Headquarters
- Sarasota, FL
- Total Firm Assets
- $147 million
- Average High-Net-Worth Client Portfolio Size
- $3.5 million
Fee Structure
Primary Fee Schedule (ADV 2A - FIRM DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.05% |
| $1,000,001 | $3,000,000 | 0.85% |
| $3,000,001 | $10,000,000 | 0.75% |
| $10,000,001 | and above | 0.65% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,500 | 1.05% |
| $5 million | $42,500 | 0.85% |
| $10 million | $80,000 | 0.80% |
| $50 million | $340,000 | 0.68% |
| $100 million | $665,000 | 0.66% |
Clients
- High-Net-Worth Share of Firm Assets
- 68.62%
- Number of High-Net-Worth Clients
- 29
- Total Client Accounts
- 621
- Discretionary Accounts
- 398
- Non-Discretionary Accounts
- 223
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
- SEC CRD Number
- 306196
Primary Brochure: ADV 2A - FIRM DISCLOSURE BROCHURE (2026-08-30)
View Document Text
Item 1 – Cover Page
Registered as WealthGen Advisors, LLC
1239 N. Gulfstream Ave., Ste 4, Sarasota, FL 34236
Phone: (941) 706-4151
www.WealthGenAdvisor.com
Form ADV Part 2A – Firm Disclosure Brochure
Effective: August 31, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of WealthGen Advisors, LLC (“the firm”). If you have any questions about the contents of this
Disclosure Brochure, please contact us at (941) 706-4151 or by email at Ken@wealthgenadvisor.com. 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 the firm to assist you
in determining whether to retain the firm. Additional details about WealthGen Advisors, LLC and its Persons are
available on the SEC’s website at www.adviserinfo.sec.gov by searching with our firm name or our CRD number
306196.
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Item 2 – Material Changes
There are no material changes since the previous annual amendment filed on March 26, 2025.
At any time, the current Disclosure Brochure is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching the firm name or CRD number 306196. A copy of this
Disclosure Brochure may be requested at any time, by contacting (941) 706-4151 or by email at
ken@wealthgenadvisor.com.
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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
Item 5 – Fees and Compensation ........................................................................................................................10
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................12
Item 7 – Types of Clients ...................................................................................................................................122
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss..........................................................12
Item 9 – Disciplinary Information ......................................................................................................................18
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................18
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............19
Item 12 – Brokerage Practices ............................................................................................................................19
Item 13 – Review of Accounts .............................................................................................................................22
Item 14 – Client Referrals and Other Compensation .......................................................................................23
Item 15 – Custody ................................................................................................................................................23
Item 16 – Investment Discretion .......................................................................................................................233
Item 17 – Voting Client Securities ......................................................................................................................23
Item 18 – Financial Information .........................................................................................................................23
ADV 2B - Individual Disclosure Brochure (Kenneth Hargreaves)………………………………………… 24
ADV 2B - Individual Disclosure Brochure (Richard A. Rayles, III)………………………………………. 28
Privacy Policy ……………………………...………………………………………………………………….. 32
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Item 4 – Advisory Business
Firm Information
WealthGen Advisors, LLC is organized in Florida as a limited liability company and registered as an Investment
Advisor to offer asset management services and financial planning on 12/04/2020.
Executive Management Team
Kenneth J. Hargreaves
Kenneth J. Hargreaves is the sole owner and Managing Member of WealthGen Advisors, LLC. Mr. Hargreaves
is a CERTIFIED FINANCIAL PLANNER™ (CFP®), an Accredited Wealth Management Advisor (AWMA®), a
Chartered Retirement Planning Counselor (CRPC®) and an Accredited Investment Fiduciary (AIF®). He has
been in the advisory business since 2008. Additional details about Mr. Hargreaves’s work history and education
are available in his individual ADV 2B disclosure brochure.
Advisory Services Offered
Services are provided primarily to high net worth individuals, individual and small businesses by giving regular
and continuous management and supervision of assets. Discretionary asset management clients are required to
engage the firm for a financial plan prior to an asset management engagement. Assets are managed on a
discretionary basis with a focus on investment goals, objectives, risk tolerance and financial situation. Investment
portfolios consist primarily of mutual funds and exchange-traded funds ("ETFs") as well as individual stocks as
appropriate. Socially responsible or environmentally responsible investing has a myriad of definitions and
interpretations, and as such, the firm does not allow clients to impose restrictions on securities.
At no time will the firm accept or maintain physical custody of funds or securities. All Client assets will be
managed within the designated brokerage account[s] held at the qualified custodian, according to the terms of the
account opening documents.
Retirement Plan Consulting Services
The firm assist Clients that are trustees or other fiduciaries to retirement plans ("Plans") by providing fee-based
consulting and advisory services. Investment Advisor Representatives perform one or more of the following
services, as selected by the Client in the Client agreement:
• Assistance in the preparation or review of an investment policy statement (“IPS”) for the Plan based
upon consultation with Client to ascertain Plan’s investment objectives and constraints.
• Acting as a liaison between the Plan and service providers, product sponsors or vendors.
• Ongoing monitoring of investment manager(s) or investments concerning the criteria specified in the
Plan’s IPS or other written guidelines provided by the Client to the Investment Advisor
Representative.
• Preparation of reports describing the performance of Plan investment manager(s) or investments, as
well as comparing the performance to benchmarks.
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• Ongoing recommendations for consideration and selection by Client about specific investments to
be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made
available as investment options under the Plan.
• Training for the members of the Plan Committee about their service on the Committee, including
education and consulting with respect to fiduciary responsibilities.
• Assistance in enrolling Plan participants in the Plan, including conducting an agreed upon number of
enrollment meetings. As part of such meetings, Representatives can provide participants with
information about the Plan. Information such as the benefits of Plan participation, the benefits of
increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms
of the Plan and the operation of the Plan.
• Assistance with investment education seminars and meetings for Plan participants. Such meetings
may be on a group or individual basis, and includes information about the investment options under
the Plan (e.g., investment objectives, risk/return characteristics, and historical performance),
investment concepts (e.g., diversification, asset classes, and risk and return), and how to determine
investment time horizons and assess risk tolerance. Such meetings do not include specific investment
advice about investment options under the Plan as being appropriate for a participant.
• Assistance at the Client's direction in making changes to investment options under the Plan.
• Assistance with the preparation, distribution and evaluation of Request for Proposals, finalist interviews,
and conversion support in connection with vendor analysis and service provider support.
• Preparation of comparisons of Plan data (e.g., regarding fees and services and participant enrollment and
contributions) to data from the Plan's prior years or a benchmark group of similar plans.
• Assistance in identifying the fees and other costs borne by the Plan for, as specified by Client,
investment management, recordkeeping, participant education, participant communication and other
services provided concerning the Plan.
If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under the
Plan, Representatives do not provide investment advice regarding company stock and are not responsible for the
decision to offer company stock as an investment option.
If a Client elects to engage the firm and our Investment Advisor Representatives to perform ongoing investment
monitoring and current investment recommendation services in the Client agreement, such services will
constitute "investment advice" under Section 3(21)(A)(ii) of ERISA. Therefore, the firm and our Investment
Advisor Representative will be deemed a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of
ERISA in connection with those services. Clients should understand that to the extent the firm is engaged to
perform functions other than ongoing investment monitoring and recommendations, those services are not
“investment advice” under ERISA, and therefore, the firm and our Investment Advisor Representatives will not
be a “fiduciary” under ERISA with respect to those other services.
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Retirement Plan Rollovers
An employee generally has four (4) options for their retirement plan when they leave an employer:
1. Leave the money in his/her former employer’s plan, if permitted
2. Rollover the assets to his/her new employer’s plan if one is available and permitted
3. Rollover to an Individual Retirement Account (IRA), or
4. Cash out the account value, which has significant tax considerations
Each of these options has advantages and disadvantages and before making a change we encourage you to speak
with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to
manage here are a few points to consider before you do so:
• Determine whether the investment options in your employer's retirement plan address your needs or
whether you might want to consider other types of investments.
• Employer retirement plans generally have a more limited investment menu than IRAs.
• Employer retirement plans may have unique investment options not available to the public such as
employer securities, or previously closed funds.
• Your current plan may have lower fees than our fees.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee
as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because
Investment Advisor Representatives have an incentive to recommend a rollover to you for the purpose of
generating fee-based compensation rather than solely based on your needs. You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also, current
employees can sometimes move assets out of their company plan before they retire or change jobs. In determining
whether to complete the rollover to an IRA, and to the extent the following options are available, you should
consider the costs and benefits of each. An employee will typically be investing only in mutual funds, you should
understand the cost structure of the share classes, available in your employer's retirement plan and how the costs
of those share classes compare with those available in an IRA. Clients should understand the various products
and services they might take advantage of at an IRA provider and the potential costs of those products and
services.
• Our strategy may have higher risk than the option(s) provided to you in your plan.
• Your current plan may also offer financial advice.
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•
If you keep your assets titled in a 401k or retirement account, participants could potentially delay their
required minimum distribution beyond age 70½.
• A 401(k) may offer more liability protection than a rollover IRA; each state may vary.
• Participants may be able to take out a loan on your 401k, but not from an IRA.
•
IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may
also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability,
higher education expenses or the purchase of a home.
•
If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital
gains tax rate.
• Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been
generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules
so you should consult with an attorney if you are concerned about protecting your retirement plan assets from
creditors.
It is important to understand the differences between these types of accounts and to decide whether a rollover is
the best option. Prior to proceeding, if you have questions contact your Investment Adviser Representative, or
call our main number as listed on the cover page of this brochure.
When WealthGen Advisors provides investment advice to you regarding your retirement plan account or
individual retirement account, we are 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 creates some conflicts with your 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, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Advisor also provides educational services to retirement plan participants with assets that could potentially be
rolled-over to an IRA advisory account. Education is based on a particular Client’s financial circumstances and
best interests. Again, Advisor has an incentive to recommend such a rollover based on the compensation received,
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which is mitigated by the fiduciary duty to act in a Client’s best interest and acting accordingly.
ERISA Fiduciary
Such services provided as an Investment Advisor Representative are subject to the Investment Advisers Act of 1940
("Advisers Act"), and the advisor is a fiduciary under the Advisers Act concerning such services. In addition, if the
Client elects to engage an Investment Advisor Representative to perform ongoing investment monitoring and
ongoing investment recommendation services to a Plan subject to ERISA in the Client agreement, such services
will constitute "investment advice" under Section 3(21)(A)(ii) of ERISA. Therefore, the IARs will be deemed a
"fiduciary" as such term is defined under Section 3(21)(A)(ii) of ERISA in connection with those services. Clients
should understand that to the extent the investment advisor representative is engaged to perform functions other
than ongoing investment monitoring and recommendations, those services are not "investment advice" under
ERISA, and therefore, the investment advisor representative will not be a "fiduciary" under ERISA with respect to
those other services.
From time to time, Investment Advisor Representatives may make the Plan or Plan participants aware of and may
offer services available from Investment Advisor Representative that are separate and apart from the services
provided under Retirement Plan Consulting. Such other services may be services to the Plan, to a Client with respect
to the Client's responsibilities or one or more Plan participants. In offering any such services, the investment advisor
representative is not acting as a fiduciary under ERISA with respect to such offering of services. If any such separate
services are offered to a Client, the Client will make an independent assessment of such services without reliance
on the advice or judgment of the Investment Advisor Representative.
Financial Planning Services
WealthGen Advisors, LLC through its Investment Advisor Representatives, generally provides financial
planning as part of a comprehensive asset management engagement. However, financial planning is available
separately for a separate fee. The type of plan can vary greatly depending on the scope and complexity of an
individual’s financial situation but may include:
Planning Strategies for Families and Individuals
• Retirement – Planning an investment strategy to provide inflation-adjusted income for life.
• College / Education – Planning to pay the future college/education expenses of a child or grandchild.
• Insurance Needs – Planning for the financial needs of survivors to satisfy such financial obligations as
housing, dependent child-care and spousal arrangements as well as education.
• Estate Planning – Planning that focuses on the most efficient and tax-friendly option to pass on an
estate to a spouse, other family members or a charity.
• Cash Flow/ Budget Planning – Planning to manage expenses against current and projected income.
• Wealth Accumulation – Planning to build wealth within a portfolio that takes into consideration risk
tolerance and time horizon.
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• Tax Planning – Planning a tax-efficient investment portfolio to maximize deductions and off-setting
losses.
• Investment Planning – Planning an investment strategy consistent with particular objectives, time
horizons and risk tolerances.
• Inheritance Planning – Planning for a tax-efficient method to pass wealth to the next generation.
Planning Strategies for Businesses
• Business Entity Planning – Review the various forms of business structures concerning liability and
income tax considerations.
• Qualified Retirement Plans – Evaluate the types of retirement plans established by an employer for the
benefit of the company’s employees.
• Stock Option Planning – Planning to maximize the value of employer-issued stock options and
optimize what to exercise and what to hold.
• Key Person Planning – Evaluate the life insurance needs required in the event of the sudden loss of a
key executive to buy time to find a new person or to implement other strategies to continue the business.
• Executive Benefits – Planning to attract, reward and retain top executive talent.
• Deferred Compensation Plans – Planning for the use of tax-deferred funds to be withdrawn and taxed
in the future.
• Business Succession Planning – Planning for the continuation of a business after key executives move
on to new opportunities, retire or pass away with the use of buy-sell agreements, key-man insurance and
engaging independent legal counsel as needed.
• Divorce or Separation Planning – Planning for the financial impact of divorce or separation such as
change in income, retirement benefits and tax considerations. Providing alternatives to collaborative
divorce attorneys to reapportion joint assets.
Prior to engaging the firm to provide stand-alone planning or consulting services, Clients are required to enter
into a Financial Planning and Consulting Agreement setting forth the terms and conditions of the engagement
(including termination), describing the scope of the services to be provided, and the portion of the fee that is due
from the Client prior to the firm commencing services. If requested by the Client, the firm can recommend the
services of other professionals.
Client Account Management
Before an engagement, Clients are required to enter into an agreement that defines the terms, conditions, and fees.
There is no minimum amount required to open or maintain an account.
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Assets Under Management
Assets under management shall be amended within 90 days of the December 31 fiscal year-end. Clients may
request more current information at any time by contacting the firm.
Assets under Management (11/18/2025)
Discretionary
$136,200,000
Non-Discretionary
$10,400,000
Total
$ 146,600,000
Item 5 – Fees and Compensation
Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid, monthly or quarterly in arrears based on the daily average balance. Investment
advisory fees are negotiable based on the scope and complexity of the services, the amount of time and expertise
required but generally follow the below schedule.
Assets Under Management
Fee
Up to $1,000,000
1.05%
$1,000,000 to $3,000,000
.85%
$3,000,000 to $10,000,000
.75%
Above $10,000,000
.65%
The investment advisory fee in the first period of service is prorated from the inception date of the account[s] to the
end of the billing cycle.
• The firm will not have the authority or responsibility to value portfolio securities.
•
If a Client terminates an engagement before the monthly or quarterly billing period, a pro-rated fee
calculation will apply.
• Asset management fees are exclusive of, and in addition to, brokerage fees, transaction fees, and other
related costs and expenses.
Unless a client has received the firm’s ADV 2A and ADV 2B more than 48 hours before signing an agreement,
they have five (5) days to terminate the agreement without a fee or penalty.
Mutual Fund Share Class Disclosures
Certain mutual fund share classes charge a 12b-1 fee that generally amounts to an additional .25% expense ratio or
more. The purpose of 12b-1 fees, as approved by the SEC, are to cover marketing expenses and shareholder services
such as support services and “other expenses” such as legal, accounting and the administrative functions of the
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custodian. When selecting a mutual fund, investment advisor representatives have a fiduciary duty to choose the
share class that helps manage the overall fee structure of the account. The total fee structure includes such fees as
the asset management fee, the expense ratio and ticket charges.
• Mutual funds typically offer multiple share classes, including lower-cost share classes that do not charge
12b-1 fees and are therefore usually less expensive.
• The firm will consider investing Client funds in 12b-1 fee paying share classes even when a lower-cost
share class is available as appropriate to account for the overall fee structure and tax considerations as
well as attributes of a fund not available for lesser fees.
Fee Billing
Investment Management Services
Investment advisory fees are calculated by the firm and deducted from the Client’s account[s] at the Custodian with
the client’s signed approval. The firm shall send an invoice to the client and Custodian indicating the amount of the
fees to be deducted from the Client's account[s] at the corresponding month-end date. Clients will be provided with
a statement, at least quarterly, from the Custodian reflecting the deduction of the investment advisory fee. Clients
should verify the accuracy of the fees.
Financial Planning Services
The firm can charge an hourly or flat fee basis for financial planning services. The total estimated fee, as well
as the ultimate fee charged is based on the scope and complexity of the engagement.
• The fee for financial plans that are based on an hourly rate are calculated by a multiple of the anticipated
number of hours required and an hourly rate of $250.
• The fee for financial plans that are based on a flat rate generally range from $5,000 to $8,000.
• A minimum fee of $5,000 is charged for a financial plan when account AUM under $500,000. The
account is not subject to an asset management fee.
• There is no fee for a financial plan when the account AUM is over $5,000,000. The account is subject
to an asset management fee.
• All investment management clients are required to have a financial plan.
Hourly Consulting Services
The firm charges an hourly fee of $250 to provide hourly consulting.
Retirement Plan Consulting
The fee for Retirement Plan Consulting will be either an assets under management fee of generally no more than
1.00% or a fixed $6,000 annual fee. The total estimated fee, as well as the ultimate fee that we charge you, is
based on the scope and complexity of the engagement.
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Other Fees and Expenses
Clients incur specific fees or charges imposed by third parties, other than the firm, 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 and executing broker/dealer. The fees charged by WealthGen Advisors are separate
and distinct from these custodial and execution fees.
In addition, all fees paid to WealthGen Advisors, LLC for investment advisory services are separate and distinct
from the internal expenses charged by mutual funds and exchange-traded funds to their shareholders. 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 could invest in these products directly, without the services
of the firm, but would not receive the services 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 the firm to fully understand
the total fees to be paid. Please refer to “Item 12 – Brokerage Practices” for additional information.
Compensation for Sales of Securities
WealthGen Advisors, LLC does not buy or sell securities to earn commissions and does not receive any
compensation for securities transactions in an advisory account.
Item 6 – Performance-Based Fees and Side-By-Side Management
WealthGen Advisors, LLC does not charge performance-based fees for its investment advisory services. The fees
charged by the firm are as described in “Item 5 – Fees and Compensation” above and are not based upon the
capital appreciation of the funds or securities held by any Client. Therefore, the firm does not engage in side-
by-side management.
Item 7 – Types of Clients
WealthGen Advisors, LLC offers investment advisory services primarily to individuals and high net worth
individuals. The number of each type of Client is provided on Form ADV Part 1A. These numbers change over
time and are updated at least annually.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
WealthGen Advisors, LLC primarily employs a combination of behavioral, charting, cyclical, fundamental and
technical method of analysis in developing investment strategies. Research and analysis from the firm is 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.
• Behavioral Analysis
Behavioral finance analysis involves an examination of conventional economics as well as behavioral and
cognitive psychological factors. Behavioral finance methodology seeks to combine a qualitative and
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quantitative approach to provide explanations for why individuals may, at times, make irrational financial
decisions. Where conventional financial theories have failed to explain certain patterns, the behavioral
finance methodology investigates the underlying reasons and biases that cause some people to behave
against their best interests. The risks relating to behavior finance analysis are that it relies on spotting
trends in human behavior that may not predict future trends.
• Charting Analysis
Charting analysis utilizes various market indicators as investment selection criteria. These criteria are
generally pricing trends that may indicate movement in the markets. 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 firm in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in the technical and
charting analysis may lose value and may have negative investment performance. The firm monitors these
market indicators to determine if adjustments to strategic allocations are appropriate.
• Cyclical Analysis
Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a
macro (entire market/economy) or micro (company-specific) level, rather than the overall fundamental
analysis of the health of the particular company that the firm is may recommend or implementing. The
risks with cyclical analysis are similar to those of technical analysis.
• Fundamental Analysis
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These
criteria consist 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 show that they are
a strong investment with a value discounted by the market. While this type of analysis helps the firm 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 firm monitors these economic indicators to determine if adjustments to
strategic allocations are appropriate. More details on the firm’s review process are included below in “Item
13 – Review of Accounts”.
• Technical Analysis
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 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 the firm will be able to predict such a reoccurrence accurately. As noted above, the firm
generally employs a long-term investment strategy for its Clients, as consistent with their financial goals.
the firm 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, the firm
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 for portfolio management purposes.
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Investment Strategies
• Income with Capital Preservation. A conservative investment strategy with an objective of long-term
accumulation. Emphasis is placed on generating current income with minimal risk of capital loss. A low-
risk investment strategy generally results in reduced potential for overall return.
• Income with Moderate Growth. This investment objective emphasizes the generation of current income
with a secondary focus on moderate capital growth.
• Growth with Income. This investment objective emphasizes modest capital growth with some focus on
generation of current income.
• Growth. This investment objective emphasizes achieving high long-term growth and capital appreciation.
There is little focus on the generation of current income.
• Aggressive Growth. This investment objective emphasizes aggressive growth and maximum capital
appreciation, with no focus on generation of current income. This objective has a very high level of risk and
is for investors with a longer time horizon.
Risk of Loss
Investing in securities involves certain investment risks. Securities fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. WealthGen Advisors, LLC 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 firm 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 firm monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate.
The specific risks associated with a strategy are provided to each Client in advance of investing Client accounts.
WealthGen Advisors, LLC will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Below is a list of risks that should be considered before investing that may apply to the
particular investment held in an account. Additional unforeseen risks may apply and affect investment
performance. Clients are encouraged to at least consider the following risks:
• Business Risk – The measure of risk associated with a particular security. It is also known as unsystematic
risk and refers to the risk associated with a specific issuer of a security. All businesses in the same industry
have similar types of business risk. More specifically, business risk refers to the possibility that the issuer
of a company stock or a bond may go bankrupt or be unable to pay the interest or principal in the case of
bonds.
• Call Risk – The risk specific to bond issues and refers to the possibility that a debt security will be called
prior to maturity. Call risk usually goes hand in hand with reinvestment risk because the bondholder must
find an investment that provides the same level of income for equal risk. Call risk is most prevalent when
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interest rates are falling, as companies trying to save money will usually redeem bond issues with higher
coupons and replace them on the bond market with issues with lower interest rates.
• Company Specific Risk – An unsystemic risk specific to a certain company's operations, executive
decisions and reputation which is difficult to quantify.
• Credit Risk – The risk that an investor could lose money if the issuer or guarantor of a fixed income security
is unable or unwilling to meet its financial obligations.
• Currency/Exchange Rate Risk – The risk of a change in the price of one currency against another.
• Force Majeure – A natural and unavoidable catastrophe that interrupts the expected course of events,
market structure and access to funds.
• Interest Rate Risk – The risk that fixed income securities will decline in value because of an increase in
interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in
interest rates than a bond or bond fund with a shorter duration.
• Inflationary Risk – The risk that future inflation will cause the purchasing power of cash flow from an
investment to decline.
• Legislative Risk – The risk of a legislative ruling resulting in adverse consequences.
• Market Risk – The risk that the value of securities may go up or down, sometimes rapidly or
unpredictably, due to factors affecting securities markets generally or particular industries. This is a risk
that will affect all securities in the same manner caused by some factor that cannot be
controlled by diversification
• Reinvestment Risk – The risk that falling interest rates will lead to a decline in cash flow from an
investment when its principal and interest payments are reinvested at lower rates.
• Social/Political Risk – The possibility of nationalization, unfavorable government action or social changes
resulting in a loss of value.
• Taxability Risk – The risk that a security that was issued with tax-exempt status could potentially lose that
status prior to maturity. Since municipal bonds carry a lower interest rate than fully taxable bonds, the bond
holders would end up with a lower after-tax yield than originally planned.
• Terrorism Risk – An act of terror or calculated use of violence against the country, market structure or
individuals.
The firm’s methods of analysis and investment strategies do not represent any significant or unusual risks
however; all strategies have inherent risks and performance limitations.
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Types of Investments (Examples, not limitations)
Investment advisor representatives of the firm allocate a Client’s assets as appropriate to help them reach
their individual investment objectives within their time horizon in a manner consistent with their risk profile.
Client funds are allocated appropriately in such investments as listed below:
• Cash Positions – Based on perceived or anticipated market conditions and/or events, certain assets may
be taken out of the market and held in a defensive cash position. All cash may be included as assets
subject to the agreed upon advisory fee. Other investment types may be included as appropriate for a
Client and their respective trading objectives. WealthGen Advisors, LLC, generally invest Client’s cash
balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper
and/or government backed debt instruments. Ultimately, the firm tries to achieve a reasonable return
on our Client’s cash balances through relatively low-risk conservative investments.
• Equity – An investment that generally refers to buying shares of stocks in return for receiving a future
payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities
may fluctuate in response to specific situations for each company, industry conditions and the general
economic environment. The importance of dividends are more during market down-turns.
• Exchange Traded Funds (ETFs) – An ETF is a portfolio of securities invested to track a market index
like an index mutual fund, but the shares are traded on an exchange like an equity. An ETF share price
fluctuates intraday depending on market conditions instead of having a net asset value (NAV) that is
calculated once at the end of the day. The shares may trade at a premium or discount; and as a result,
investors pay when purchasing shares and receive more or less than when selling shares. The supply of
ETF shares is regulated through a mechanism known as creation and redemption that involves large
specialized investors, known as authorized participants (APs). Authorized participants are large financial
institutions with a high degree of buying power, such as market makers, banks or investment companies
that provide market liquidity. When there is a shortage of shares in the market, the authorized participant
creates more (creation). Conversely, the authorized participant will reduce shares in circulation
(redemption) when supply falls short of demand. Multiple authorized participants help improve the
liquidity of an ETF and stabilize the share price. To the extent that authorized participants cannot or are
otherwise unwilling to engage in creation and redemption transactions, shares of an ETF tend to trade at
a significant discount or premium and may face trading halts and delisting from the exchange. The
performance of ETFs is subject to market risk, including the complete loss of principal. ETFs also have
a trading risk based on cost inefficiency if the ETFs are actively traded and a liquidity risk if the ETFs
has a significant price spread and low trading volume. In addition, investors buying or selling shares in
the secondary market pay brokerage commissions, which is a cost not incurred by mutual funds. Like
mutual funds, shares of an ETF represent partial ownership of an underlying portfolio of securities.
o Inverse ETFs - An inverse ETF seeks to deliver inverse returns of underlying indexes. To achieve
their investment results, inverse ETFs generally use derivative securities, such as swap
agreements, forwards, futures contracts and options. Inverse ETFs are designed for speculative
traders and investors seeking tactical day trades against their respective underlying indexes.
Inverse ETFs only seek investment results that are the inverse of their benchmarks' performances
Page 16 of 33
for one day only. Inverse ETFs carry many risks and are not suitable for risk-averse investors.
This type of ETF is best suited for sophisticated, highly risk-tolerant investors who are
comfortable with taking on the risks inherent to inverse ETFs. The principal risks associated with
investing in inverse ETFs include compounding risk, derivative securities risk, correlation risk
and short sale exposure risk. Compounding risk is one of the main types of risks affecting inverse
ETFs. Inverse ETFs held for periods longer than one day are affected by compounding returns.
Since an inverse ETF has a single-day investment objective of providing investment results that
are one times the inverse of its underlying index, the fund's performance likely differs from its
investment objective for periods greater than one day. Investors who wish to hold inverse ETFs
for periods exceeding one day must actively manage and rebalance their positions to mitigate
compounding risk.
• Exchange-Traded Notes (ETNs) – An ETN is a senior unsecured debt obligation designed to track the
total return of an underlying market index or other benchmark. ETNs may be linked to a variety of assets,
for example, commodity futures, foreign currency and equities. ETNs are similar to ETFs in that they are
listed on an exchange and can typically be bought or sold throughout the trading day.
• Fixed Income – An investment that generally pays a return on a fixed schedule, though the amount of the
payments can vary. This type of investment can include corporate and government debt securities,
leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and
other asset-backed securities, although individual bonds may be the best-known type of fixed income
security. In general, the fixed income market is volatile, and fixed income securities carry interest rate
risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is often more pronounced
for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury inflation
protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely);
however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing
in foreign fixed income securities also include the general risk of non-U.S. investing described below.
• Mutual Funds – A pool of funds collected from many investors to invest in securities such as stocks,
bonds, money market instruments and similar assets.
o Open-End Mutual Funds – A type of mutual fund that does not have restrictions on the amount of
shares the fund will issue and will buy back shares when investors wish to sell. Investing in mutual
funds carries the risk of capital loss, and thus you may lose money investing in mutual funds. All
mutual funds have internal costs that lower investment returns. The funds can be of bond “fixed
income” nature (lower risk) or stock “equity” nature
o Closed-End Mutual Funds – A type of mutual fund that raises a fixed amount of capital through an
initial public offering (IPO). The fund is then structured, listed and traded like a stock on a stock
exchange. Clients should be aware that closed-end funds available within the program are not readily
marketable. To provide investor liquidity, the funds may offer to repurchase a certain percentage of
shares at net asset value on a periodic basis. Thus, Clients may be unable to liquidate all or a portion
of their shares in these types of funds.
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o Alternative Strategy Mutual Funds – Certain mutual funds available in the program invest primarily
in alternative investments and/or strategies. Investing in alternative investments and/or strategies may
not be suitable for all investors and involves special risks, such as risks associated with commodities,
real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces,
regulatory changes and potential illiquidity. There are special risks associated with mutual funds that
invest principally in real estate securities, such as sensitivity to changes in real estate values and
interest rates and price volatility because of the fund’s concentration in the real estate industry.
• Non-U.S. Securities – Securities that present certain risks such as currency fluctuation, political and
economic change, social unrest, changes in government regulation, differences in accounting and the
lesser degree of accurate public information available.
• Unit Investment Trust (UIT) – An investment company that offers a fixed, unmanaged portfolio,
generally of stocks and bonds, as redeemable "units" to investors for a specific period. It is designed to
provide capital appreciation and dividend income. UITs can be resold in the secondary market. A UIT
may be either a regulated investment corporation (RIC) or a grantor trust. The former is a corporation in
which the investors are joint owners; the latter grants investors proportional ownership in the UIT's
underlying securities.
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 firm.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving the firm or any of its Supervised Persons.
Item 10 – Other Financial Industry Activities and Affiliations
WealthGen Advisors, LLC has no other activities or affiliations to disclose.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
The firm has implemented a Code of Ethics (the “Code”) that defines our fiduciary commitment to each Client.
This Code applies to all persons associated with the firm (our “Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding our duties to Clients. WealthGen
Advisors and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the
obligation of the firm'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 our Code, please contact us at (941) 706-4151 or by email at
ken@wealthgenadvisor.com.
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Personal Trading with Material Interest
WealthGen Advisors allows our Supervised Persons to purchase or sell the same securities that are bought or sold
for Clients. WealthGen Advisors does not act as principal in any transactions. In addition, WealthGen Advisors
does not act as the general partner of a fund or advise an investment company. WealthGen Advisors, LLC does
not have a material interest in any securities traded in Client accounts.
Personal Trading in Same Securities as Clients
WealthGen Advisors, LLC allows Investment Advisor Representatives to purchase or sell the same securities that
are bought or sold for Clients. Owning the same securities bought or sold for Clients presents a conflict of interest
that, as fiduciaries, the firm must disclose to Clients and mitigate through policies and procedures. As noted
above, WealthGen Advisors, LLC has adopted a 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, Investment Advisor Representatives have a conflict of interest if trading in the same securities.
The fiduciary duty to act in the best interest of its Clients can potentially be violated if personal trades are made
with more advantageous terms than Client trades, or by trading based on material non-public information. The
firm will require that personal securities trades made by Investment Advisor Representatives be reported to the
Chief Compliance Officer (“CCO”) for review. Currently, Mr. Hargreaves serves as the CCO and the sole
investment adviser representative. We have also adopted written policies and procedures to detect the misuse of
material, non-public information.
Personal Trading at Same Time as Client
While WealthGen Advisors allows Investment Advisor Representatives to purchase or sell the same securities
that are bought or sold for Clients, such trades are typically aggregated with Client orders or traded afterwards.
At no time will the firm or Investment Advisor Representatives trade to the detriment of any Client.
Item 12 – Brokerage Practices
Schwab Advisor Services, a division of Charles Schwab & Co., Inc (“Schwab”)
WealthGen Advisors requires that clients establish brokerage accounts with the Schwab Advisor Services, a
division of Charles Schwab & Co., Inc. (Schwab), a member FINRA/SIPC broker/dealer to maintain custody of
clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the
discretion of the Advisor’s clients, including those accounts under ERISA or IRA rules and regulations, in which
case the client is acting as either the plan sponsor or IRA accountholder.
WealthGen Advisors is independently owned and operated and not affiliated with Schwab. Schwab provides
WealthGen Advisors with access to its institutional trading and custody services, which are typically not available
to Schwab retail investors. These services generally are available to independent investment advisors on an
unsolicited basis, at no charge to advisors. Schwab’s services include brokerage services that are related to the
execution of securities transactions, custody, research, including that in the form of advice, analyses and reports,
and access to mutual funds and other investments that are otherwise generally available only to institutional
investors or would require a significantly higher minimum initial investment.
Schwab also makes available to WealthGen Advisors other products and services that benefit WealthGen
Advisors but may not benefit its clients’ accounts. These benefits can include national, regional or WealthGen
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Advisors specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential
benefits may include occasional business entertainment of personnel of WealthGen Advisors by Schwab Advisor
Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms
of entertainment, some of which may accompany educational opportunities. Other of these products and services
assist WealthGen Advisors in managing and administering clients’ accounts. These include software and other
technology (and related technological training) that provide access to client account data (such as trade
confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for
multiple client accounts), provide research, pricing information and other market data, facilitate payment of
WealthGen Advisors’ fees from its clients’ accounts, and assist with back-office training and support functions,
recordkeeping and client reporting. Many of these services generally may be used to service all or some
substantial number of WealthGen Advisors accounts, including accounts not maintained at Schwab Advisor
Services. Schwab Advisor Services also makes available to WealthGen Advisors other services intended to help
WealthGen Advisors manage and further develop its business enterprise. These services may include professional
compliance, legal and business consulting, publications and conferences on practice management, information
technology, business succession, regulatory compliance, employee benefits providers, human capital consultants,
and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services
rendered to WealthGen Advisors by independent third parties. Schwab Advisor Services may discount or waive
fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing
these services to WealthGen Advisors. While, as a fiduciary, WealthGen Advisors endeavors to act in its clients’
best interests, the recommendation/requirement that clients maintain their assets in accounts at Schwab may be
based in part on the benefit to WealthGen Advisors of the availability of some of the foregoing products and
services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services
provided by Schwab, which creates a conflict of interest. WealthGen Advisors believes that its requirement to
use Schwab as it custodian based on the services provided and fees charges
Best Execution
Although the commissions and/or transaction fees paid by our Clients generally comply with our duty to obtain
best execution, Clients may pay a commission that is higher than what another qualified broker-dealer might
charge to affect the same transaction when we determine, in good faith, that the commission/transaction fee is
reasonable in relation to the value of the brokerage and research services we receive.
In seeking best execution, the determining factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services,
including the value of research provided, execution capability, commission rates, and responsiveness.
Accordingly, although we will seek competitive rates, we may not necessarily obtain the lowest possible
commission rates for Client transactions. The brokerage commissions or transaction fees charged by the broker-
dealer/custodian are exclusive of, and in addition to, our investment management fee. Our best execution
responsibility is qualified if the securities we purchase are mutual funds that are traded at net asset value as
determined at the daily market close.
Aggregation & Allocation of Transactions
Although each Client’s portfolio accounts are individually managed, we can purchase or sell the same securities
at the same time for multiple Clients. When this occurs, it is often advantageous to aggregate the securities of
multiple Clients into one trading block for execution. If your portfolio securities are purchased or sold in an
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aggregated transaction with the securities of other Clients, you will all receive the same execution price, and if
the aggregated purchase or sale involves several executions to complete the transaction, you will all receive the
average price paid or received on the aggregated transaction.
However, if an aggregated transaction results in only a partial execution and the equal allocation of the partial
execution amongst multiple Clients would result in an inefficient trading unit in Client portfolios, we reserve the
right to allocate the transaction to specific individual Clients on an equitable rotational basis so that over time no
Client is disadvantaged in the management of its portfolio.
Directed Brokerage
WealthGen Advisors, LLC does not accept directed brokerage arrangements (when a Client requires that account
transactions be affected through a specific broker-dealer).
Soft Dollars
A soft dollar arrangement is a revenue programs offered to an advisor in exchange for directing securities
transactions. WealthGen Advisors, LLC receives support services without cost, at a discount, and/or at a
negotiated rate, that include such things as research reports or other information about particular companies or
industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial
database software and services; computerized news and pricing services; quotation equipment for use in running
software used in investment decision-making.
These support services are provided based on the overall relationship without a minimum production level or
value of assets held with the custodian. Consequently, they are not the result of soft dollar arrangements or any
other express arrangements that involves the execution of Client transactions as a condition to the receipt of
services.
Cash Sweep Program
Investment portfolios often include a cash allocation to maintain liquidity, manage risk, and provide funds for
opportunistic investments. Cash allocations can serve as a buffer against market volatility and ensure funds are
readily available for future investment opportunities or withdrawals. Sweep programs automatically transfer
uninvested cash from a brokerage account into a money market fund or other short-term investment vehicle at the
custodian. This process is automated and occurs regularly, often at the end of each business day. While the cash
is held in the sweep account, it earns interest. This ensures that even idle cash generates some return, albeit
typically lower than other investment options. By automating cash movement, sweep programs reduce the need
for manual transfers, saving time and minimizing the risk of human error in managing cash balances. Sweep
accounts provide quick access to cash for reinvestment or withdrawals, enhancing liquidity management within
the portfolio. Minimizing manual cash management tasks reduces administrative burdens for investors and
advisors, allowing them to focus on strategic investment decisions. Sweep programs often offer lower interest
rates than short-term investments like high-yield savings accounts or CDs. This is due to their liquidity and
convenience. While convenient, the lower interest rates mean that investors can miss out on higher returns if cash
is kept in the sweep account for extended periods. The advisor uses sweep programs strategically to manage cash
flows within a portfolio, ensuring that cash is readily available for investment opportunities without sacrificing
significant returns. Sweep accounts can also be used to facilitate regular transactions, such as automatic
withdrawals for living expenses or periodic investments in other asset classes. While sweep programs offer
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convenience and liquidity, they require careful consideration as part of an overall investment strategy. Advisors
and clients should weigh the benefits of liquidity and automation against the potential for higher returns through
alternative cash management strategies.
Item 13 – Review of Accounts
Frequency of Reviews
Client accounts are monitored on a regular and continuous basis by Mr. Hargreaves as the Chief Compliance
Officer. Formal reviews are generally conducted at least annually with the client and as needed.
Causes for Reviews
In addition to the investment monitoring noted above, each Client account shall be reviewed at least annually.
Accounts are generally 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. Clients are encouraged
to notify the firm 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.
Review Reports
Clients will receive statements no less than quarterly from the Custodian. These statements are sent directly from
the Custodian. Clients can also establish electronic access to the Custodian’s website so that they can view these
reports and their account activity. Client statements will include all positions, transactions and fees relating to the
Client’s account[s].
Item 14 – Client Referrals and Other Compensation
WealthGen Advisors, LLC does not engage paid solicitors for Client referrals or have additional referral
compensation to disclose.
Item 15 – Custody
WealthGen Advisors, LLC does not have physical custody of Client funds or securities. All Clients receive at
least quarterly account statements directly from the custodians. Upon opening an account with a qualified
custodian Clients are provided with contact information.
WealthGen Advisors, LLC has indirect or constructive custody of client funds based on the ability to withdraw
fees from client accounts:
• WealthGen Advisors must obtain client authorization for direct fee deduction,
• WealthGen Advisors concurrently sends an invoice to the client when an invoice is sent to the
custodian for payment,
• The custodian will send quarterly invoices to the client wherein WealthGen Advisors fees are itemized.
Clients should review the statements they receive form the custodian and comapre them to the invoice they
receive from WealthGen Advisors. Clients should alert WealthGen Advisors of any fee discrepancies.
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Item 16 – Investment Discretion
The firm requires discretionary authority for asset management. Discretion includes the authority to
determine the securities to be bought or sold as well as the amount. Prior to the firm assuming discretionary
authority over a Client’s account, the Client shall be required to execute a written agreement, granting the
firm full or limited authority to buy, sell, or otherwise effect transactions.
Item 17 – Voting Client Securities
WealthGen Advisors, LLC does not vote Client proxies, but third-party money managers selected or
recommended by our firm may vote proxies for Clients. Clients will otherwise receive their proxies or other
solicitations directly from their custodian. Except in the event a third-party money manager votes proxies, Clients
maintain exclusive responsibility for:
• directing the manner in which proxies solicited by issuers of securities beneficially owned by the Client
shall be voted; and,
• making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other
type events pertaining to the Client’s investment assets.
Item 18 – Financial Information
Neither the firm nor its management have any adverse financial situations that would reasonably impair their
ability to meet all obligations to its Clients.
• Neither the firm nor any of its control persons has been subject to a bankruptcy or financial compromise.
• The firm does not collect advance fees of $1,200 or more for services to be performed six months or more
in the future.
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Item 1 – Cover Page
Registered as WealthGen Advisors, LLC
1239 N. Gulfstream Ave., Ste 4, Sarasota, FL 34236
Phone: (941) 706-4151
www.WealthGenAdvisor.com
Kenneth J. Hargreaves
ADV 2B – Individual Disclosure Brochure
CRD No. 5495305
August 31, 2026
This brochure supplement provides information about your Investment Advisor Representative that supplements
the firm disclosure brochure. You should have received a copy of the firm brochure that describes the investment
advisory services offered through WealthGen Advisors, LLC a registered investment advisor. Please contact
WealthGen Advisors, LLC at the telephone number above if you did not receive their brochure or if you have any
questions about the contents of this supplement. Additional information about your Investment Advisor
Representative is available on the SEC’s website at www.adviserinfo.sec.gov.
Page 24 of 33
Item 2 – Educational Background and Business Experience
This section of the brochure supplement includes the supervised person’s name, age (or year of birth), formal
education after high school, and business background (including an identification of the specific positions held)
for the preceding five years.
Kenneth J. Hargreaves
Year of Birth: 1985
Education
The following information details your Financial Advisor’s formal education. If a degree was attained, the type
of degree will be listed next to the name of the institution. If a degree is not listed, the Financial the firm attended
the institution but did not attain a degree.
Florida State University – BS Finance (2008)
Professional Designations
The following provides information on professional designation(s) that your Financial Advisor earned.
Certified Financial Planner - CFP® 03/2012
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States
by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is
voluntary; no federal or state law or regulation requires financial planners to hold CFP® certification. It is
recognized in the United States and a number of other countries for its:
(1) high standard of professional education;
(2) stringent code of conduct and standards of practice; and,
(3) ethical requirements that govern professional engagements with Clients.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfil the following
requirements:
Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and professional
delivery of financial planning services, and attain a bachelor’s degree from a regionally accredited United
States college or university (or its equivalent from a foreign university). CFP Board’s financial planning
subject areas include insurance planning and risk management, employee benefits planning, investment
planning, income tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered
in 10 hours over two days, includes case studies and Client scenarios designed to test one's ability to
correctly diagnose financial planning issues and apply one's knowledge of financial planning to real-world
circumstances;
Page 25 of 33
Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by the CFP Board's Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals. Individuals who become certified
must complete the following ongoing education and ethics requirements to maintain the right to continue
to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two years,
including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct,
to maintain competence and keep up with developments in the financial planning field; and,
Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary
standard of care. This means CFP® professionals must provide financial planning services in the best
interests of their Clients. CFP® professionals who fail to comply with the above standards and
requirements may be subject to CFP Board’s enforcement process, which could result in suspension
or permanent revocation of their CFP® certification.
Accredited Wealth Management Advisor® - AWMA®
Designation: Accredited Wealth Management Advisor (AWMA). Issuing Organization: College for
Financial Planning. Prerequisites/Experience Required: None. Educational Requirements: Self-study
course: 15 modules requiring 120-150 hours. Continuing Education: 16 hours every two years.
Chartered Retirement Planning Counselor® - CRPC®
Designation: Chartered Retirement Planning Counselor (CRPC). Issuing Organization: College for
Financial Planning. Prerequisites/Experience Required: None. Educational Requirements: Self-study
course (11 modules requiring 90-100 hours). Continuing Education: 16 hours every two years.
Accredited Investment Fiduciary® - AIF®
Designation: Accredited Investment Fiduciary (AIF). Issuing Organization: Center for Fiduciary Studies.
Prerequisites/Experience Required: None. Educational Requirements: Candidate must complete one of
the following: Web-based program or Capstone program. Continuing Education: 6 hours per year.
Business Experience
The following information details your Financial Advisor’s business experience for at least the past five years.
12/2019 - Present
WealthGen Advisors, LLC
President, Chief Compliance Officer and Investment Advisor Representative
03/2012 – 12/2019
Capital Group Companies
Vice President
11/2009 – 03/2012
Mosely Investment Management, Inc.
Investment Advisor Representative
02/2008 – 10/2009
Ameriprise Financial Services, Inc.
Financial Advisor
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Item 3 – Disciplinary Information
This section includes any legal or disciplinary events and material to a Client's or prospective Client's evaluation
of the supervised person.
There are no legal or disciplinary events required to be disclosed in response to this item. Any such
disciplinary information would be available at www.adviserinfo.sec.gov.
Item 4 – Other Business Activities
This section includes any relationship between the advisory business and the supervised person’s other financial
industry activities that creates a material conflict of interest with Clients and describes the nature of the conflict
and generally how it is addressed. If the supervised person is actively engaged in any investment-related business
or occupation, including if the supervised person is registered, or has an application pending to register, as a
broker-dealer, registered representative of a broker-dealer, futures commission merchant ("FCM"), commodity
pool operator ("CPO"), commodity trading advisor ("CTA"), or an associated person of an FCM, CPO, or CTA,
the business relationship, if any, between the advisory business and the other business, is disclosed below.
There are no investment related business activities to disclose.
Item 5 – Additional Compensation
This section includes details regarding if someone who is not a Client provides an economic benefit to the
supervised person for providing advisory services. For purposes of this Item, economic benefits include sales
awards and other prizes, but not the supervised person’s regular salary, if any.
There is no compensation requirement to disclose.
Item 6 – Supervision
This section explains how WealthGen Advisors, LLC supervises the supervised person, including how the advice
the supervised person provided to Clients is monitored.
WealthGen Advisors, LLC maintains a supervisory structure and system reasonably designed to prevent
violations of applicable state rules and regulations. Richard A. Rayles, III serves as the Chief Compliance
Officer and is responsible for administering the policies and procedures and a system of technology-based
controls to monitor account activity for irregularities or patterns that require review and potential action
that may lead to disciplinary action or reimbursements. His telephone number is 941-706-4151 should
any questions or issues arise.
Page 27 of 33
Item 1 - Cover Page
Registered as WealthGen Advisors, LLC
1239 N. Gulfstream Ave., Ste 4, Sarasota, FL 34236
Phone: (941) 706-4151
www.WealthGenAdvisor.com
Richard A. Rayles, III
ADV 2B – Individual Disclosure Brochure
CRD No. 7820684
August 31, 2026
This brochure supplement provides information about your Investment Advisor Representative that supplements
the firm disclosure brochure. You should have received a copy of the firm brochure that describes the investment
advisory services offered through WealthGen Advisors, LLC a registered investment advisor. Please contact
WealthGen Advisors, LLC at the telephone number above if you did not receive their brochure or if you have any
questions about the contents of this supplement. Additional information about your Investment Advisor
Representative is available on the SEC’s website at www.adviserinfo.sec.gov.
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Item 2 - Educational Background and Business Experience
This section of the brochure supplement includes the supervised person’s name, age (or year of birth), formal
education after high school, and business background (including an identification of the specific positions held)
for the preceding five years.
Richard A. Rayles, III
Year of birth: 1979
Education
The following information details your Financial Advisor’s formal education. If a degree was attained, the type
of degree will be listed next to the name of the institution. If a degree is not listed, the individual attended the
institution but did not attain a degree.
University of Central Florida – Finance (2004)
Business Experience
The following information details your Financial Advisor’s business experience for at least the past five years.
07/2023 - Present
WealthGen Advisors, LLC
Investment Advisor Representative
08/2020 – 07/2023
Self-Employed
Owner
02/2017 – 08/2020
DM Creative
Project Manager
02/2015 – 01/2017
Kryptonite Digital
Operations Director
10/2013 – 02/2015
BNY Mellon
Mutual fund Accountant
03/2009 – 06/2013
Goldrock Global FX (International Goldrock Ltd)
Chief FX Dealer of Market Making
01/2007 – 03/2009
I Trade FX
Senior Spot FX Trader
Professional Designations
The following provides information on professional designation(s) that your Financial Advisor earned.
The Investment Adviser Certified Compliance Professional® (IACCP®)
The Investment Adviser Certified Compliance Professional® (IACCP®) designation is awarded to
individuals who complete an instructor-led program of in-person and/or online study, pass a certifying
examination, complete an ethics assessment, and meet a minimum requirement of two years of work
experience related to investment adviser compliance. The designation signifies intermediate-level
knowledge of investment adviser regulation and compliance best practices. IACCP Designees are required
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to annually complete 10 General and 2 Ethics continuing education (CE) credits to maintain their
designation.
Extensive development of course and certification materials, together with expert instructors and
facilitators from the compliance, legal, regulatory, financial industry, and academic sectors, help ensure
that individuals earning the IACCP designation have been trained, tested and certified to meet high
investment adviser industry professional standards. The IACCP program is co-sponsored by Comply and
the Investment Adviser Association (IAA).
I am certified as an INVESTMENT ADVISER CERTIFIED COMPLIANCE PROFESSIONAL ® or
IACCP®, and I may use this certification mark. The IACCP designation is voluntary and is sponsored by
Comply and the Investment Adviser Association (IAA). No federal or state law or regulation requires
investment adviser compliance professionals to hold the IACCP designation. More information about the
IACCP designation can be found at https://www.comply.com/services/education-iaccp.
IACCP Designees have met high standards for education, examination, experience, and agree to adhere
to professional and ethical standards. To become an IACCP Designee, an individual must fulfill the
following requirements:
• Education: The IACCP Program coursework consists of 17 required compliance courses and
three electives. The courses are grouped into the following categories: the Advisers Act,
Disclosures, Trading, Mandates, Ethics, Skills, and Electives. All are two hours in length and are
available either live/in-person or live/online.
• Examination: Pass the comprehensive IACCP Certifying Examination. The Examination tests
the candidate's knowledge of investment adviser regulations as well as industry best practice, as
presented in the IACCP education courses and material. This representation of industry best
practice is driven by compliance industry consensus and periodic job task analysis, gained through
subject matter experts with decades of experience in the compliance field. The purpose of the
IACCP Examination is to help ensure that investment adviser compliance professionals have a
minimum level of general foundation knowledge related to applicable regulatory laws, rules,
requirements, and certain best practices.
• Experience: Provide proof of a minimum of two years of work experience relating to investment
adviser compliance.
• Ethics: Complete an Ethics Assessment and agree to adhere to the IACCP Code of Ethics and
Professional Standards of Conduct.
Individuals who become certified as IACCP Designees must complete the following ongoing education and ethics
requirements to maintain the right to continue to use the IACCP designation.
• Continuing Education: Complete 12 professional continuing education (CE) credit hours each
year. Two (2) of the 12 credit hours must be earned by attending an approved ethics program(s).
The purpose of the IACCP Continuing Education Requirement is to ensure that IACCP Designees
maintain and enhance professional competence; maintain the IACCP certification; review ethics
and professional standards of conduct; remain current with regulatory changes and trends; refresh
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investment adviser compliance knowledge; and increase the level and depth of investment adviser
knowledge. Credits can be earned by attending qualified educational programs offered through
Comply, IAA, or certain other industry educational providers.
• Ethics: Commit to continued compliance with the IACCP Code of Ethics and Professional
Standards of Conduct.
Item 3 - Disciplinary Information
This section includes any legal or disciplinary events and material to a Client's or prospective Client's evaluation
of the supervised person.
There are no legal or disciplinary events required to be disclosed in response to this item. Any such
disciplinary information would be available at www.adviserinfo.sec.gov.
Item 4 - Other Business Activities
This section includes any relationship between the advisory business and the supervised person’s other financial
industry activities that creates a material conflict of interest with Clients and describes the nature of the conflict
and generally how it is addressed. If the supervised person is actively engaged in any investment-related business
or occupation, including if the supervised person is registered, or has an application pending to register, as a
broker-dealer, registered representative of a broker-dealer, futures commission merchant ("FCM"), commodity
pool operator ("CPO"), commodity trading advisor ("CTA"), or an associated person of an FCM, CPO, or CTA,
the business relationship, if any, between the advisory business and the other business, is disclosed below.
There are no investment related business activities to disclose.
Item 5 - Additional Compensation
This section includes details regarding if someone who is not a Client provides an economic benefit to the
supervised person for providing advisory services. For purposes of this Item, economic benefits include sales
awards and other prizes, but not the supervised person’s regular salary, if any.
There is no compensation requirement to disclose.
Item 6 – Supervision
This section explains how WealthGen Advisors, LLC supervises the supervised person, including how the advice
the supervised person provided to Clients is monitored.
WealthGen Advisors, LLC maintains a supervisory structure and system reasonably designed to prevent
violations of applicable state rules and regulations. Richard A. Rayles, III serves as the Chief
Compliance Officer and is responsible for administering the policies and procedures and a system of
technology-based controls to monitor account activity for irregularities or patterns that require review
and potential action that may lead to disciplinary action or reimbursements. His telephone number is
941-706-4151 should any questions or issues arise.
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Privacy Policy
Our Commitment to You
WealthGen Advisors (“the firm”) 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 the firm, as described herein 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. The firm (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. WealthGen Advisors, LLC 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 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
Account applications and forms
Other advisory agreements and legal documents
Investment questionnaires and suitability
documents
Transactional information with us or others
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 the 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.
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How do we share your information?
WealthGen Advisors, LLC 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
Servicing our Clients
We share information with technology vendors and third-party service
providers to manage and support operations and regulatory compliance
(such as administrators, brokers, custodians, regulators, credit agencies,
consultants and 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.
No
Not Shared
Marketing Purposes
The firm 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 WealthGen
Advisors 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.
Yes
Yes
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).
No
Not Shared
Information About Former Clients
The firm 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.
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 (941) 706-4151 or by email at Ken@WealthGenAdvisor.com.
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