Overview
- Headquarters
- Fallbrook, CA
- Total Firm Assets
- $112 million
- Average High-Net-Worth Client Portfolio Size
- $1.7 million
Fee Disclosure
FORM ADV PART 2A - WEALTHLYNK, INC.
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.10% |
| $1,000,001 | and above | 1.00% |
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $11,750 | 1.18% |
| $5 million | $51,750 | 1.04% |
| $10 million | $101,750 | 1.02% |
| $50 million | $501,750 | 1.00% |
| $100 million | $1,001,750 | 1.00% |
Clients
- High-Net-Worth Share of Firm Assets
- 56.42%
- Number of High-Net-Worth Clients
- 38
- Total Client Accounts
- 178
- Non-Discretionary Accounts
- 178
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 327527
Primary Brochure: FORM ADV PART 2A - WEALTHLYNK, INC. (2026-09-18)
View Document Text
Wealthlynk, Inc.
Firm Brochure – Form ADV Part 2A
This brochure provides information about the qualifications and business practices of
Wealthlynk, Inc. and of its principal, Scott Raygene Weber. If you have any questions about
the contents of this brochure, please contact us at (760) 621-4471
or scott.weber@wealthlynk.com. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission or by any state
securities authority.
Additional information about Scott Raygene Weber is available on the SEC’s website
at www.adviserinfo.sec.gov (CRD: 327527).
1615 S Mission Rd, Suite A
Fallbrook, CA 92028
(760) 621-4471
scott.weber@wealthlynk.com
Registration as an investment adviser does not imply a certain level of skill or training.
Version Date: 09/18/2026
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Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment
dated 01/16/2026 are described below. Material changes relate to Wealthlynk, Inc.’s
policies, practices, or conflicts of interest only.
• Wealthlynk, Inc. has successfully transitioned to registration with the United States
Securities and Exchange Commission from its prior registration at the state level.
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Item 3: Table of Contents
Item 2: Material Changes .......................................................................................................................... 2
Item 3: Table of Contents .......................................................................................................................... 3
Item 4: Advisory Business ......................................................................................................................... 4
A. Description of the Advisory Firm ........................................................................................................ 4
B. Types of Advisory Services ................................................................................................................ 4
C. Client-Tailored Services and Restrictions ........................................................................................... 5
D. Wrap Fee Programs .......................................................................................................................... 5
E. Assets Under Management ............................................................................................................... 5
Item 5: Fees and Compensation ................................................................................................................ 5
A. Fee Schedule ................................................................................................................................... 5
B. Payment of Fees ............................................................................................................................... 6
C. Client Responsibility for Third-Party Fees ........................................................................................... 7
D. Prepayment of Fees; Refunds ............................................................................................................ 7
E. Outside Compensation for the Sale of Securities to Clients ................................................................. 7
Item 6: Performance-Based Fees and Side-By-Side Management ................................................................ 8
Item 7: Types of Clients ............................................................................................................................. 8
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .............................................................. 8
Item 9: Disciplinary Information................................................................................................................. 9
Item 10: Other Financial Industry Activities and Affiliations ......................................................................... 9
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................ 9
Item 12: Brokerage Practices ................................................................................................................... 10
Item 13: Review of Accounts ................................................................................................................... 11
Item 14: Client Referrals and Other Compensation ................................................................................... 11
Item 15: Custody .................................................................................................................................... 11
Item 16: Investment Discretion ................................................................................................................ 12
Item 17: Voting Client Securities (Proxy Voting) ......................................................................................... 12
Item 18: Financial Information ................................................................................................................. 12
Media and Public Communications ......................................................................................................... 13
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Item 4: Advisory Business
A. Description of the Advisory Firm
Wealthlynk, Inc. (“Wealthlynk”) is a California corporation founded in 2023. The Principal
Owner is Scott Raygene Weber.
B. Types of Advisory Services
Portfolio Management Services
We provide ongoing, non-discretionary portfolio management tailored to each client’s
goals, time horizon, and risk tolerance. Our process is typically memorialized in
an Investment Policy Statement (IPS) and may include:
•
Investment strategy and personal investment policy
• Asset allocation and security selection
• Risk tolerance assessment and monitoring
• Periodic portfolio monitoring and recommendations
We make recommendations consistent with our fiduciary duties and seek fair and
equitable allocation of opportunities over time.
Financial Planning
We offer financial planning on topics such as investments, retirement income, education
funding, insurance considerations, and tax considerations.
• Financial planning is provided to existing clients at no additional fee.
Services Limited to Specific Types of Investments
We generally provide advice regarding mutual funds, ETFs, equities, and fixed income.
We may use other securities when appropriate to help diversify a portfolio.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to your retirement plan or IRA, we act as a fiduciary
under ERISA and/or the Internal Revenue Code, as applicable. We will:
• Provide prudent advice and put your interests first
• Avoid misleading statements about conflicts, fees, and investments
• Maintain policies and procedures designed to ensure advice in your best interest
• Charge no more than is reasonable for our services
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• Provide basic information about conflicts of interest
Rollover Recommendations
For rollovers (e.g., plan-to-IRA, IRA-to-IRA), we document a comparative analysis of costs,
services, investment options, and your needs. Where we or our supervised persons receive
related compensation (e.g., insurance commissions), we provide written conflict
disclosures and the reasons we believe the recommendation is in your best interest.
C. Client-Tailored Services and Restrictions
We offer the same core services to all clients, tailored through the IPS. Clients may request
reasonable restrictions; certain restrictions (for example, excluding broad asset classes)
may limit our ability to implement recommendations.
D. Wrap Fee Programs
Wealthlynk does not participate in wrap fee programs.
E. Assets Under Management
As of June 2026, our regulatory assets under management (RAUM) were:
• Discretionary: $0
• Non-discretionary: $ 112,008,547
We monitor RAUM and will transition to SEC registration if and when we meet applicable
thresholds.
Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management (Blended, Asset-Based)
Total Assets Under Management
Annual Fee
$0 – $500,000
1.25%
$500,001 – $1,000,000
1.10%
$1,000,001 and up
1.00%
• The schedule above is blended by tier.
• Lower fees for comparable services may be available from other firms.
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• Fees are generally negotiable and will be stated in your advisory agreement.
• You may terminate without penalty for a full refund of Wealthlynk’s fees within five
business days of signing. Thereafter, termination requires 30 days’ written notice.
Financial Planning Fees
• Financial planning is provided to existing clients at no additional fee.
B. Payment of Fees
Standard (Default: Billed in Advance)
• Asset-based fees are debited monthly in advance by the qualified custodian with
your written authorization.
• Billing Value: the account’s market value as of the last business day of the prior
month (as reported by the custodian) × 1/12 of the applicable annual rate.
• Fees are prorated for additions/withdrawals during the period and for mid-period
terminations. Unearned prepaid fees are refunded on a prorated basis to the
termination date.
• You will receive custodian statements showing fee deductions. Upon request, we
provide an invoice showing the calculation, the period covered, and the value used.
•
In addition to our advisory fee, you may incur fund/ETF expenses and any
applicable custodial or transaction fees.
• For accounts custodied at Altruist Financial LLC (“Altruist”), fees are debited by
Altruist per your authorization and appear on Altruist statements.
• Tiering/Householding: we may aggregate household accounts for breakpoint
purposes and apply the blended rate to each tier.
• Valuation: prices are provided by the custodian. Assets the custodian cannot price
are handled under our valuation policy and may be excluded from billing unless
otherwise agreed.
• Third-Party Managers (if applicable): sub-advised strategies may include a separate
manager fee disclosed by that manager.
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Alternative (Billed in Arrears by Agreement or Account Type)
• Where specified in your agreement or required by account type, fees may be billed
in arrears monthly using the same Billing Value methodology. All other terms above
apply.
C. Client Responsibility for Third-Party Fees
You are responsible for all third-party fees (e.g., custodian fees, brokerage fees, fund/ETF
operating expenses, and transaction costs). These are separate from Wealthlynk’s fees.
See Item 12 for more information.
D. Prepayment of Fees; Refunds
We may collect fees in advance. Refunds of unearned prepaid fees are issued on
a prorated basis within fourteen (14) days by check or deposit back into your account.
Refund formula (for advance-billed, asset-based fees):
Refund = Prepaid fee − [Daily rate × days elapsed in billing period through termination date],
where Daily rate = Annual rate ÷ 365.
E. Outside Compensation for the Sale of Securities to Clients
Scott Raygene Weber is an insurance agent and may receive commissions or other
compensation related to insurance products.
• This creates a conflict of interest because it can incentivize recommendations
based on compensation rather than client need. Conflicts are disclosed and
documented.
• You are not obligated to purchase products through us; products may be available
elsewhere at lower cost.
• Commissions are not our primary source of compensation for advisory services.
• Advisory fees are not reduced to offset commissions or markups on recommended
products.
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Item 6: Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or any fees based on a share of capital gains or
capital appreciation.
Item 7: Types of Clients
We provide services to:
•
Individuals
• High-net-worth individuals
We have no account minimum.
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss
Methods of Analysis
Our analysis methods may include:
• Charting analysis (pattern recognition; risk: past performance may not predict
future results)
• Fundamental analysis (financial statements, management, competitive dynamics;
risk: market may not recognize perceived value)
• Modern portfolio theory (risk/return optimization; risk: model assumptions may not
hold in all markets)
Investment Strategies
• We primarily employ long-term strategies.
•
Investing in securities involves risk of loss that you should be prepared to bear.
Material Risks of Specific Securities
• Mutual funds/ETFs: market risk; operating expenses; premiums/discounts to NAV;
liquidity and tracking-error risks; complex strategies may involve
derivatives/leverage risks.
• Equities: company-specific, industry, and market risks.
• Fixed income: interest-rate, inflation, liquidity, call, and credit/default risks; longer
maturities typically have greater price sensitivity.
Past performance is not indicative of future results.
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Item 9: Disciplinary Information
• Criminal or Civil Actions: None
• Administrative Proceedings: None
• SRO Proceedings: None
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer/Futures/Commodities Registration
Wealthlynk and its personnel are not registered as, and have no pending applications to
become, a broker-dealer/registered representative, futures commission merchant,
commodity pool operator, or commodity trading advisor.
Other Business Activities and Conflicts
Scott Raygene Weber is an independent licensed insurance agent. This creates a conflict
due to commission-based compensation. We address this via best-interest processes,
disclosure, supervisory review, and documentation. There is no tying of services; clients
are never obligated to purchase insurance products, and products may be available
elsewhere on more favorable terms.
Selection of Other Advisers/Managers
We do not utilize or select third-party investment advisers.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Code of Ethics
Wealthlynk maintains a written Code of Ethics covering prohibited purchases and sales,
insider trading, personal trading, exempt transactions, conflicts, gifts and entertainment,
confidentiality, service on boards, compliance procedures, reporting, training,
recordkeeping, annual review, and sanctions. A copy is available upon request.
Recommendations Involving Material Financial Interests
We do not recommend securities in which the firm or related persons have a material
financial interest.
Personal Trading; Trading Around the Same Time as Clients
We maintain a restricted list and procedures to avoid conflicts, including trading in
securities we also recommend. Our policies are designed to mitigate conflicts associated
with trading at or around the same time as client transactions.
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Item 12: Brokerage Practices
Custodian/Broker-Dealer Selection and Best Execution
Wealthlynk can work with multiple qualified custodians. We prefer Altruist Financial LLC
(“Altruist”) based on overall value, including execution quality, access to fractional and
commission-free trading for many securities, digital account opening, service reliability,
and consolidated reporting. However, clients may choose a custodian other than
Altruist. We will make reasonable efforts to accommodate a client’s custodian preference.
Features, turnaround times, and costs may differ by custodian and could affect your
overall experience and total cost.
We have a duty to seek best execution, meaning we seek to obtain the most favorable
terms for you under the circumstances. We periodically assess the reasonableness of
services and costs across custodial options in light of the value provided, including quality
of trade execution, commissions/transaction costs, responsiveness, error resolution, and
technology.
Research and Other Soft-Dollar Benefits
We do not receive research, products, or services other than execution from custodians or
broker-dealers in connection with client transactions (“soft dollars”).
Brokerage for Client Referrals
We do not receive client referrals in exchange for selecting any broker-dealer or custodian.
Client-Directed Brokerage/Custody
Clients may direct Wealthlynk to use a specific custodian. Client-directed arrangements
may result in higher transaction costs or less favorable execution and may limit our ability
to aggregate orders.
Trade Aggregation
Given our non-discretionary model and individualized timing, we generally
do not aggregate or “block” trades. This may result in less favorable prices, particularly for
illiquid securities or during volatile markets. When multiple clients approve the same trade
on the same day, we may aggregate solely to seek better execution and will allocate
pro-rata by order size.
Trade Errors
We promptly correct trade errors. Clients will not bear losses attributable to our error. Any
gains from error corrections are typically retained by the custodian or a designated account
consistent with policy.
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Item 13: Review of Accounts
Periodic Reviews
Accounts receiving ongoing advisory services are reviewed at least quarterly by Scott
Raygene Weber, CEO and Chief Compliance Officer, with reference to the IPS and risk
tolerance.
Non-Periodic Reviews
Reviews may be triggered by material market, economic, or political events, or by changes
in your financial situation (e.g., retirement, job change, relocation, inheritance).
Reports to Clients
Clients receive account statements directly from the custodian showing holdings,
transactions, and fees deducted. Upon request, we provide an invoice showing the fee
calculation, period covered, and value used.
Item 14: Client Referrals and Other Compensation
Economic Benefits
We do not receive any economic benefit, directly or indirectly, from any third party for
providing advice to clients.
Compensation to Non-Advisory Personnel
We do not directly or indirectly compensate any non-advisory person for client referrals.
Item 15: Custody
Because advisory fees are deducted directly from client accounts, Wealthlynk is deemed
to have limited custody. In such cases, we will:
• Maintain written authorization from you to deduct fees from an account held by a
qualified custodian
•
Instruct the custodian to deduct fees in the authorized amount, with the custodian
providing statements directly to you at least quarterly (and monthly when activity
occurs) showing fee deductions
• Upon request, provide an invoice itemizing the fee, including the formula, period
covered, and the value used
Review custodian statements carefully and compare them to any invoices we provide.
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Item 16: Investment Discretion
Wealthlynk does not accept trading discretion. We implement trades only after obtaining
your consent (e.g., email or recorded confirmation). Market conditions between
recommendation and execution may impact prices and outcomes.
Item 17: Voting Client Securities (Proxy Voting)
Wealthlynk does not accept authority to vote client securities. You will receive proxies
directly from issuers or the custodian and should direct proxy questions to them.
Item 18: Financial Information
• Balance Sheet: We neither require nor solicit prepayment of more than $1,200 in
fees per client, six months or more in advance; therefore, a balance sheet is not
required.
• Financial Condition: Wealthlynk and its management have no financial condition
reasonably likely to impair our ability to meet contractual commitments to clients.
• Bankruptcy: Wealthlynk has not been the subject of a bankruptcy petition in the
past ten years.
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Media and Public Communications
Scott Raygene Weber may engage in public communications (e.g., television, radio,
podcasts, webinars, written articles, social media) to provide general financial education,
market commentary, and economic insights.
•
Information presented is educational and not personalized investment advice. Do
not make investment decisions solely based on such materials; please contact us
to discuss your circumstances.
• We do not disclose client-specific information without prior written consent and
comply with applicable advertising and communications rules, including
disclosures related to testimonials/endorsements and third-party ratings where
used.
• Views reflect information available at the time and may change without notice; we
are not obligated to update publicly disseminated materials.
• Avoid sharing sensitive information on public platforms. For questions, contact us
at scott.weber@wealthlynk.com.
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