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11 SE 2ND ST.
LEE’S SUMMIT, MO 64063
(816) 246-9473
www.wisewealth.com
stephen@wisewealth.com
FORM ADV PART 2A
FIRM BROCHURE
AUGUST 20, 2025
This Brochure provides information about the qualifications and business practices of Wise
Wealth, LLC [“ADVISER”]. If you have any questions about the contents of this Brochure, please
contact us at 816-246-9473 or at info@wisewealth.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.
Wise Wealth, LLC is a registered investment adviser. Registration of an Investment Adviser
does not imply any level of skill or training. The oral and written communications of an Adviser
provide you with information about which you determine to hire or retain an Adviser.
Additional information about Wise Wealth, LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a
CRD number. The CRD number for Wise Wealth, LLC is 143421.
ITEM 2 - MATERIAL CHANGES
We do not have any material changes to report since our last annual update to this firm
brochure, which was filed on March 5, 2025.
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ITEM 3 – TABLE OF CONTENTS
Item 1 – Cover Page ………………………………………………………………………………………………………………………………. 1
ITEM 2 - MATERIAL CHANGES .............................................................................................................................. 2
ITEM 3 – TABLE OF CONTENTS ............................................................................................................................. 3
ITEM 4 – ADVISORY BUSINESS .............................................................................................................................. 4
ITEM 5 – FEES AND COMPENSATION ..................................................................................................................... 5
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT ..................................................................... 7
ITEM 7 – TYPES OF CLIENTS ................................................................................................................................. 7
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................................ 7
ITEM 9 – DISCIPLINARY INFORMATION ................................................................................................................. 10
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ...................................................................... 11
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTION AND PERSONAL TRADING .................. 11
ITEM 12 – BROKERAGE PRACTICES ...................................................................................................................... 12
ITEM 13 – REVIEW OF ACCOUNTS ...................................................................................................................... 13
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................................... 14
ITEM 15 – CUSTODY ........................................................................................................................................ 14
ITEM 16 – INVESTMENT DISCRETION ................................................................................................................... 15
ITEM 17 – VOTING CLIENT SECURITIES ................................................................................................................ 15
ITEM 18 – FINANCIAL INFORMATION ................................................................................................................... 15
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ITEM 4 – ADVISORY BUSINESS
OWNERSHIP/ADVISORY HISTORY
Wise Wealth, LLC (“we” or the “firm”) has been a Missouri registered investment adviser since
June 2007 and a Kansas registered investment adviser since 2011. We were subsequently
registered with the Securities and Exchange Commission on July 6, 2018. We are owned and
managed by Stephen Stricklin. Additional information about Mr. Stricklin can be found in Item
19 and his supplemental brochure, ADV Part 2B.
ADVISORY SERVICES OFFERED
Before we enter an Adviser-Client relationship, we may offer a complimentary general
consultation to discuss services available, give a prospective client time to review services
desired, and determine whether a relationship might benefit the client. Investment advisory
services begin only after we and the client formalize the relationship with a properly executed
agreement. We offer the following services to our clients:
PORTFOLIO MANAGEMENT SERVICES
We manage individualized portfolios for our clients. We work with each client to formulate an
individualized portfolio based upon his/her objectives, time frame, risk parameters and other
investment considerations. We use marketable securities that may include, but not limited to,
exchange traded funds (ETFs), mutual funds, bonds, common stock (equities), and treasury
bonds. (Additional information about securities used and their risks can be found under Item
8.) Our investment philosophy is to use principles of value, safety and quality to seek
investment options globally. We place heavy emphasis on risk control, believing that avoiding
losses allows appreciation potential of equities to be realized.
We utilize the services of a Sub-Advisor to manage client’s assets on a discretionary basis and in
accordance with the client’s stated investment objectives. In these situations, we offer
consulting and advisory services in overseeing such Sub-Advisors. We make recommendations
regarding the use of a Sub-Advisor and its investment style based on, but not limited to, the
client’s financial needs, long-term goals, and investment objectives.
Sub-Advisors selected by us offer multiple strategies. Once a Sub-Advisor is selected, we
continue to monitor the chosen firm to ensure that it adheres to the philosophy and
investment style for which it was selected and to ensure that its performance, portfolio
strategies, and management remain aligned with the client’s overall investment goals and
objectives. We will retain discretionary authority to hire and fire Sub-Advisors and reallocate
the client’s assets to other Sub-Advisors, where such action is deemed to be in the best interest
of the client. Our ongoing review includes, but is not limited to, assessment of the Sub-
Advisor’s disclosure brochure, performance information, materials, personnel turnover, and
regulatory events.
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FINANCIAL PLANNING
On occasion, we offer financial planning services, separate from our portfolio management
services, that involve a review of your financial situation, goals and risk tolerance. We will focus
on a single topic or multiple topics as identified in our meetings with the client. Typically, we
meet with the client to discuss questions, conduct research on the chosen topics and present
the findings to them through a second meeting. Upon delivery of the recommendation, the
engagement is concluded.
TAILORED SERVICES
Our financial planning and portfolio management services are individualized to each client. A
client may impose restrictions on investment in certain securities or types of securities. Any
restrictions must be provided in writing.
WRAP PROGRAM
We do not sponsor a wrap program. This section is not applicable.
CLIENT ASSETS MANAGED
As of February 2025, we manage $304,176,037 in client assets on a discretionary basis.
ITEM 5 – FEES AND COMPENSATION
PORTFOLIO MANAGEMENT SERVICES
We charge an annual management fee based on a percentage of assets under management in
the client’s account as reported by its custodian. The management fee schedule is as follows:
Account Value
Up to $500,000
$500,001 to $1,000,000
$1,000,001 to $2,000,000
$2,000,001 to $3,000,000
$3,000,001 to $4,000,000
$4,000,001 to $5,000,000
$5,000,000 +
Investment Management Fee
up to 1.35%
up to 1.25%
up to 1.15%
up to 1.00%
up to 0.85%
up to 0.75%
Up to 0.50%
The management fee is calculated monthly as of the last business day of the month and
collected on a quarterly basis in arrears. The initial quarter’s management fee will be prorated
for the amount of time services were rendered. The fee is tiered which means the applicable
rate will be applied to the fair market value in each applicable range of account value. For
example, an account with a quarter-end value of $1,000,000 will be charged at a rate of 1.35%
for the first $500,000 and 1.25% for the remaining $500,000. Notwithstanding the Account’s
fair market value, the minimum annual fee table is stated in the client’s Investment
Management Agreement and may be negotiated.
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Our management fee includes the Sub-Advisor’s management fee. The maximum Sub-Advisor
management fee is 0.75%.
Additionally, our management fees do not include brokerage commissions, transaction fees,
and other related costs and expenses that are incurred by the client. Clients may incur certain
charges imposed by custodians, brokers, third party investment and other third parties such as
fees charged by managers, custodial fees, 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. Mutual funds and exchange traded funds also charge internal
management fees, which are disclosed in a fund’s prospectus. Such charges, fees and
commissions are exclusive of and in addition to our fee and it will not receive any portion of
these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker-
dealers for client transactions and determining the reasonableness of their compensation (e.g.,
fees).
The specific way our management fees are charged is established in a client’s written
agreement. Clients may also elect to be billed directly for fees or to authorize us to directly
debit fees from client accounts. Management fees shall be prorated for each capital
contribution and withdrawal made during the applicable calendar quarter (with the exception
of de minimis contributions and withdrawals).
FINANCIAL PLANNING SERVICES
Our financial planning services are offered at an hourly rate of $100. At the beginning of
engagement, we will provide you with a written estimate of the number of hours we believe
the service will take. However, we will track the time we spend collecting your information,
analyzing and researching the chosen topics, and the time presenting the findings to you. The
first half of the estimated fee will be due upon engagement with the remainder due at the
delivery of the recommendation. Clients may not be charged a financial planning fee if you
engage in our portfolio management services.
TERMINATION OF SERVICES
A client may terminate the Investment Management Agreement and/or financial counseling
services for any reason at any time and, within the first five (5) business days after signing the
contract, without any cost or penalty. Thereafter, the Agreement may be terminated at any
time by giving ten (10) days written notice. Upon termination, when management fees are
charged in advance, the management fees will be prorated for the number of days that services
were rendered during the termination quarter, and all unearned fees will be refunded to the
client. For financial consulting fees paid in advance, fees will be prorated for the number of
hours worked.
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OTHER SECURITIES COMPENSATION
We have no other securities compensation to report.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT
We do not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client) or provide side by side management.
ITEM 7 – TYPES OF CLIENTS
We provide portfolio management services to individuals, but we also offer all services to high
net worth individuals, corporate pension and profit-sharing plans, Taft-Hartley plans, charitable
institutions, foundations, endowments, municipalities, registered mutual funds, private
investment funds, trust programs, sovereign funds, foreign funds such as UCITs and SICAVs, and
other U.S. and international institutions.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
We provide a variety of investment strategies designed for a wide range of investors with
diverse wealth management objectives. We utilize the services of a subadvisor for the portfolio
management services that we offer to clients. The typical structure of our portfolio offerings is
an approach where we research and manage ETFs and mutual fund holdings, but our strategies
may also include individual securities. On an ongoing basis, our Investment Team undertakes an
extensive research process that re-evaluates the asset class selection, asset allocation, holding
selection, and portfolio rebalancing needs for each investment strategy.
Asset Class Selection –Properly defining and selecting the individual asset classes that are
consistent with the objectives of each strategy.
Asset Allocation – Implementing and adapting the asset class weightings as a result of each
strategy’s investment research and forecasting processes.
Holding Selection – Selecting, monitoring, and replacing the specific holdings based on a
disciplined process directed by the objective of each strategy.
Portfolio Rebalancing – Crafting and deploying an appropriate rebalancing approach based on
the intent of each strategy.
INVESTMENT RISKS
Selection of Other Advisers – Although we seek to select only those subadvisors who will invest
your assets with the highest level of integrity, our selection process cannot ensure that the
selected subadvisor will have positive performance or outperform a particular benchmark. We
do not have control over the day-to-day operations of the subadvisor.
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Asset Class Allocation - The rise and fall of certain asset classes or their underlying securities or
commodities may not react according to predicted trends.
Active Management - This process concentrates on factors that are believed to lead to the
quality and future success of particular money managers. The risk assumed is that the manager
will fail to perform as expected.
Portfolio Rebalancing - Depending on the rebalancing strategy implemented, long-term or
short-term trading may be involved. Trading can affect investment performance, particularly
through increased brokerage and other transaction costs and taxes. Short-term trading
generally holds greater risk, and you should be aware that there is a material risk of loss using
short-term strategies.
Timing Risk - While it is likely that stocks will gain over the next two decades, this may not be
the case in the short-term. If you need to protect your principal investment in the short-term,
timing is an important risk to consider.
Political Risk - Government decisions may damage the value of your investments. Changes to
social security, benefits law, and tax law may impact your financial decisions. Any foreign
investments may be impacted by the decision of their local governments.
Foreign Risk – Foreign investments have additional risks relative to domestic investments. This
includes currency fluctuations, differences in accounting standards, different market exchanges,
potentially less liquidity, etc.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
Investing in securities such as ETFs and mutual funds involves risk. Seeking to obtain higher
rates of return on investments typically entails accepting higher levels of risk. We or your
investment adviser will work with you to identify the balance of risks and rewards that is
appropriate and comfortable for you. However, it is still your responsibility to ask questions if
you do not fully understand the risks associated with any investment or investment strategy.
Also, while we strive to render our best judgment on your behalf, many economic and market
variables beyond our control can affect the performance of your investments and we cannot
assure that your investments will be profitable, or no losses will occur in your investment
portfolio.
Past performance is one consideration with respect to any investment or investment adviser, but
it is not a predictor of future performance.
We or your investment adviser will discuss with you the investment risks of ETFs and mutual
funds to determine the investment objectives that will guide your portfolio selection. We will
explain and answer any questions you have about these kinds of investments, which present
special considerations.
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ETFs are a type of security that derive their value from a basket of securities such as stocks,
bonds, commodities or indices and are traded on exchanges during the day like individual
stocks. Conversely, traditional mutual funds are priced once a day at the close of the market.
The value of your portfolio will fluctuate with the value of its underlying securities. ETFs trade
like a stock, and there may be brokerage commissions associated with buying and selling.
We primarily invest in passively managed funds which are designed to seek the investment
results that generally correspond to the price and yield of an index, however; we may invest in
actively managed ETFs and mutual funds. ETFs that are actively managed do not just seek to
passively track an index; instead, they seek to achieve a specified investment objective using an
active investment strategy.
Equity-based ETFs have a similar risk profile to those of equity mutual funds, while fixed
income-based ETFs have a risk profile similar to bond mutual funds. You should anticipate that
the value of an ETF’s shares will decline, in correlation with any decline in the value of its
corresponding index. However, an ETF’s return may not match the return of the index.
Sometimes referred to as “tracking error,” expenses and other factors may affect the
performance of an ETF so that the ETF’s performance does not exactly match the performance
of their respective underlying indexes. The ETF may invest in small capitalization, mid-
capitalization, emerging markets and international companies. These companies may
experience greater price volatility than larger, more established companies.
Exchange-traded notes (ETNs) are issued as senior, unsecured, unsubordinated debt obligations
of an underlying bank or other financial institution. They are linked to the performance of an
index, underlying security, or commodity. ETNs trade on an exchange and are like ETFs in that
regard. However, unlike ETFs, ETNs carry credit risk related to the issuer’s ability to pay back
the note. While the performance of these securities is linked to the performance of an
underlying index, security, or commodity, an investor does not own any underlying assets
(which is the case with ETFs). It is, however, relying on the financial institution issuer’s promise
to make good on the terms of the ETN. This means that the market value of ETNs can be
adversely affected by downgrades in the creditworthiness to the underlying issuing financial
institution. In the extreme case that the issuer of the ETN goes bankrupt, you may lose your
entire investment because ETNs are unsecured debt instruments. In contrast, if an ETF were to
suffer bankruptcy or close, you would usually receive cash for the market value of the basket of
securities or, in the case of larger positions of $50,000 or more, you may request to take
distribution of the underlying securities.
Commodities may provide protection against inflation and/or the inability of fiat currencies to
maintain their store of real value. Commodities may provide imperfect correlations relative to
other asset classes and serve to increase diversification for risk-tolerant portfolios. It is also
important to understand that commodity ETFs can be significantly affected by commodity
prices, world events, import controls, worldwide competition, government regulations, and
economic conditions.
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We also provide what we believe are the primary risks for you to review as listed below.
Market Risk. ETFs are largely influenced by the value of the indices they track. As the
index value changes in response to news and general economic conditions of domestic,
international and commodity/natural resource markets, in general, so will the value of
the ETF. This can result in a loss of your initial investment.
International Investment Risk. International investments may involve risk of capital loss
from unfavorable fluctuations in currency exchange rates, differences in generally
accepted accounting principles, or economic and political instability in other nations.
Emerging Markets Risk. Investments in emerging markets may be subject to a greater
risk of loss than investments in more developed markets. Emerging markets may be
more likely to experience inflation risk, political turmoil and rapid changes in economic
conditions than more developed markets. Emerging markets often have less consistency
in accounting and reporting requirements, unreliable securities valuation and greater
risk associated with custody of securities.
Income Risk. An ETF’s income may decline when interest rates fall. This decline can
occur because: (1) the ETF must invest in lower-yielding bonds as bonds in its portfolio
mature, (2) bonds in the underlying index are substituted, or (3) the ETF otherwise
needs to purchase additional bonds.
Interest-Rate Risk. Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
Liquidity Risk. Markets can also experience a decline in liquidity which can negatively
impact ETF prices and increase the difficulty of selling a position. The ability to purchase
or sell large positions of ETF securities, due to possible low trade volume, may take time
(i.e. days).
Sector-Specific Risk. The value of investments that are concentrated in industry-specific
sectors have additional risks relative to broad market investments. These investments
may decline due to changes in the specific industry, such as government regulation or
consumer trends.
ITEM 9 – DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of us or the integrity of our
management. We have no information applicable to this Item.
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ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
BROKER DEALER AFFILIATION
We are not affiliated with a broker-dealer.
FUTURES/COMMODITIES FIRM AFFILIATION
We are not affiliated with a futures or commodities broker.
OTHER INDUSTRY AFFILIATIONS
Our investment advisers are also independent licensed insurance agents with various insurance
companies and may sell insurance to the firm’s clients. This causes a conflict of interest
because they receive a commission that is separate from the investment management fees
outlined in Item 5 of this brochure, ADV Part 2A. We attempt to mitigate this conflict of
interest to the best of our ability by placing the client’s interests ahead of our own through our
fiduciary duty. Additionally, it is our policy that recommended insurance purchases do not have
to be purchased through us or any affiliate.
Our owner, Mr. Stricklin, is co-owner of Bright Portfolios LLC, a registered investment advisor
and subadvisor. Mr. Stricklin does not recommend our services to Bright Portfolios, LLC’s
clients. However, Bright Portfolios, LLC acts as a subadvisor to some of our client portfolios.
This creates a financial incentive for Mr. Stricklin to recommend Bright Portfolios, LLC portfolios
to our clients because he receives a portion of their fee. In order to mitigate any conflicts of
interest, Mr. Stricklin places the client’s interests ahead of his own, through his fiduciary duty,
and clients are never obligated to use Bright Portfolios, LLC’s sub-advisory services.
Mr. Stricklin also owns Wise Wealth Tax Planning, LLC. Although he does not engage in tax
planning services, as an owner he has a financial incentive to recommend clients to Wise
Wealth Tax Planning, LLC. Mr. Stricklin attempts to mitigate these conflicts of interest to the
best of his ability by placing the client’s interests ahead of his own and through his fiduciary
duty. Additionally, recommended tax planning services do not have to be purchased through
Mr. Stricklin, any affiliate, or agency.
RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISER
We utilize the services of a Sub-Advisor to manage some or all of a client’s assets on a
discretionary basis and in accordance with the client’s stated investment objectives. A detailed
description of these services can be found under Item 4 and Item 5.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTION AND PERSONAL
TRADING
DESCRIPTION
We have adopted a Code of Ethics for all supervised persons of the firm describing its high
standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes
provisions relating to the confidentiality of client information, a prohibition on insider trading, a
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prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the
reporting of certain gifts and business entertainment items, and personal securities trading
procedures, among other things. All of our supervised persons must acknowledge the terms of
the Code of Ethics annually, or as amended.
MATERIAL INTEREST IN SECURITIES
We do not have a material interest in any securities.
INVESTING IN OR RECOMMENDING THE SAME SECURITIES
We anticipate that, in appropriate circumstances, consistent with clients’ investment
objectives, it will cause accounts over which we have management authority to effect and will
recommend to investment advisory clients or prospective clients, the purchase or sale of
securities in which we, our affiliates and/or clients, directly or indirectly, have a position of
interest. Our employees and associated persons are required to follow our Code of Ethics.
Subject to satisfying this policy and applicable laws, officers, directors and employees and our
affiliates may trade for their own accounts in securities which are recommended to and/or
purchased for clients. The Code of Ethics is designed to assure that the personal securities
transactions, activities and interests of the employees will not interfere with (i) making
decisions in the best interest of advisory clients and (ii) implementing such decisions while, at
the same time, allowing employees to invest for their own accounts. Nonetheless, because the
Code of Ethics in some circumstances would permit employees to invest in the same securities
as clients, there is a possibility that employees might benefit from market activity by a client in
a security held by an employee. Employee trading is continually monitored under the Code of
Ethics, and to reasonably prevent conflicts of interest between us and our clients.
Our clients or prospective clients may request a copy of the firm's Code of Ethics by contacting
Stephen Stricklin, President.
ITEM 12 – BROKERAGE PRACTICES
RECOMMENDATION CRITERIA
Some of the primary considerations in determining reasonableness of commissions and related
brokerage services are: rates charged by other brokers that provide clearing or custody services
for registered investment advisers; reputation and financial strength; breadth and depth of
available products, with an important factor being the broker’s no-transaction-fee mutual fund
universe; accuracy with which transactions are processed; customer service responsiveness;
availability of technology solutions interoperable with our systems and suitable for managing
multiple accounts; as well as client satisfaction. We periodically evaluate the foregoing factors,
and while it may conclude based on its review that commission rates paid by clients are
reasonable, lower commissions may be available from other brokers or in conjunction with
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retail (non-advisory) accounts, and certain mutual funds that carry a transaction fee may be
available on a no-transaction-fee basis from other brokers or directly from the fund company.
RESEARCH AND SOFT DOLLARS
“Soft dollars” are defined as a form of payment investment firms can use to pay for goods and
services such as news subscriptions or research. When an investment firm gives its business to
a particular brokerage firm, the brokerage firm in return can agree to use some of its revenue
to pay for these types of services. In order to stem the potential conflicts of interest that may
arise from “soft dollar” arrangements, we pursue a policy of not entering into any such
arrangements, either orally or in writing. Should we enter into a “soft dollar” arrangement, it
shall be only to the extent that it complies with the “safe harbor” requirements of Section 28(e)
of the Securities Exchange Act of 1934 and any then-current federal and state regulations. Also,
upon entering into any such arrangements, we will immediate update this ADV Part 2A.
BROKERAGE FOR CLIENT REFERRALS
We do not receive client referrals or any other incentive from any broker-dealer or custodian.
DIRECTED BROKERAGE
Some clients may direct us to a specific broker-dealer to execute securities transactions for their
accounts. When so directed, we may not be able to effectively negotiate lower brokerage
commissions or achieve best execution on those clients’ transactions. This can result in
substantially higher fees, charges or dealer concessions in one or more transactions for the
clients’ accounts because we cannot negotiate favorable prices.
TRADE AGGREGATION
When buying or selling the same security for multiple client accounts at the same time, we may
“block” or group the trades together. As a result, each client will receive the average price
obtained on the entire block, which may be more advantageous compared to that which would
have been obtained on separate smaller orders.
When blocking orders, we will first determine the number of shares of a given security to be
traded for each client account. Next, we will enter an order for the total number of shares to be
traded as a block. After the order is filled, we will provide instructions to the custodian to
allocate the trade among individual client accounts per calculations performed in the first step.
In the event an order is only partially filled or pro-rata allocation would negatively affect a
client, we will instruct the custodian in an alternative allocation of the trade.
ITEM 13 – REVIEW OF ACCOUNTS
PERIODIC REVIEWS
Our investment adviser representatives monitor the subadvisor portfolios on a daily basis. We
will also meet with clients as needed to conduct a review of their financial situation and provide
updates if necessary.
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OTHER REVIEWS
Additional reviews are conducted periodically depending on market conditions, economic or
political events, or by changes in a client’s financial situation (such as retirement, termination of
employment, physical move or inheritance).
REPORTS
Clients will receive at least quarterly statements from their custodian.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
OTHER COMPENSATION
We do not receive extra compensation or any other economic benefit for providing investment
advice or other advisory services to clients.
CLIENT REFERRALS
We do not pay for client referrals or use solicitors.
ITEM 15 – CUSTODY
Custody, as it applies to investment advisors, has been defined by regulators as having access or
control over client funds and/or securities. In other words, custody is not limited to physically
holding client funds and securities. If an investment adviser has the ability to access or control
client funds or securities, the investment adviser is deemed to have custody and must ensure
proper procedures are implemented. We are deemed to have custody of client funds and
securities whenever we are given the authority to have fees deducted directly from client
accounts. However, this is the only form of custody we will ever maintain. It should be noted
that authorization to trade in client accounts is not deemed by regulators to be custody. For
accounts in which we are deemed to have custody, we have established procedures to ensure
all client funds and securities are held at a qualified custodian in a separate account for each
client under that client’s name. Clients or an independent representative of the client will
direct, in writing, the establishment of all accounts and therefore are aware of the qualified
custodian’s name, address and the manner in which the funds or securities are maintained.
Finally, account statements are delivered directly from the qualified custodian to each client, or
the client’s independent representative, at least quarterly. Clients should carefully review
those statements and are urged to compare the statements with reports received from us.
When clients have questions about their account statements, they should contact us or the
qualified custodian preparing the statement.
We also assist some or all clients with the ability to move money from one account to another.
In these situations, you will sign standing letter of instruction (“SLOAs”) with your custodian that
grants us the ability to facilitate the transfer. When your money is transferred between accounts
with different titles, this is considered a limited form of custody. In 2017, the SEC issued a no-
action letter (“Letter”) with respect to Rule 206(4) -2 (“Custody Rule”) under the Investment
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Advisers Act of 1940 (“Advisers Act”). We and your custodian follow the safeguards outlined in
the letter. These safeguards include:
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.
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.
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.
The client can terminate or change the instruction to the client’s qualified custodian.
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.
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.
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
We offer discretionary and non-discretionary investment management services. For those client
accounts where we provide ongoing supervision, the client has given us, and the sub-advisor
has written discretionary authority over the client’s accounts with respect to securities to be
bought or sold and the amount of securities to be bought or sold. Details of this relationship are
fully disclosed to the client before any advisory relationship has commenced. The client
provides us and the subadvisor discretionary authority via a limited power of attorney in the
agreement between the client and the custodian.
ITEM 17 – VOTING CLIENT SECURITIES
As a matter of firm policy and practice, we do not have any authority to vote proxies on behalf
of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and
all securities maintained in client portfolios. We may provide advice to clients regarding the
clients’ voting of proxies.
ITEM 18 – FINANCIAL INFORMATION
BALANCE SHEET
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or
more in advance. Therefore, we are not required to provide a balance sheet.
Wise Wealth, LLC
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FINANCIAL CONDITION
Registered investment advisers are required in this Item to provide you with certain financial
information or disclosures about our financial condition. We have no financial commitment
that impairs its ability to meet contractual and fiduciary commitments to clients and has not
been the subject of any bankruptcy proceedings.
BANKRUPTCY
We have not been the subject of a bankruptcy proceeding.
Wise Wealth, LLC
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ADV Part 2A – 8/20/2025