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Disclosure Brochure
March 28, 2025
a Registered Investment Adviser
101 Main Street, Suite 220
Huntington Beach, CA 92648
(714) 536-4065
www.weaverconsultinggroup.com
This brochure provides information about the qualifications and business practices of Weaver Consulting
Group, LLC (hereinafter “Weaver Consulting Group” or the “Firm”). If you have any questions about the
contents of this brochure, please contact the Firm at the telephone number listed above. The information in this
brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC)
or by any state securities authority. Additional information about the Firm is available on the SEC’s website at
www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of
skill or training.
Disclosure Brochure
Weaver Consulting Group, LLC
Item 2. Material Changes
There are no material changes in this brochure from the last annual updating amendment on March 14, 2024, of Weaver
Consulting Group. Material changes relate to Weaver Consulting Group’s policies, practices or conflicts of interests.
The material changes in this brochure from the last annual updating amendment of Weaver Consulting Group on March
14, 2024, are described below. Material changes relate to Weaver Consulting Group ’s policies, practices or conflicts of
interests.
• Weaver Consulting Group updated its fees for Financial Planning and Consulting services. (Item 5)
• Weaver Consulting Group updated its fees for Investment Management services. (Item 5)
• FeeX changed its name to Pontera. (Item 5)
• Financial Planning fees can be paid via PayPal. (Item 5)
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Weaver Consulting Group, LLC
Item 3. Table of Contents
Item 2. Material Changes ................................................................................................................................................................. 2
Item 3. Table of Contents ................................................................................................................................................................ 3
Item 4. Advisory Business ............................................................................................................................................................... 4
Item 5. Fees and Compensation ....................................................................................................................................................... 7
Item 6. Performance-Based Fees and Side-by-Side Management ................................................................................................. 10
Item 7. Types of Clients ................................................................................................................................................................ 10
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .......................................................................................... 11
Item 9. Disciplinary Information ................................................................................................................................................... 13
Item 10. Other Financial Industry Activities and Affiliations ....................................................................................................... 13
Item 11. Code of Ethics ................................................................................................................................................................. 13
Item 12. Brokerage Practices ......................................................................................................................................................... 14
Item 13. Review of Accounts ........................................................................................................................................................ 17
Item 14. Client Referrals and Other Compensation ....................................................................................................................... 18
Item 15. Custody .......................................................................................................................................................................... 18
Item 16. Investment Discretion ...................................................................................................................................................... 19
Item 17. Voting Client Securities .................................................................................................................................................. 19
Item 18. Financial Information ...................................................................................................................................................... 20
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Disclosure Brochure
Weaver Consulting Group, LLC
Item 4. Advisory Business
Weaver Consulting Group offers a variety of advisory services, which include financial planning,
consulting, and investment management services. Prior to Weaver Consulting Group rendering any of the
foregoing advisory services, clients are required to enter into one or more written agreements with Weaver
Consulting Group setting forth the relevant terms and conditions of the advisory relationship (the “Advisory
Agreement”).
Weaver Consulting Group has been registered as an investment adviser since May 2017 and is principally
owned by Jason Weaver and Travis Weaver. As of December 2024, Weaver Consulting Group had
$892,892,590in assets under management, $892,892,590 .00 of which was managed on a discretionary basis
and $0.00 of which was managed on a non-discretionary basis.
While this brochure generally describes the business of Weaver Consulting Group, certain sections also
discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or
other persons occupying a similar status or performing similar functions), employees or any other person
who provides investment advice on Weaver Consulting Group’ behalf and is subject to the Firm’s
supervision or control.
Financial Planning and Consulting Services
Weaver Consulting Group offers clients a broad range of financial planning and consulting services, which
may include any or all of the following functions:
•
Education Planning
•
Investment Planning
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Cash Flow / Net Worth Planning
•
Insurance Planning
•
Trust and Estate Planning
•
Retirement Planning
•
Financial Reporting
•
Tax Planning
While each of these services is available on a stand-alone basis, certain of them may also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below). The Firm will use third parties for certain financial planning
and consulting services.
In performing these services, Weaver Consulting Group is not required to verify any information received
from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly
authorized to rely on such information. Weaver Consulting Group may recommend clients engage the Firm
for additional related services, its Supervised Persons in their individual capacities as insurance agents or
registered representatives of a broker-dealer and/or other professionals to implement its recommendations.
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Disclosure Brochure
Weaver Consulting Group, LLC
Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Weaver
Consulting Group or its affiliates to provide (or continue to provide) additional services for compensation,
including investment management services. Clients retain absolute discretion over all decisions regarding
implementation and are under no obligation to act upon any of the recommendations made by Weaver
Consulting Group under a financial planning or consulting engagement. Clients are advised that it remains
their responsibility to promptly notify the Firm of any change in their financial situation or investment
objectives for
the purpose of reviewing, evaluating or revising Weaver Consulting Group’
recommendations and/or services.
Investment and Wealth Management Services
Weaver Consulting Group manages client investment portfolios on a discretionary or non-discretionary
basis. In addition, Weaver Consulting Group may provide clients with wealth management services which
includes a broad range of comprehensive financial planning and consulting services as well as discretionary
and/or non-discretionary management of investment portfolios.
Weaver Consulting Group primarily allocates client assets among various mutual funds, structured notes,
individual debt and equity securities, and exchange-traded funds (“ETFs”) including closed-end and
leveraged ETFs, in accordance with their stated investment objectives.
Where appropriate, the Firm may also provide advice about any type of legacy position or other investment
held in client portfolios. Clients may engage Weaver Consulting Group to manage and/or advise on certain
investment products that are not maintained at their primary custodian, such as variable life insurance and
annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e.,
529 plans). In these situations, Weaver Consulting Group directs or recommends the allocation of client
assets among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or the custodian designated by the product’s provider.
Weaver Consulting Group tailors its advisory services to meet the needs of its individual clients and seeks
to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs
and objectives. Weaver Consulting Group consults with clients on an initial and ongoing basis to assess
their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the
management of their portfolios. Clients are advised to promptly notify Weaver Consulting Group if there
are changes in their financial situation or if they wish to place any limitations on the management of their
portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if
Weaver Consulting Group determines, in its sole discretion, the conditions would not materially impact the
performance of a management strategy or prove overly burdensome to the Firm’s management efforts.
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Disclosure Brochure
Weaver Consulting Group, LLC
Pension Consulting Services
Weaver Consulting Group offers consulting services to pension or other employee benefit plans (including
but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
identifying investment objectives and restrictions
providing guidance on various assets classes and investment options
recommending money managers to manage plan assets in ways designed to achieve objectives
•
•
•
• monitoring performance of money managers and investment options and making recommendations for
•
•
changes
recommending other service providers, such as custodians, administrators and broker-dealers
creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the
plan and its participants.
Written Acknowledgement of Fiduciary Status
When we provide 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.
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Disclosure Brochure
Weaver Consulting Group, LLC
Sponsor and Manager of Wrap Program
Weaver Consulting Group provides substantially all investment management services as the sponsor and
manager of a wrap program (the “Wrap Program”), a wrap fee program (i.e., an arrangement where
brokerage commissions and transaction costs are absorbed by the Firm). Accounts managed through the
Wrap Program are done so in substantially the same manner as those managed under a non-wrap
arrangement. Participants in the Wrap Program may pay a higher aggregate fee than if investment
management and brokerage services are purchased separately. Additional information about the Wrap
Program is available in Weaver Consulting Group’ Wrap Brochure, which appears as Part 2A Appendix 1
of the Firm’s Form ADV.
Item 5. Fees and Compensation
Weaver Consulting Group offers services on a fee basis, which may include fixed fees, as well as fees based
upon assets under management. Additionally, certain of the Firm’s Supervised Persons, in their individual
capacities, may offer securities brokerage services and/or insurance products under a separate commission-
based arrangement.
Financial Planning and Consulting Fees
Weaver Consulting Group charges a fixed fee for providing financial planning and consulting services
under a stand-alone engagement. These fees are negotiable, but generally range from $1,000-$5,000,
depending upon the scope and complexity of the services and the professional rendering the financial
planning and/or the consulting services. If the client engages the Firm for additional investment advisory
services, Weaver Consulting Group may offset all or a portion of its fees for those services based upon the
amount paid for the financial planning and/or consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement and Weaver Consulting Group generally requires one-half of the fee payable upon
execution of the Advisory Agreement. The outstanding balance is generally due upon delivery of the
financial plan or completion of the agreed upon services. Fees can be paid via PayPal. The Firm does not,
however, take receipt of $1,200 or more in prepaid fees in excess of six months in advance of services
rendered.
Investment Management Fees
Weaver Consulting Group offers investment management services for an annual fee based on the amount
of assets under the Firm’s management. This management fee generally varies between 15 and 150 basis
points (0.15%-1.5%), depending upon the size and composition of a client’s portfolio, the complexity of
services, the client’s risk tolerance, and the type of services rendered.
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Disclosure Brochure
Weaver Consulting Group, LLC
The annual fee is prorated and charged monthly, in arrears, based upon the market value of the average
daily account balance for that month. Since the asset-based fee is determined by average daily account
balance, if assets are deposited into or withdrawn from an account after the inception of a quarter, the base
fee payable with respect to such assets is adjusted accordingly. For the initial period of an engagement, the
fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final
billing period is prorated through the effective date of the termination and the outstanding or unearned
portion of the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), Weaver Consulting Group may
negotiate a fee rate that differs from the range set forth above.
Pension Consulting Fees
The rate for pension consulting services is between .15% - 1.0 % of the plan assets for which Weaver
Consulting Group is providing such consulting services. These fees are paid monthly in arrears. Weaver
Consulting Group may also charge hard dollar fees of $1,000-$25,000 for consulting services for companies
vs. a percentage of assets. Fees are negotiable.
Pontera
We use a third party platform to facilitate management of held away assets such as defined contribution
plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody
of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not
affiliated with the platform in any way and receive no compensation from them for using their platform. A
link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client
account(s) is connected to the platform, Weaver Consulting Group will review the current account
allocations. When deemed necessary, Weaver Consulting Group will rebalance the account considering
client investment goals and risk tolerance, and any change in allocations will consider current economic
and market trends. The goal is to improve account performance over time, minimize loss during difficult
markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at
least quarterly and allocation changes will be made as deemed necessary.
Fee Discretion
Weaver Consulting Group may, in its sole discretion, negotiate to charge a lesser fee based upon certain
criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of
assets to be managed, related accounts, account composition, pre-existing/legacy client relationship,
account retention and pro bono activities.
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Disclosure Brochure
Weaver Consulting Group, LLC
Additional Fees and Expenses
In addition to the advisory fees paid to Weaver Consulting Group, clients may also incur certain charges
imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other
financial institutions (collectively “Financial Institutions”). These additional charges may include securities
brokerage commissions, transaction fees, custodial fees, margin costs, charges imposed directly by a mutual
fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and
other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s
brokerage practices are described at length in Item 12, below.
Direct Fee Debit
Clients generally provide Weaver Consulting Group with the authority to directly debit their accounts for
payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for
client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send
statements to clients not less than quarterly detailing all account transactions, including any amounts paid
to Weaver Consulting Group.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to Weaver
Consulting Group’ right to terminate an account. Additions may be in cash or securities provided that the
Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into
a client’s account. Clients may withdraw account assets on notice to Weaver Consulting Group, subject to
the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios
as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment
objectives. Weaver Consulting Group may consult with its clients about the options and implications of
transferring securities. Clients are advised that when transferred securities are liquidated, they may be
subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g.,
contingent deferred sales charges) and/or tax ramifications.
Use of Margin
Weaver Consulting Group does not recommend the use of leverage in accounts, but may recommend
margin on accounts where clients have borrowing needs. In these cases the fee payable to the Firm will be
assessed on the assets managed by the Firm (gross of margin).
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Disclosure Brochure
Weaver Consulting Group, LLC
Commissions and Sales Charges for Recommendations of Securities
Clients can engage certain persons associated with Weaver Consulting Group (but not the Firm directly) to
render securities brokerage services under a separate commission-based arrangement. Clients are under no
obligation to engage such persons and may choose brokers or agents not affiliated with Weaver Consulting
Group.
Under this arrangement, the Firm’s Supervised Persons, in their individual capacities as registered
representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), may provide securities brokerage
services and implement securities transactions under a separate commission based arrangement. Supervised
Persons may be entitled to a portion of the brokerage commissions paid to PKS, as well as a share of any
ongoing distribution or service (trail) fees from the sale of mutual funds. Weaver Consulting Group may
also recommend no-load or load-waived funds, where no sales charges are assessed. Prior to effecting any
transactions, clients are required to enter into a separate account agreement with PKS.
A conflict of interest exists to the extent that Weaver Consulting Group recommends the purchase or sale
of securities where its Supervised Persons receive commissions or other additional compensation as a result
of the Firm’s recommendation. The Firm has procedures in place to ensure that any recommendations made
by such Supervised Persons are in the best interest of clients. For certain accounts covered by the Employee
Retirement Income Security Act of 1974 (“ERISA”) and such others that Weaver Consulting Group, in its
sole discretion, deems appropriate, Weaver Consulting Group may provide its investment advisory services
on a fee-offset basis. In this scenario, Weaver Consulting Group may offset its fees by an amount equal to
the aggregate commissions and 12b-1 fees earned by the Firm’s Supervised Persons in their individual
capacities as registered representatives of PKS.
Item 6. Performance-Based Fees and Side-by-Side Management
Weaver Consulting Group does not provide any services for a performance-based fee (i.e., a fee based on
a share of capital gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
Weaver Consulting Group offers services to individuals, pension and profit sharing plans, trusts, estates,
charitable organizations, corporations and business entities.
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Weaver Consulting Group, LLC
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
Weaver Consulting Group takes a holistic approach to asset allocation, employing an asset allocation
strategy that builds a portfolio that fits the individual needs of its clients. The first step in the Firm’s
investment strategy is getting to know the client - to understand their dreams, goals and create a complete
picture of their financial situation. This comprehensive approach to discovery and assessment is integral to
the way the Firm does business. Only when the Firm has a true understanding of a client’s needs and goals
can the investment process begin. Building on that foundation, the Firm recommends strategies and
investments that it believes are in alignment with client’s goals while managing risk.
Weaver Consulting Group is focused on delivering attractive risk-adjusted returns for its clients. The Firm
seeks to accomplish this through a combination of fundamental and quantitative analysis of countries, asset
classes, money managers and issuers. Fundamental analysis involves an evaluation of the financial
condition and competitive position of a particular country, asset class, fund or issuer. Quantitative analysis
involves analyzing historical performance of issuers based on certain criteria including beta, value,
momentum, yield and quality. This screening is designed to build portfolios of securities which possess
those positive traits that have historically delivered attractive risk-adjusted returns.
Risk of Loss
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of Weaver Consulting Group’ recommendations
and/or investment decisions may depend to a great extent upon correctly assessing the future course of price
movements of stocks, bonds and other asset classes. There can be no assurance that Weaver Consulting
Group will be able to predict those price movements accurately or capitalize on any such assumptions.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for
a profit that cannot be offset by a corresponding loss.
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Disclosure Brochure
Weaver Consulting Group, LLC
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily
per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption
fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a
mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may,
among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least
once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However,
certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There
is also no guarantee that an active secondary market for such shares will develop or continue to exist.
Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more).
Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may
have no way to dispose of such shares.
Use of Leveraged Mutual Funds and ETFs
The Firm may invest in mutual funds that use leverage (borrowing funds to invest). While the use of
leverage can substantially improve returns, it may also increase overall portfolio risk.
Interval funds
Interval funds are a type of closed-end fund that allow withdrawals only at set times, usually once a
quarter. The fund may also impose limits on how much may be withdrawn during a quarter. Interval
funds will usually invest in high-yielding and low-liquidity type investments that may not be found in
normal mutual funds. This carries additional liquidity and valuation risk.
Options
Options are contracts to purchase a security at a given price, risking that an option may expire out of the
money resulting in minimal or no value. An uncovered option is a type of options contract that is not
backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is
not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions
entail buying and selling multiple options on the same underlying security, but with different strike prices
or expiration dates, which helps limit the risk of other option trading strategies. Option writing also
involves risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk,
political/regulatory risk, inflation (purchasing power) risk and interest rate risk.
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Item 9. Disciplinary Information
Weaver Consulting Group has not been involved in any legal or disciplinary events that are material to a
client’s evaluation of its advisory business or the integrity of its management.
Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations.
Registered Representatives of a Broker/Dealer
Certain of the Firm’s Supervised Persons are registered representatives of PKS and may provide clients
with securities brokerage services under a separate commission-based arrangement. This arrangement is
described at length in Item 5.
Licensed Insurance Agents
A number of the Firm’s Supervised Persons are licensed insurance agents and may offer certain insurance
products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that Weaver
Consulting Group recommends the purchase of insurance products where its Supervised Persons may be
entitled to insurance commissions or other additional compensation. The Firm has procedures in place
whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any
such affiliations.
Item 11. Code of Ethics
Weaver Consulting Group has adopted a code of ethics in compliance with applicable securities laws
(“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Weaver
Consulting Group’ Code of Ethics contains written policies reasonably designed to prevent certain unlawful
practices such as the use of material non-public information by the Firm or any of its Supervised Persons
and the trading by the same of securities ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of Weaver Consulting Group’ personnel to report their personal
securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public
offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities
that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s
policies and procedures. This Code of Ethics has been established recognizing that some securities trade in
sufficiently broad markets to permit transactions by certain personnel to be completed without any
appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions
may be made to the policies stated below.
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Weaver Consulting Group, LLC
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person with access to this information may knowingly effect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that
security unless:
•
the transaction has been completed;
•
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
•
a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii)
money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit
investment trusts that are invested exclusively in one or more mutual funds.
Clients and prospective clients may contact Weaver Consulting Group to request a copy of its Code of
Ethics.
Weaver Consulting Group and its associated persons may have material financial interests in issuers of
securities that Weaver Consulting Group may recommend for purchase or sale by clients. For example,
TrueMark Investments and TrueShares.
This presents a conflict of interest in that Weaver Consulting Group or its related persons may receive
more compensation from investment in a security in which in which Weaver Consulting Group or a
related person has a material financial interest than from other investments. Weaver Consulting Group
always acts in the best interest of the client consistent with its fiduciary duties and clients are not required
to invest in such investments if they do not wish to do so.
Item 12. Brokerage Practices
Recommendation of Broker/Dealers for Client Transactions
Weaver Consulting Group generally recommends that clients utilize the custody, brokerage and clearing
services of Fidelity Institutional Wealth Services (“Fidelity”) for investment management accounts. The
final decision to custody assets with Fidelity is at the discretion of the client, 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. Weaver Consulting Group is independently owned and operated and not affiliated with
Fidelity. Fidelity provides Weaver Consulting Group with access to its institutional trading and custody
services, which are typically not available to retail investors.
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Weaver Consulting Group, LLC
Factors which Weaver Consulting Group considers in recommending Fidelity or any other broker-dealer to
clients include their respective financial strength, reputation, execution, pricing, research and service.
Fidelity may enable the Firm to obtain many mutual funds without transaction charges and other securities
at nominal transaction charges. The commissions and/or transaction fees charged by Fidelity may be higher
or lower than those charged by other Financial Institutions.
The commissions paid by Weaver Consulting Group’ clients to Fidelity comply with the Firm’s duty to
obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial
Institution might charge to effect the same transaction where Weaver Consulting Group determines that the
commissions are reasonable in relation to the value of the brokerage and research services received. In
seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s
services, including among others, the value of research provided, execution capability, commission rates
and responsiveness. Weaver Consulting Group seeks competitive rates but may not necessarily obtain the
lowest possible commission rates for client transactions.
Consistent with obtaining best execution, brokerage transactions may be directed to certain broker/dealers
in return for investment research products and/or services which assist Weaver Consulting Group in its
investment decision-making process. Such research generally will be used to service all of the Firm’s
clients, but brokerage commissions paid by one client may be used to pay for research that is not used in
managing that client’s portfolio. The receipt of investment research products and/or services as well as the
allocation of the benefit of such investment research products and/or services poses a conflict of interest
because Weaver Consulting Group does not have to produce or pay for the products or services.
Weaver Consulting Group periodically and systematically reviews its policies and procedures regarding its
recommendation of Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
Weaver Consulting Group may receive without cost from Fidelity computer software and related systems
support, which allow Weaver Consulting Group to better monitor client accounts maintained at Fidelity.
Weaver Consulting Group may receive the software and related support without cost because the Firm
renders investment management services to clients that maintain assets at Fidelity. The software and support
is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The software
and related systems support may benefit Weaver Consulting Group, but not its clients directly. In fulfilling
its duties to its clients, Weaver Consulting Group endeavors at all times to put the interests of its clients
first. Clients should be aware, however, that Weaver Consulting Group’ receipt of economic benefits from
a broker/dealer creates a conflict of interest since these benefits may influence the Firm’s choice of
broker/dealer over another that does not furnish similar software, systems support or services.
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Specifically, Weaver Consulting Group may receive the following benefits from Fidelity:
• Funds to be used toward qualifying third-party service providers for research, marketing,
compliance, technology and software platforms and services;
• Receipt of duplicate client confirmations and bundled duplicate statements;
• Access to a trading desk that exclusively services its institutional traders;
• Access to block trading which provides the ability to aggregate securities transactions and then
allocate the appropriate shares to client accounts; and
• Access to an electronic communication network for client order entry and account information.
Brokerage for Client Referrals
Weaver Consulting Group does not consider, in selecting or recommending broker/dealers, whether the
Firm receives client referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct Weaver Consulting Group in writing to use a particular Financial Institution to execute
some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the
account with that Financial Institution and the Firm will not seek better execution services or prices from
other Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by Weaver Consulting Group (as described above). As
a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive
less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its
duty of best execution, Weaver Consulting Group may decline a client’s request to direct brokerage if, in
the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational
difficulties.
Commissions or Sales Charges for Recommendations of Securities
As discussed above, certain Supervised Persons in their respective individual capacities are registered
representatives of PKS. These Supervised Persons are subject to FINRA Rule 3040 which restricts
registered representatives from conducting securities transactions away from their broker-dealer unless PKS
provides written consent. Therefore, clients are advised that certain Supervised Persons may be restricted
to conducting securities transactions through PKS if they have not secured written consent from PKS to
execute securities transactions though a different broker-dealer. Absent such written consent or separation
from PKS, these Supervised Persons are prohibited from executing securities transactions through any
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broker-dealer other than PKS under its internal supervisory policies. The Firm is cognizant of its duty to
obtain best execution and has implemented policies and procedures reasonably designed in such pursuit.
Trade Aggregation
Transactions for each client generally will be effected independently, unless Weaver Consulting Group
decides to purchase or sell the same securities for several clients at approximately the same time. Weaver
Consulting Group may (but is not obligated to) combine or “batch” such orders to obtain best execution, to
negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in
prices and commissions or other transaction costs that might not have been obtained had such orders been
placed independently. Under this procedure, transactions will generally be averaged as to price and
allocated among Weaver Consulting Group’ clients pro rata to the purchase and sale orders placed for each
client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase
or sale of securities, including securities in which Weaver Consulting Group’ Supervised Persons may
invest, the Firm generally does so in accordance with applicable rules promulgated under the Advisers Act
and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Weaver
Consulting Group does not receive any additional compensation or remuneration as a result of the
aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when
only a small percentage of the order is executed, shares may be allocated to the account with the smallest
order or the smallest position or to an account that is out of line with respect to security or sector weightings
relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one
account has limitations in its investment guidelines which prohibit it from purchasing other securities which
are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account
reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to
other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv)
with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro
rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the
Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis
among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all
accounts, shares may be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
Account Reviews
Weaver Consulting Group monitors client portfolios on a continuous and ongoing basis while regular
account reviews are conducted on at least a quarterly basis. Such reviews are conducted by the Firm’s
investment adviser representatives. All investment advisory clients are encouraged to discuss their needs,
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Weaver Consulting Group, LLC
goals and objectives with Weaver Consulting Group and to keep the Firm informed of any changes thereto.
The Firm contacts ongoing investment advisory clients at least annually to review its previous services
and/or recommendations and to discuss the impact resulting from any changes in the client’s financial
situation and/or investment objectives.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements directly
from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise
requested, clients may also receive written or electronic reports from Weaver Consulting Group and/or an
outside service provider, which contain certain account and/or market-related information, such as an
inventory of account holdings or account performance. Clients should compare the account statements they
receive from their custodian with any documents or reports they receive from Weaver Consulting Group or
an outside service provider.
Item 14. Client Referrals and Other Compensation
Client Referrals
The Firm does not currently provide compensation to any third-party solicitors for client referrals.
The firm may host or attend mutual fund company or other company educational programs, events, or conferences
where expenses are paid for by the fund company or other third parties whose products and services FIRM may
utilize while managing client accounts. This represents a conflict of interest to use and promote their products and
services.
Item 15. Custody
The Advisory Agreement and/or the separate agreement with any Financial Institution generally authorize
Weaver Consulting Group to debit client accounts for payment of the Firm’s fees and to directly remit that
those funds to the Firm in accordance with applicable custody rules. The Financial Institutions that act as
the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees,
have agreed to send statements to clients not less than quarterly detailing all account transactions, including
any amounts paid to Weaver Consulting Group.
In addition, as discussed in Item 13, Weaver Consulting Group may also send periodic supplemental reports
to clients. Clients should carefully review the statements sent directly by the Financial Institutions and
compare them to those received from Weaver Consulting Group.
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Custody is also disclosed in Form ADV because Weaver Consulting Group has authority to transfer money
from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, Weaver
Consulting Group will follow the safeguards specified by the SEC rather than undergo an annual audit.
1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature,
the third party’s name, and either the third party’s address or the third party’s account number at a
custodian to which the transfer should be directed.
2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or from time to time.
3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature
review or other method to verify the client’s authorization and provides a transfer of funds notice to the
client promptly after each transfer.
4. The client has the ability to terminate or change the instruction to the client’s qualified custodian.
5. The investment adviser has no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party contained in the client’s instruction.
6. The investment adviser maintains records showing that the third party is not a related party of the
investment adviser or located at the same address as the investment adviser.
7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and
an annual notice reconfirming the instruction.
Item 16. Investment Discretion
Weaver Consulting Group may be given the authority to exercise discretion on behalf of clients. Weaver
Consulting Group is considered to exercise investment discretion over a client’s account if it can effect
and/or direct transactions in client accounts without first seeking their consent. Weaver Consulting Group
is given this authority through a power-of-attorney included in the agreement between Weaver Consulting
Group and the client. Clients may request a limitation on this authority (such as certain securities not to be
bought or sold). Weaver Consulting Group takes discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold; and
• When transactions are made.
Item 17. Voting Client Securities
Declination of Proxy Voting Authority
Weaver Consulting Group generally does not accept the authority to vote a client’s securities (i.e., proxies)
on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are
custodied and may contact the Firm at the contact information on the cover of this brochure with questions
about any such issuer solicitations.
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Item 18. Financial Information
Weaver Consulting Group is not required to disclose any financial information due to the following:
• The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more
in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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