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Item 1: Cover Page
PART 2A OF FORM ADV - FIRM BROCHURE
March 26, 2026
Wealth Management Group of North America, LLC
dba: WMGNA, LLC
IA Firm CRD# 125765
10 Talcott Notch Rd, Suite 103
Farmington, CT 06032
(860) 679-5255
www.WMGNA.com
This brochure provides information about the qualifications and business practices of Wealth Management Group of
North America, LLC. If you have any questions about the contents of this brochure, please contact us at (860) 679-5255 or
by email at: Brian@WMGNA.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 Wealth Management Group of North America, LLC is available on the SEC’s website:
www.adviserinfo.sec.gov
Registration does not imply a certain level of skill or training.
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Item 2: Material Changes
• Added Mr. Jacob Paul Sapia, CFP® as an investment advisor representative.
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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 ....................................................................................................7
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ..............................................8
ITEM 7: TYPES OF CLIENTS & ACCOUNT REQUIREMENTS .....................................................................9
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS ........................................9
ITEM 9: DISCIPLINARY INFORMATION ............................................................................................... 14
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................... 14
ITEM 11: CODE OF ETHICS, CLIENT TRANSACTIONS AND PERSONAL TRADING .................................... 14
ITEM 12: BROKERAGE PRACTICES ..................................................................................................... 16
ITEM 13: REVIEW OF ACCOUNTS ...................................................................................................... 18
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ................................................................ 19
ITEM 15: CUSTODY ........................................................................................................................... 19
ITEM 16: INVESTMENT DISCRETION .................................................................................................. 20
ITEM 17: VOTING CLIENT SECURITIES ................................................................................................ 21
ITEM 18: FINANCIAL INFORMATION ................................................................................................. 21
PART 2B OF FORM ADV: BROCHURE SUPPLEMENTS .......................................................................... 24
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Item 4: Advisory Business
Wealth Management Group of North America, LLC (WMGNA) specializes in offering financial planning,
consulting, and investment management services, in coordination with tax preparation and/or filing (Tax).
WMGNA is a limited liability company formed in the State of Connecticut and registered with the Securities
and Exchange Commission (SEC). It was founded in 1996 by Mr. Brian Beck and Mr. Daniel Friedman. As of
FYE2025, WMGNA had $40,161,792.00
in non-Discretionary assets under management, (AUM) and
$306,284,916.00 in Discretionary assets under management.
We offer four types of services, and it is possible for clients to engage WMGNA in one or more of the
following:
•
•
•
•
Financial Planning & Tax (subscription-based)
Financial Consulting & Tax (billed hourly)
Investment Management (fee-based)
Investment Management (non-fee-based)
Financial Planning & Tax (subscription-based):
We offer a subscription service in which we provide financial planning & tax services to individuals, families,
and businesses.
Generally, such services will involve preparing a financial plan, referred to as our “Tax-Out Financial Solutions
Plan,” for clients based on their goals and objectives. This planning may include, but not limited to one or
more of the following areas: Tax Planning, Cash Flow Analysis, Investment Policy Statement, Educational
Funding, Restylement™ Planning, Real Estate Analysis, Stock Option Planning, Employee Benefits Review,
Estate Planning, Charitable Planning, and Business Planning.
We will provide the client with a written summary of their situation and make observations and
recommendations. Some of our recommendations may include, but not limited to - For clients to begin or
revise investment programs, Create and/or revise wills and/or trusts, Obtain and/or revise insurance coverage,
Commence and/or alter retirement savings, Establish education and/or charitable giving prograMr.
The recommendations developed are based upon our professional judgment and we cannot guarantee any
results. The client is under no obligation to implement and/or follow any recommendations or advice given by
WMGNA.
WMGNA’s subscription service may also include - Consolidated investment reports prepared either quarterly,
semi-annually, or annually, Access to our app and personal financial website, Storage and organization of
financial documents, and Access to WMGNA’s team of strategic partners.
Financial Consulting & Tax (billed hourly):
We provide financial planning and tax services to individuals, families, and businesses, these services are billed
on an hourly basis. Since the client is engaging us once and not on an ongoing basis, the process is less formal
than our subscription-based service offering. Thus, we may or may not provide clients with a written financial
plan, these services are negotiated with the client, agreed to, and signed off by both WMGNA and the Client.
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The agreement will outline the services that the client is paying for, and it may include, but not limited to one
or more of the following areas: Tax Planning, Cash Flow Analysis, Investment Policy Statement, Educational
Funding, Restylement™ Planning, Real Estate Analysis, Stock Option Planning, Employee Benefits Review,
Estate Planning, Charitable Planning, Business Planning.
We will provide the client with a written summary of their situation and make observations and
recommendations. Some of our recommendations may include, but not limited to - For clients to begin or
revise investment programs, Create and/or revise wills and/or trusts, Obtain and/or revise insurance coverage,
Commence and/or alter retirement savings, Establish education and/or charitable giving prograMr.
Since this a one-time service the client will not be entitled to - Consolidated investment reports, Access to our
app and personal financial website, Storage, and organization of financial documents, however, they will get
access to WMGNA’s team of strategic partners.
Investment Management Services (fee-based):
WMGNA frequently outsources the management of their client’s investments to third party money managers,
who will manage the client’s money on a discretionary basis for a fee. Our selection of third-party money
managers begins with a discovery meeting to find out the client's objectives, review current investments, time
horizons, risk tolerance, liquidity needs, prior investment history, as well as family composition and investing
background. We may need to gather additional client information such as tax returns, as well as bank and
401k statements.
We will take the information and documents and develop an appropriate investment management strategy by
first building an asset allocation that will match the client’s objectives, time horizons, risk tolerance, liquidity
needs and investing background. Next, we will search our universe for third-party managers that will fit into
the above-mentioned criteria. From this list we will then select what we believe are the best managers for the
client based upon investing style, performance history and peer group ranking, management/manager
experience, and overall fit to the client’s investment experience, background, and comfort level.
At a minimum of once per year, WMGNA will review the client’s overall situation, their third-party money
managers that have been selected, and, if needed, make changes proactively based upon - portfolio drifts,
management changes, under performance, and/or new opportunities that become available.
During the year the client will be expected to notify WMGNA of any material changes to their situation, such
as including, but not limited to - Loss/change of job, Liquidity needs, Change of retirement date, as well as any
changes to the clients over all goals and/or needs.
Investment Management Services (non-fee-based):
WMGNA also offers investment management services to our clients without using third party money
managers. In these cases, WMGNA offers non-discretionary investment management to qualified clients. Our
investment management service focuses on building an asset allocation model based on the client’s needs and
objectives. We do this by having a discovery meeting with the client to find out the client's goals objectives,
review current investments, time horizons, risk tolerance, liquidity needs, prior investment history, as well as
family composition and investing background. We may need to gather additional client information such as tax
returns, as well as bank and 401k statements.
We will take the information gathered and develop an appropriate investment management strategy by first
building a customized asset allocation model that will match the client’s objectives, time horizon(s), risk
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tolerance, liquidity needs and investing background. Next, we will develop a portfolio of investments that
consists of the investment types listed below. Investment selections will be based upon costs, performance
history versus the markets and their peer group, management/ manager experience, extra benefits (such as
living benefits, downside protection), and overall fit to the client’s investment experience and philosophy.
• Mutual Funds*
• Exchange Traded Funds (ETFs)*
• Domestic Equities
• Foreign Equities
• Options
• Corporate Bonds
• Certificates of Deposit
• Municipal bonds
• U.S. Treasuries
• Tax free fixed income
• Real Estate Investment Trusts (REITs)*
• 3rd Party Money Managers*
• Unit Investment Trusts (UIT’s)*
• Alternative Investments/Hedge Funds/Private Equity*
• Variable Annuities*
(* - These types of investment options are products and/or services created and offered by other investment
companies, broker dealers, and insurance companies. They will typically have a separate fee structure that is
commission based. WMGNA will review the details of these products (i.e. features, advantages, benefits, and
fee structure) with clients prior to WMGNA adding them to a client’s portfolio.)
Because some types of investments involve certain additional degrees of risk, they will only be implemented
or recommended when consistent with a client's stated investment objectives, risk tolerance, liquidity needs,
and suitability.
Third‑Party Asset Managers (TPAMs)
The firm may recommend or utilize Third‑Party Asset Managers (“TPAMs”) to provide portfolio management
services for certain clients. When TPAMs are used, the firm develops a client‑specific asset allocation strategy
(the “True Success Plan™”) based on the client’s investment objectives, risk tolerance, liquidity needs, time
horizon, and any client‑imposed restrictions. This strategy guides the identification of appropriate TPAMs and
investment programs.
The firm conducts due diligence on TPAMs using third‑party databases such as Envestnet and/or SEI. This
includes quantitative screening, performance evaluation, regulatory and compliance review, organizational
assessment, and discussions with TPAM personnel. Clients retain final approval authority over the selection of
any TPAM and must provide written acknowledgment before implementation.
The firm provides ongoing monitoring of each TPAM and conducts a formal review at least annually. TPAMs
identifies material concerns such as sustained
may be recommended for termination
if the firm
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underperformance, significant organizational changes, or compliance‑related issues. Any changes require
client approval prior to implementation.
Item 5: Fees and Compensation
WMGNA will receive compensation based on the type of advisory services WMGNA performs. The WMGNA
investment advisory contract may be terminated by the client within five (5) business days of the signing of
the advisory agreement/contract and the client will not be responsible for advisory fees incurred during that
time. Please review the fee and compensation information below
Financial Planning & Tax (subscription-based):
Terms and conditions are covered by the WMGNA Subscription Agreement for: Financial Planning & Tax
Services. Annual costs range from $1,200 to $12,000 and can be billed monthly. If billed monthly, Client will be
invoiced on the 1st of the month and costs will be deducted on the 15th via ACH.
Financial Consulting & Tax (billed hourly):
Terms and conditions are covered by the WMGNA Financial Consulting & Tax Services. Costs are billed hourly
based upon the number of hours it will take to complete the client’s project. The total cost will be agreed on
by both WMGNA and the client before any work is performed. The maximum hourly fee is $325 with a 3-hour
minimum.
Investment Management Services (fee-based):
The billing procedures and costs for this service will be outlined in separate tri-party agreements. We
currently utilize tri-party agreements with Envestnet and SEI. Clients will be provided with a copy of the
chosen third-party money manager’s Form ADV Part 2, all relevant Brochures, and a third-party money
manager’s privacy policy. The client’s total annual advisory fee will not exceed 2.0% annually, except for
alternative investments, hedge funds and/or private equities are used. In these cases, the client will receive an
additional fee schedule to sign before using these programs.
WMGNA’s fees listed below are included in the client’s total annual fee provided in the tri-party agreement.
Our maximum fees are based on the following tiered schedule:
Assets Under Management ($) Annual (%)
$0 - $1,000,000
$1,000,001 - $2,000,000
$2,000,001 - $5,000,000
$5,000,001+
1.0%
0.90%
0.75%
0.60%
Investment Management Services (non-fee-based):
Certain securities and products are available on a commission basis. To sell securities for a commission, we
must use a licensed broker-dealer. Our current Broker-Dealer is Arkadios Capital member of FINRA/SIPC, and a
member of Arkadios Capital. All of our commissioned based securities transactions are supervised by a person
who is also a registered representative of Arkadios Capital. Our supervised persons may accept compensation
for the sale of securities or other investment products, including distribution or service (“trail”) fees from the
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sale of mutual funds. You should be aware that the practice of accepting commissions for the sale of securities
presents a conflict of interest and gives our firm and/or our supervised persons an incentive to recommend
investment products based on the compensation received, rather than on client’s needs.
The client is under no obligation to purchase investment products through WMGNA and may use other
brokers or agents which are not affiliated with us.
Other Fees and Expenses
Clients may incur transaction charges for trades executed in their accounts by third party money managers.
These transaction fees are separate from advisory fees and will be disclosed in the tri-party agreement. Clients
may also pay charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (i.e., fund management fees, 12b-1 fees, and other fund expenses). The
client may also incur other costs associated with the custodian. See item 12 for more information. Our firm
does not receive these fees.
Termination and Refunds:
Financial Planning & Tax (subscription-based) – If paid annually, client needs to contact WMGNA in writing 30
days prior to their annual renewal date and state that they wish to cancel the agreement. If service is
cancelled during the year, the client will receive a pro-rated refund. If billed monthly the client has until the
10th of every month to terminate the agreement and not be charged for the month. If any of the subscription
includes the cost of the client’s tax preparation work, the client’s refund may be affected by the time of the
year they cancel and if WMGNA has already paid for client’s tax preparation for that said year.
Financial Consulting & Tax (billed hourly) – If the work was completed as agreed to in the Tax and Financial
Consulting Agreement, there is no refund. However, if the client notifies WMGNA before any or all the work
by WMGNA has been completed, we will refund an amount equal to the unworked hours by WMGNA.
Investment Management Services (fee-based) – Third Party Money Manager fees are billed quarterly in
advance. Thus, the client will only be refunded from the day of cancellation to the end of the current quarter.
Investment Management Services (non-fee-based) – No fees are being charged; however, we do receive
commissions. These commissions are not refundable to the client.
Lower fees for comparable services may be available from other sources.
Item 6: Performance-Based Fees and Side-By-Side Management
WMGNA does not use or charge performance-based fees and/or participates in side-by-side management.
Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client's
account. Unless negotiated differently, our fees are calculated as described above, and are not charged on the
basis of a share of capital gains upon, or capital appreciation of, the funds in client advisory accounts.
Side-by-side management refers to the practice of managing accounts that are charged performance-based
fees while at the same time managing accounts that are not charged performance-based fees.
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Item 7: Types of Clients & Account Requirements
We have the following types of clients:
Individuals and High Net Worth Individuals;
•
• Pension and Profit Sharing Plans;
• Corporations, limited liability companies and/or other business types.
WMGNA does not have account requirements.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We may use the following methods of analysis in formulating our investment advice and/or managing client
assets:
Technical Analysis - Technical Analysis involves studying past price patterns and trends in the financial
markets to predict the direction of both the overall market and specific stocks. The risk of market timing based
on technical analysis is that charts may not accurately predict future price movements. Current prices of
securities may reflect all information known about the security and day to day changes in market prices of
securities may follow random patterns and may not be predictable with any reliable degree of accuracy.
Fundamental Analysis - Fundamental analysis involves analyzing individual companies and their industry
groups, such as a company's financial statements, details regarding the company's product line, the
experience, and expertise of the company's management, and the outlook for the company's industry. The
resulting data is used to measure the true value of the company's stock compared to the current market
value. The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not
provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust
rapidly to new information, utilizing fundamental analysis may not result in favorable performance.
Cyclical Analysis - Cyclical analysis is a type of technical analysis that involves evaluating recurring price
patterns and trends based upon business cycles. The lengths of economic cycles may be difficult to predict
with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and
consequently the changing value of securities that would be affected by these changing trends.
Quantitative Analysis - Quantitative analysis deals with measurable factors as distinguished from qualitative
considerations such as the character of management or the state of employee morale, such as the value of
assets, the cost of capital, historical projections of sales, and so on.
Qualitative Analysis - Qualitative analysis is a securities analysis that uses subjective judgment based on
unquantifiable information, such as management expertise, industry cycles, strength of research and
development, and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on
numbers that can be found on reports such as balance sheets. The two techniques, however, will often be
used together in order to examine a company's operations and evaluate its potential as an investment
opportunity.
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Investment Strategies
We believe that asset allocation across diverse investment is the key to long term success in reaching client
objectives. A Client’s portfolio is customized to that client’s specific investment objectives and risk tolerance.
All of our investment advice is based on using a strategic asset allocation methodology, with prevailing long-
term trends in mind. Short-term trends and strategies will not be employed unless necessary in accordance
with Client mandates.
We use the following strategies in managing client accounts, provided that such strategies are appropriate to
the needs of the client and consistent with the client's investment objectives, risk tolerance, and time
horizons, among other considerations:
Long-Term Purchases: When utilizing this strategy, we may purchase securities with the idea of holding them
for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by
holding the security for this length of time, we may not take advantages of short-term gains that could be
profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before
we make the decision to sell. Typically we employ this sub-strategy when we believe the securities to be well
valued; and/or we want exposure to a particular asset class over time, regardless of the current projection for
this class.
Short-Term Purchases: When utilizing this strategy, we may also purchase securities with the idea of selling
them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of
conditions that we believe will soon result in a price swing in the securities we purchase.
Options: We may use options as an investment strategy for clients that are comfortable with the complexity
and have an options agreement on file with the appropriate approved level for the strategy to be used. An
option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a
share of stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a security.
An option is also a derivative, because it derives its value from an underlying asset. The two types of options
are calls and puts. A call gives the buyer the right to buy an asset at a certain price within a specific period of
time. A put gives the buyer the right to sell an asset at a certain price within a specific period of time. We will
buy a put if we have determined that the price of the stock will fall before the option expires.
Covered call writing involves the sale of a call option on a security you own. In this strategy, you receive a
premium for making the option available to a buyer; the person purchasing the call option has the right to buy
the security from you at an agreed-upon price.
Multi-leg strategies (i.e. spreads, straddles, butterflies, strangles, etc…) involve the purchase and/or sale of
two or more option contracts. These strategies when used in conjunction with one another allows one the
ability to vary price, time and other factors.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may
increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease and
your account(s) could suffer a loss. It is important that you understand the risks associated with investing in
the stock market, are appropriately diversified in your investments, and ask us any questions you may have.
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Market Risks
All investments, particularly equities and debt securities are subject to market volatility, economic factors and
various other market risks. The success of a particular investment may depend to a great extent upon correctly
assessing the future course of price movements of stocks and bonds. Wealth Management Group of North
America, has no way to accurately predict price movements of investments.
Concentrated Positions - Client portfolios may contain one or more highly concentrated investment positions
and also may be heavily invested and/or over weighted in specific industries. This increases the potential
volatility within a portfolio thus increasing the risk of loss relative to the overall markets as a whole.
Small Capitalization Companies - Assets may be invested in smaller less established companies. Both debt and
equity securities of such issuers tend to be more volatile than larger, more established companies. Such
volatility could adversely impact client portfolios.
Large Capitalization Companies - Large cap stocks can perform differently from other segments of the equity
market of the equity market as a whole. Large capitalization companies may be less flexible in evolving
markets or unable to implement change as quickly as smaller capitalization companies.
Non-U.S. Investments - Wealth Management Group of North America, may recommend that clients invest
client funds in securities (debt, equity, currencies, derivatives, etc...) of companies domiciled outside the
United States.(Primarily for diversification) Such investments expose the account to a number of risks that
may not exist in the domestic market alone. Such risks include, among other things, trade balances and
imbalances and related economic policies, currency exchange rate fluctuations, imposition of exchange
control regulation, withholding taxes, limitations on the removal of funds or other assets, possible
nationalization of assets or industries, political difficulties, and political instability in foreign nations.
Margin and Short Sales – The use of margin, and short sales represents a potential increase in risk, given their
inherent nature of increasing a portfolios overall risk through varying degrees of leverage. The use of leverage
& the borrowing of capital will increase risk. Short sales limit upside appreciation, along with an unlimited risk
of loss. Short positions are also subject to a “short squeeze” that could force you to close out the position(s) to
stop the risk of continued loss.
Here are some of the fee-based investment types listed in “Item 4” of this ADV Part 2A, with the 3 main
risks most commonly associated with each:
• Mutual Funds - Market risk, Management risk, Tracking risk.
Mutual Funds are investment vehicles that contain/hold other investments and may be limited by their
investment strategies, and a Mutual Fund's price may fluctuate based on underlying market conditions,
and the pricing of the underlying securities.
• Exchange Traded Funds (ETFs) - Market risk, Management risk, Tracking risk.
ETF’s are investment vehicles that contain/hold other investments allowing them to be traded on an
exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of an ETF can
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be lower from that of the underlying securities, that the ETF may be limited by its investment strategy, and
that an ETF's price may fluctuate throughout the day.
• Real Estate Investment Trust (REITs) REITs - Issuer risk, Liquidity risk, Management risk.
REITs are investment vehicles that contain/hold real estate investments allowing them to be traded on an
exchange. They may be subject to brokerage trading costs, cost efficiency, the market price of a REIT can
be lower from that of the underlying real estate, and a REITs price may fluctuate throughout the day.
• Domestic Equities - Market risk, Company risk, Liquidity risk.
Domestic Equities are typically traded on an exchange. They may be subject to brokerage trading costs,
cost efficiency, the market price of a domestic equity may fluctuate throughout the day.
• Foreign Equities - Currency risk, Foreign Market risk, Company risk.
Foreign Equities are typically traded on an exchange. They may be subject to brokerage trading costs, cost
efficiency, the market price of a foreign equity may fluctuate throughout the day and overnight, depending
on the exchange in which it is traded.
• Corporate Bonds - Interest Rate risk, Issuer risk, Liquidity risk.
Corporate bonds are not traded on an exchange. They may be subject to brokerage trading costs, cost
efficiency, the market price of a Corporate bond may fluctuate by the interest rate environment, and
credit rating of the issuer.
• Commercial Paper - Credit risk, Fixed Income risk, Interest Rate risk.
Commercial paper is not traded on an exchange. They may be subject to brokerage trading costs, cost
efficiency, the market price of a Commercial paper may fluctuate by the lending/overnight rate
environment, and credit rating of the issuer.
• Certificates of Deposit - Fixed Income risk, Interest Rate risk, Liquidity risk.
Certificates of deposit are not traded on an exchange. They may be subject to brokerage trading costs, cost
efficiency, the market price of a certificate of deposit may fluctuate by the interest rate environment, the
issuing bank and liquidity risk if sold on the secondary market.
• Municipal Bonds - Fixed Income risk, Interest Rate risk, Credit risk.
Municipal bonds are not traded on an exchange. They may be subject to brokerage trading costs, cost
efficiency, the market price of a municipal bonds may fluctuate by the interest rate environment, the
issuing municipality credit rating and taxing authority.
• U.S. Treasuries - Fixed Income risk, Interest Rate risk, Credit risk.
U.S. Treasuries are not traded on an exchange as they are issued by the U.S. Government and may be
subject to brokerage trading costs, cost efficiency, the market price of a U.S. Treasuries may fluctuate by
the interest rate environment, and U.S. currency strength/weakness.
• Commodities - Commodity risk, Interest Rate risk, Liquidity risk.
Factors that can influence commodity prices include politics, seasons, weather, technology, and market
conditions.
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• 3rd Party Money Managers – Market risk, Management risk, Tracking risk.
3rd Party Money Managers manages the securities portfolio of an individual or institutional investor.
Typically, a money manager employs people with various expertises ranging from research and selection of
investment options to monitoring the assets and deciding when to sell them.
• Hedge Funds - Market risk, Management risk, Tracking risk.
Hedge Funds are limited partnerships that act as an investment vehicle that contain/hold investments that
may use high risk methods, such as investing with borrowed money, in hopes of realizing large capital
gains and may be limited by their investment strategies, and a Hedge Fund's price may fluctuate based on
underlying market conditions, and the pricing of the underlying securities.
While WMGNA has provided a comprehensive list of risks associated with our fee-based investment options,
investing in financial markets and products may bring additional risks that have not been listed above. Clients
should consult with their WMGNA representative about any additional risks with which they may be
concerned.
Our non-fee based investments and products vary based on various factors, to include current industry and
market conditions. Clients should consult with their WMGNA representative about any additional risks with
which they may be concerned. Lower fees for comparable services may be available from other sources.
TPAM Evaluation and Selection Methodology
When evaluating TPAMs, the firm uses both quantitative and qualitative methods of analysis. Quantitative
analysis includes absolute and risk‑adjusted performance, benchmark and peer comparisons, volatility and
downside risk measures, maximum drawdown, and style consistency. Qualitative analysis includes review of
investment philosophy, research methodology, decision‑making processes, risk‑management framework,
organizational stability, ownership structure, financial condition, and key personnel experience.
The firm reviews Form ADV disclosures, regulatory history, and any disciplinary events. Meetings with TPAM
representatives may be conducted to assess investment process, team dynamics, and operational controls.
The firm also evaluates manager fees, total client cost, and potential conflicts of interest to ensure
recommendations are made in the client’s best interest.
Risks of Using TPAMs
Using TPAMs involves risks, including:
•
•
•
•
•
The TPAM may underperform its benchmark or peer group
The TPAM may deviate from its stated investment strategy (“style drift”)
Changes in personnel, ownership, or organizational structure may affect performance
Market conditions may impact the TPAM’s strategy differently than expected
The TPAM may experience operational, regulatory, or compliance issues
Clients should understand that no investment strategy or TPAM can guarantee performance or prevent loss.
Lower fees for comparable services may be available from other sources.
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Item 9: Disciplinary Information
WMGNA has not been the subject of any disciplinary actions and does not have any legal of disciplinary
information to disclose. Any disciplinary information regarding Wealth Management Group of North America,
and/or its Investment Advisor Representatives would be disclosed here as well as additional information being
disclosed on the Wealth Management Group of North America, IAR’s ADV Part 2B.
Pursuant to 950 Mass. Code Regs. 12.205(8)(d) Massachusetts residents can request disciplinary information
regarding Wealth Management Group of North America, LLC and its representatives by contacting the
Massachusetts Securities Division at (617) 727-3548.
Item 10: Other Financial Industry Activities and Affiliations
Representatives of our firm are registered representatives of Arkadios Capital, Inc., member FINRA/SIPC, and
brokers. They may offer products and receive commissions as a result of these transactions. A conflict of
interest may arise as these commissionable securities sales may create an incentive to recommend products
based on the compensation they may earn. Client accounts will not be subject to both fee-based
compensation and commission-based compensation.
Representatives of our firm are licensed insurance agents. They may offer insurance products and receive
normal and customary fees as a result of insurance sales. A conflict of interest may arise as these insurance
sales may create an incentive to recommend products based on the compensation our supervised persons
may earn. Our firm will take steps to address this potential conflict of interest, acting at all times in the best
interests of our clients and are bound by our firm’s Code of Ethics. Please refer to Item 11 below for additional
information.
If and when a “Conflict of Interest” exists, the WMGNA representative will address the situation by identifying
the specifics of the Conflict of Interest on the WMGNA “Conflict of Interest Form”, and the form will signed by
both the Client and the WMGNA representative.
Third‑Party Asset Manager Affiliations
The firm may recommend TPAMs to clients based on its due‑diligence process. When recommending TPAMs,
the firm evaluates fees, services, and potential conflicts of interest. All applicable fees and expenses are
disclosed to clients prior to implementation. Clients retain full discretion to accept or reject any TPAM
recommendation.
Item 11: Code of Ethics, Client Transactions and Personal Trading
We recognize that the personal investment transactions of members and employees of our firm demand the
application of a high Code of Ethics and require that all such transactions be carried out in a way that does not
endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients
and for members and employees of our firm, it is logical and even desirable that there be common ownership
of some securities.
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Our firm’s associated persons may buy or sell securities or have an interest or position in a security for their
personal account, which we also recommend to clients. We are and will continue to be in compliance with The
Insider Trading and Securities Fraud Enforcement Act of 1988. As these situations may represent a potential
conflict of interest, it is a policy of the applicant that no associated persons shall prefer his or her own interest
to that of the advisory client. No person employed by us may purchase or sell any security prior to a
transaction or transactions being implemented for an advisory account.
The associated persons shall not buy or sell securities for their personal account(s) where their decision is
derived, in whole or in part, by information obtained as a result of his/her employment unless the information
is also available to the investing public upon reasonable inquiry. We maintain a list of all securities holdings for
all associated persons, which is reviewed on a regular basis by a principal of the firm. This log is available for
client review upon request.
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons.
An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to
provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at
all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle
for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and
Procedures. We require all of our supervised persons to conduct business with the highest level of ethical
standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation
and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read,
understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct
business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or
appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a
summary of our
Code of Ethics
A client or prospect can request and view our Code of Ethics at any time.
Our firm’s related person may invest in the same securities that our firm’s related person recommends to
clients. In order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing
procedure) with respect to transactions effected by our members, officers and employees for their personal
accounts. In order to monitor compliance with our personal trading policy, we have a quarterly securities
transaction reporting system for all of our associates.
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. We
require all of our supervised persons to conduct business with the highest level of ethical standards and to
comply with all federal and state securities laws at all times. Upon employment or affiliation and at least
annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand,
and agree to comply with our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics
in its entirety, a copy will be provided promptly upon request.
Our firm’s related persons may invest in the same securities that our firm’s related person recommends to
clients. In order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing
procedure) with respect to transactions effected by our members, officers and employees for their personal
accounts. In order to monitor compliance with our personal trading policy, we have a quarterly securities
transaction reporting system for all of our associates.
15
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. We
require all of our supervised persons to conduct business with the highest level of ethical standards and to
comply with all federal and state securities laws at all times. Upon employment or affiliation and at least
annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand,
and agree to comply with our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics
in its entirety, a copy will be provided promptly upon request.
Department of Labor Fiduciary Rule
Our firm provides investment advice to assets affected by the Department of Labor (“DOL”) Fiduciary Rule for
a level fee. As such, we abide by the Impartial Conduct Standards as defined by the DOL. To comply with these
standards, our firm and our advisors give advice that is in our clients’ best interest, charge no more than
reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section
4975(d)(2), and make no misleading statements about investment transactions, compensation, conflicts of
interest, and any other matters related to investment decisions.
As a level-fee fiduciary, we maintain a non-variable compensation structure that is provided on the basis of a
fixed percentage of the value of assets or a set fee that does not vary with the particular investment
recommended, as opposed to a commission or other transaction based fee.
Item 12: Brokerage Practices
We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that
are overall most advantageous when compared to other available providers and their services. We consider a
wide range of factors, including, among others, these:
• Costs
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
Selecting Brokerage Firms
WMGNA maintains the ability to work with multiple custodians and maintains the right to recommend clients
work with the qualified custodian that they feel most comfortable with based on the specific needs of the
client. WMGNA does not receive fees or commissions from these arrangements. WMGNA will recommend a
custodian based on the client’s needs, historically proven integrity, and financial responsibility.
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Our clients may pay a commission to one of our custodians that is higher than another qualified broker dealer
might charge to affect the same transaction where we determine in good faith that the commission is
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 broker-dealer’s services, including the value
of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we
will seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest possible
commission rates for specific client account transactions.
Currently, we recommend four custodians to clients:
•
•
•
•
Charles Schwab
National Financial Services (NFS) – wholly owned subsidiary of Fidelity
SEI
TD Ameritrade – now part of Charles Schwab
Research and Other Soft-Dollar Benefits
Although the investment research products and services that may be obtained by our firm will generally be
used to service all of our clients, a brokerage commission paid by a specific client may be used to pay for
research that is not used in managing that specific client’s account.
Our firm does not accept products or services that do not qualify for Safe Harbor outlined in Section 28(e) of
the Securities Exchange Act of 1934, such as those services that do not aid in investment decision-making or
trade execution.
Soft Dollars
While WMGNA has no formal soft dollar program in which soft dollars are used to pay for third party services,
WMGNA, may receive research, products, or other services from custodians and broker-dealers in connection
with client securities transactions (“soft dollar benefits”).
WMGNA may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor
contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that
any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it,
and WMGNA, does not seek to allocate benefits to client accounts proportionate to any soft dollar credits
generated by the accounts. WMGNA, benefits by not having to produce or pay for the research, products or
services, and WMGNA, will have an incentive to recommend a broker-dealer based on receiving research or
services. Clients should be aware that WMGNA’s acceptance of soft dollar benefits may result in higher
commissions charged to the client.
Best Execution
We believe in using custodians that provide the best services at competitive rates. The reasonableness of
commission rates is based on several factors, including the broker's ability to provide professional services,
execution, the broker's reputation, experience and financial stability of the broker or dealer, and the quality of
service rendered by the broker or dealer in transactions. Best execution is not measured solely by reference to
commission rates. Paying a broker a higher commission rate than another broker might charge is permissible if
the difference in cost is reasonably justified by the quality of the brokerage services offered. Each of the above
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mentioned custodians (TD Ameritrade & NFS) have a history of best execution performance that is well
documented in various publications and testing results.
Client Brokerage Commissions
We do not use client brokerage commissions to obtain research or other products or services.
The aforementioned research and brokerage services are used by our firm to manage accounts for which we
have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or
similar services at our own expense.
Procedures to Direct Client Transactions in Return for Soft Dollars
We do not direct client transactions to a particular broker-dealer in return for soft dollar benefits.
Order Aggregation
It is WMGNA’s practice to aggregate transactions across multiple client accounts if and whenever possible, in
an effort to obtain the best execution for our clients.
Directed Brokerage
In limited circumstances, and at our discretion, some clients may instruct WMGNA, to use one or more
particular brokers for the transactions in their accounts. If clients choose to direct our firm to use a particular
broker, clients should understand that this might prevent from effectively negotiating brokerage commissions
on clients behalf. This practice may also prevent WMGNA, from obtaining a favorable price and execution.
Thus, when directing brokerage business, clients should consider whether the commission expenses,
execution, clearance, and settlement capabilities that clients will obtain through a particular broker are
adequately favorable in comparison to those that we would otherwise obtain for clients.
Trade Errors
Trading errors can and do happen. If a trade error occurs when entering a trade on behalf of a client. If the
error occurred was found to be WMGNA’s fault, WMGNA’s policy is to restore a client’s account to the
position it should have been in had the trade error had not occurred. Depending on the circumstances,
corrective actions may include canceling/busting said trade, adjusting the client account to reflect the
appropriate asset allocation and/or the reimbursing of any fees to the client account.
Brokerage and Trading Practices for TPAM Programs
When clients engage a TPAM, the TPAM may require the use of a specific custodian or broker‑dealer for
execution of trades. In such cases, the firm reviews the TPAM’s trading practices, execution quality, and
operational processes as part of its due‑diligence and monitoring responsibilities. The firm evaluates whether
the TPAM’s brokerage arrangements are consistent with the client’s best interest, taking into account
execution quality, costs, and available services.
The firm monitors TPAM trading activity as part of its ongoing oversight and conducts an annual review of
performance, strategy adherence, personnel changes, organizational developments, and Form ADV updates.
Item 13: Review of Accounts
WMGNA will review client’s accounts at least on an annual basis, based upon their subscription-based
anniversary or for non-subscription-based clients, their implementation date. Subscribers to our membership
services may also receive a Consolidated Investment Report quarterly or semi-annually in which their accounts
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will be reviewed. Mr. Daniel J Friedman, Mr. Brian P. Beck, and Mr. Christopher J. Powers separately and/or
together will review client accounts.
Client accounts may be reviewed more frequently than described above. Some factors that would trigger an
off-cycle review are - Major market or economic events, Changes to the tax laws, Change in life event of the
client, and/or a Review requested by the client.
Regular Reports
Clients will receive at least quarterly statements from their custodian(s) and investments companies. Clients
will receive these statements along with any transactions on an electronic basis unless they opt otherwise.
Clients who are using our Investment Management Services (fee-based) through Envestnet will have access to
their portfolio performance reports at least quarterly via Envestnet’s client portal.
Item 14: Client Referrals and Other Compensation
Referral Fees
We pay referral fees (non-commission based) to independent solicitors (non-registered representatives) for
the referral of clients to our firm in accordance with Rule 206 (4)-3 of the Investment Advisers Act of 1940.
Such referral fees represent a share of our investment advisory fee charged to our clients. This arrangement
will not result in higher costs to the client. In this regard, we maintain Solicitors Agreements in compliance
with applicable state and federal laws. All clients referred by Solicitors to our firm will be given full written
disclosure describing the terms and fee arrangements between our firm and Solicitor(s). In cases where state
law requires licensure of solicitors, we ensure that no solicitation fees are paid unless the solicitor is registered
as an investment adviser representative of our firm. If we are paying solicitation fees to another registered
investment adviser, the licensure of individuals is the other firm’s responsibility.
Compensation Related to TPAMs
The firm does not receive any compensation, direct or indirect, from TPAMs for recommending their services.
All TPAM recommendations are made solely in the client’s best interest. Clients are informed of all applicable
TPAM fees and expenses prior to implementation.
Item 15: Custody
If WMGNA does have custody it is solely a consequence of its authority to deduct subscription-based clients
monthly fee via our ACH service. WMGNA is not required to have annual financial statements audited because
we have met the following conditions:
1.
The client provides an instruction to the Qualified Custodian (WMGNA), 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.
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2.
3.
4.
5.
6.
7.
The client authorizes the investment adviser (WMGNA), 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 has the ability to 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; and
The client’s Qualified Custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
WMGNA does not accept or maintain custody of any Client’s investment accounts. All Client’s assets will be
placed by one or more of our custodians listed in Section 12 unless client requests a qualified custodian of
their own preference. While WMGNA will make its best effort to use the client’s custodian of choice, this is
not guaranteed. Qualified custodians will direct debit the client’s investment advisory fees based upon the tri-
party agreement that the client signs.
Client’s tri-party agreements with Envestnet, Arkadios Capital, and SEI give them written authorization to
deduct client’s investment advisory fees from the account(s) held with the qualified custodian. This ability to
deduct investment advisory fees from clients account(s) falls under the category of trade authorization over
client funds or securities. WMGNA does not have physical custody of any client funds and/or securities. If
directed by WMGNA, client funds and securities will be held by one or more of their qualified custodians.
Clients will receive account statements from the independent, qualified custodians holding the client’s funds
and securities at least quarterly. The account statements from client’s custodians will indicate the amount of
client’s advisory fees deducted from clients account(s) each billing period. Clients should carefully review
account statements for accuracy. If clients have a question regarding account statements or if clients did not
receive a statement from the custodian, please contact WMGNA immediately.
WMGNA has implemented these transparent safeguards to help protect clients and their assets.
Item 16: Investment Discretion
Discretionary Authority for Trading
WMGNA has discretionary authority for trading under the tri-party agreements with Envestnet and Arkadios
Capital. WMGNA under its separate written agreement, WMGNA Investment Management Services (fee-
based), has elected to give up its discretionary authority for all third-party management investment accounts.
All other investment accounts managed directly by
WMGNA are on a non-discretionary basis.
Discretionary Authority for Third Party Investment Managers and/or Sub-Managers
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WMGNA often outsources the daily management of client’s investments to third-party money managers and
sub-managers. These managers require the client to give them discretionary trading authority. These
managers also have the authority to choose the investments to be bought and/or sold, and the amount of the
securities to be bought and/or sold.
WMGNA will offer advice as to what third-party money managers and/or sub-manager(s) a client uses.
WMGNA only after a discussion with the client will hire and/or fire such managers, determine the portion of
the client's account that shall be managed by any given manager, and to change the allocation of assets
among a group of managers.
Discretionary Authority for Third Party Investment Managers and/or Sub-Managers
WMGNA often outsources the money management of client’s investments to third party investments
managers (TPAMs) and sub-managers. These managers require the client to give them discretionary trading
authority. These managers also have the authority to choose the investments to be bought and/or sold, and
the amount of the securities to be bought and/or sold.
WMGNA will offer advice as to what Third Party Investment Managers and/or Sub-Manager(s) a client uses.
WMGNA only after a discussion with the client will hire and/or fire such managers, determine the portion of
the client's account that shall be managed by any given manager, and to change the allocation of
assets among a group of managers.
Item 17: Voting Client Securities
Proxy Votes
WMGNA can and will assist clients with voting proxies if the client chooses. If a client owns shares of
investments, clients are shareholders and can exercise their right to vote on proxies as a shareholder. In most
cases, clients will receive proxy materials directly from the account custodian. However, in the event we were
to receive any written or electronic proxy materials, the materials would be forwarded directly to clients by
mail, unless clients have authorized the firm to contact clients by electronic mail, in which case, we would
forward any electronic solicitation to vote proxies. Clients that would like assistance from WMGNA in
understanding the material within the proxy and/or would like assistance with the voting process can contact
WMGNA by phone or by email using the contact information on the front of this brochure.
Class Action Lawsuits
WMGNA, does not determine if securities held by clients are the subject of a class action lawsuit or whether
clients are eligible to participate in said class action settlement or litigation nor does WMGNA, initiate or
participate in litigation to recover damages on a client’s behalf for damages as a result of said actions,
misconduct, or negligence of said party.
Item 18: Financial Information
Financial Condition
21
WMGNA does not have any financial situations that will result in WMGNA, from meeting contractual
commitments to clients. An audited financial statement is not required to be provided by WMGNA.
WMGNA and/or its representatives have never been the subject of a bankruptcy proceeding.
Item 19: Third Party Asset Manager (TPAM) Selection, Review and
Monitoring Protocol
Purpose
This item outlines the policies and procedures used by the firm to evaluate, select, monitor, and, when
necessary, terminate Third Party Asset Managers (TPAMs). These protocols are designed to ensure fiduciary
oversight, consistency, and compliance with applicable SEC regulations, including the firm’s obligation to act in
the best interest of clients.
Initial Selection Process
Development of Asset Allocation Strategy (True Success Plan™)
Prior to the selection of any TPAM, the firm develops a client-specific asset allocation strategy that considers:
Client investment objectives and constraints, Target asset allocation ranges, Client risk tolerance, Liquidity
needs and time horizon, ESG preferences or other client-imposed restrictions, if applicable.
This information serves as the foundation for identifying appropriate investment
strategies and TPAMs.
Manager Universe Development
The firm conducts a comprehensive screening of potential TPAMs using third-party databases, including
Envestnet and/or SEI. The screening process includes: Application of quantitative filters (e.g., asset class,
strategy type, minimum track record, capacity constraints), Review of regulatory history and compliance
disclosures., Elimination of managers with identified red flags, material compliance issues, or regulatory
concerns.
Quantitative Analysis
Each TPAM that passes the initial screen is evaluated using quantitative metrics, including but not limited to:
Absolute and risk-adjusted performance, Benchmark and peer group comparisons, Volatility, downside
deviation, and maximum drawdown, Style consistency and factor exposure analysis.
Organizational and Personnel Review
The firm evaluates the stability and quality of the TPAM’s organization, including: Ownership structure and
financial stability, Key personnel experience, background, and tenure, Review of Form ADV, Assessment of
organizational culture and governance practices.
Detailed Due Diligence Management Meetings
The firm conducts phone or virtual meetings with TPAM representatives, which may include: Management
presentations, Question-and-answer sessions, Evaluation of investment philosophy, decision-making process,
and team dynamics.
Legal and Compliance Review
22
As part of due diligence, the firm reviews: Form ADV Part 2A and Part 2B, SEC registration status and
examination history (as available through Envestnet and/or SEI), Disclosure of any regulatory actions,
sanctions, or disciplinary events
Selection Process (Using Envestnet and/or Morningstar)
Investment Performance Evaluation
The firm assesses: Risk-adjusted performance results, Consistency of returns over relevant market cycles,
Performance attribution to evaluate sources of return
investment philosophy, Research methodology and
Investment Process Review
The firm evaluates: Clarity and consistency of
implementation discipline, Risk management framework and controls.
Best Interest Standard
The firm seeks to ensure that each TPAM recommendation is made in the client’s best interest by: Evaluating
manager fees and overall cost to the client, Disclosing all applicable fees and expenses, Identifying and
mitigating potential conflicts of interest
All TPAM recommendations are presented to the client. The client retains final approval authority and
provides written acknowledgment prior to implementation.
Ongoing Monitoring and Annual Review
The firm conducts ongoing monitoring and, at a minimum, an annual review of each TPAM, which includes:
Performance review relative to stated objectives, benchmarks, and peer groups, Identification of style drift or
strategy deviations, Evaluation of changes in investment strategy or asset allocation, Review of personnel
changes, ownership changes, or organizational developments, Assessment of market outlook and potential
impact on the TPAM’s strategy, Portfolio risk analysis, including returns relative to predefined thresholds -
Periodic fee review, Review of Form ADV updates, amendments, and material disclosures, Evaluation of new
programs and competitive positioning, when applicable.
Manager Termination Protocol
A TPAM may be recommended for termination if the firm identifies material concerns, including but not
limited to sustained underperformance, significant organizational changes, or compliance-related issues.
The termination process includes: Notifying the client via phone and/or email, Providing a clear explanation of
the reasons for the recommended termination, Recommending an alternative manager, when appropriate,
with supporting rationale, Obtaining client approval prior to implementing any changes, Execution of required
documentation, including the SIS change form, signed by the client and the relationship management team.
All actions are documented and retained in accordance with the firm’s recordkeeping policies.
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Part 2B of Form ADV: Brochure Supplements
Supplement 1: Brian P. Beck
Supplement 2: Daniel Friedman
Supplement 3: Christopher Powers
Supplement 4: Jacob P. Sapia
Brochure Supplements
Item 1: Cover Page
Brian P. Beck
Daniel Friedman
Christopher Powers
Jacob P. Sapia, CFP®
Wealth Management Group of North America LLC dba: WMGNA, LLC
10 Talcott Notch Rd, Suite 103
Farmington, CT 06032
April 2026
This brochure supplement provides information about the above-listed supervised employees that supplement the
WMGNA LLC brochure. You should have received a copy of that brochure. Please contact Mr. Brian P. Beck at (860) 679-
5255 if you have not received this brochure or if you have any questions about the contents of this supplement.
Professional Designations Used:
Experience - Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as
Ethics - Agree to be bound by CFP Board's Standards of Professional Conduct, a set of documents outlining the ethical and
CERTIFIED FINANCIAL PLANNER (CFP®) and federally registered CFP® (with flame design) marks (collectively, the "CFP®
marks") are professional certification marks granted in the United States by Certified Financial Planner Board of
Standards, Inc. ("CFP Board"). The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other
countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and
(3) ethical requirements that govern professional engagements with clients. Currently, more than 63,000 individuals
have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must
satisfactorily fulfill the following requirements:
•
Education - Complete an advanced college-level course of study addressing the financial planning subject areas that CFP
Board's studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a
Bachelor's Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP
Board's financial planning subject areas include insurance planning and risk management, employee benefits planning, investment
planning, income tax planning, retirement planning, and estate planning;
Examination - Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over a
•
two-day period, includes case studies and client scenarios designed to test one's ability to correctly diagnose financial planning
issues and apply one's knowledge of financial planning to real world circumstances;
•
2,000 hours per year); and
•
practice standards for CFP® professionals.
24
Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the
right to continue to use the CFP® marks:
•
Continuing Education - Complete 30 hours of continuing education hours every two years, including two hours on the Code
of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the
financial planning field; and
•
Ethics - Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require
that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must
provide financial planning services in the best interests of their clients.
25
Item 2: Name, Educational and Business Experience
Name:
Mr. Brian P. Beck
Born: 1967
Education, Certifications & Industry Exams Passed:
Emory University | BBA in Finance and Marketing | 1989
Series 6 | Investment Company Products/Variable Contracts Representative Examination | 1990
Series 63 | Uniform Securities Agent State Law Examination | 1992
Series 7 | General Securities Representative Examination | 1995
Series 24 - General Securities Principal Examination | 1995
Series 65 | Uniform Investment Adviser Law Examination | 1996
Securities Industry Essentials Examination (SIE) | 2018
Insurance License (Lic# 954607) | Life, Health, & Variable Annuity
Financial Services Background for the Preceding Ten Years:
Wealth Management Group of North America, LLC | Managing Member & Investment Advisor | 08/1995 - Present
Arkadios Capital |Registered Representative | 11/2024-Present
Osaic Wealth, Inc.| Registered Representative | 08/2024-11/2024
Triad Advisor, LLC |Registered Representative | 11/2014-08/2024
National Planning Corporation | Investment Adviser & Registered Representative | 04/2009 – 11/2014
LEXCO Wealth Management, Inc. | Investment Advisor | 04/2009 – 01/2013
Securities America, Inc. | Registered Representative | 02/2003 – 04/2009
Securities Service Network | Registered Representative | 09/1995 – 02/2003
Item 3: Disciplinary Information
As an Investment Advisor Representative, you are required to disclose all material fact regarding any legal or disciplinary
events that would be material in your evaluation.
Mr. Brian P. Beck has never been the subject of an administrative or self-regulatory organization proceeding; or any
other hearing or formal adjudication regarding a professional attainment, designation or license.
For more information about Mr. Brian P. Beck, please visit FINRA’s Broker Check at www.finra.org/brokercheckand/or
the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov.
Item 4: Other Business Activities
Mr. Brian P. Beck is not actively engaged in any other investment advisory - related business or occupation at this time
(other than WMGNA, LLC).
Mr. Brian P. Beck has an active insurance license.
Item 5: Additional Compensation
Mr. Brian P. Beck does not receive any economic benefit from any person, company, or organization in the investment
advisory industry, outside of WMGNA, LLC.
Mr. Brian P. Beck has an active insurance license that allows him to discuss/offer/sell insurance products for
compensation.
Item 6: Supervision
As the Chief Compliance Officer (CCO) of WMGNA LLC, Mr. Brian P. Beck is responsible for the supervision of all
investment adviser representatives of WMGNA LLC. His contact information is on the cover page of this disclosure
document. Mr. Brian P. Beck adheres to all required regulations regarding the activities of an Investment Adviser
26
Representative and follows all policies and procedures outlined in the firm’s policies and procedures manual, the firms
compliance manual, including the code of ethics, and applicable securities regulatory requirements.
27
Item 2: Name, Educational and Business Experience
Name:
Mr. Daniel Friedman
Born: 1964
Education, Certifications & Industry Exams Passed:
Denison University | BA in Liberal Arts | 1986
Series 6 | Investment Company Products/Variable Contracts Representative Examination | 1990
Series 65 | Uniform Investment Adviser Law Examination | 1997
Series 63 | Uniform Securities Agent State Law Examination | 2004
Securities Industry Essentials Examination (SIE) | 2017
Insurance License | Life, Health, & Variable Annuity
Financial Services Background for the Preceding Ten Years:
Wealth Management Group of North America, LLC | Managing Member & Investment Advisor | 07/1996 – Present
Arkadios Capital |Registered Representative | 11/2024-Present
Osaic Wealth, Inc.| Registered Representative | 08/2024-11/2024
Triad Advisor, LLC |Registered Representative | 10/2019-08/2024
National Planning Corporation | Investment Adviser & Registered Representative | 04/2009 – 11/2014
LEXCO Wealth Management, Inc | Investment Advisor | 04/2009 – 01/2013
Securities America, Inc. | Registered Representative | 02/2003 – 04/2009
Securities Service Network | Registered Representative | 07/1996 – 02/2003
Item 3: Disciplinary Information
As an Investment Advisor Representative, you are required to disclose all material facts regarding any legal or
disciplinary events that would be material in your evaluation.
Mr. Daniel Friedman has never been the subject of an administrative or self-regulatory organization proceeding; or any
other hearing or formal adjudication regarding a professional attainment, designation or license.
For more information about Mr. Daniel Friedman, please visit FINRA’s Broker Check at
www.finra.org/brokercheckand/or the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov.
Item 4: Other Business Activities
Mr. Daniel Friedman is not actively engaged in any other investment advisory - related business or occupation at this
time (other than WMGNA, LLC).
Item 5: Additional Compensation
Mr. Daniel Friedman does not receive any economic benefit from any person, company, or organization in the
investment advisory industry, outside of WMGNA, LLC.
Item 6: Supervision
Mr. Daniel Friedman is supervised by WMGNA LLC ‘s Chief Compliance Officer (CCO), Mr. Brian P. Beck. Mr. Brian P.
Beck is responsible for the supervision of all investment adviser representatives of WMGNA LLC. His contact information
is on the cover page of this disclosure document. Mr. Brian P. Beck adheres to all required regulations regarding the
activities of an Investment Adviser Representative and follows all policies and procedures outlined in the firm’s policies
and procedures manual, the firm’s compliance manual, including the code of ethics, and applicable securities regulatory
requirements.
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Item 2: Name, Educational and Business Experience
Name:
Mr. Christopher Powers
Born: 1969
Education, Certifications & Industry Exams Passed:
Bentley University | Bachelor of Science in Finance | 1994
Series 7 | General Securities Representative Exam (GSRE) | 1995
Series 63 | Uniform Agent State Law Examination | 1995
Series 65 | Uniform Investment Adviser Law Examination | 1995
Series 31 | Futures Managed Funds Exam | 2009
Financial Services Background for the Preceding Ten Years:
Wealth Management Group of North America LLC | Managing Member & Investment Advisor | 09/2018 – Present
Arkadios Capital |Registered Representative | 11/2024-present
Osaic Wealth, Inc.| Registered Representative | 08/2024-11/2024
Triad Advisor, LLC |Registered Representative | 10/2019-08/2024
RBC Wealth Management | Senior Vice President | 11/2005 – 06/2018
Advest Inc. | Vice President | 09/1995 – 11/2005
Item 3: Disciplinary Information
As an Investment Advisor Representative, you are required to disclose all material fact regarding any legal or disciplinary
events that would be material in your evaluation.
Mr. Powers was discharged from RBC Capital Markets, LLC on 06/25/2018. This disclosure event involved a situation
where Mr. Powers was discharged after allegations were made that Mr. Powers was not fully forthcoming in connection
with an internal review resulting from a FINRA inquiry. For more information about Mr. Christopher Powers please
search CRD #2578640, please visit and search FINRA’s Broker Check tool located at www.finra.org/brokercheckand/or
the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov.
Item 4: Other Business Activities
Mr. Christopher Powers is not actively engaged in any other investment advisory - related business or occupation at this
time (other than WMGNA, LLC).
Mr. Christopher Powers has an active insurance license.
Item 5: Additional Compensation
Mr. Christopher Powers does not receive any economic benefit from any person, company, or organization in the
investment advisory industry, outside of WMGNA, LLC.
Mr. Christopher Powers has an active insurance license that allows him to discuss/offer/sell insurance products for
compensation.
Item 6: Supervision
As the Chief Compliance Officer (CCO) of WMGNA LLC, Mr. Brian Beck is responsible for the supervision of all investment
adviser representatives of WMGNA LLC. His contact information is on the cover page of this disclosure document. Mr.
Christopher Powers adheres to all required regulations regarding the activities of an Investment Adviser Representative
and follows all policies and procedures outlined in the firm’s policies and procedures manual, the firms compliance
manual, including the code of ethics, and applicable securities regulatory requirements.
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Item 2: Name, Educational and Business Experience
Name:
Mr. Jacob Paul Sapia, CFP®
Born: 1998
Education, Certifications & Industry Exams Passed:
Roger Williams University | Bachelor of Science in Economics | 2020
Professional Designation: Chartered Financial Planner® (CFP®)
Series 66 | Uniform Investment Adviser Law Examination | 12/2020
Series 7 | General Securities Representative Exam (GSRE) | 11/2020
SIE | Securities Industry Essentials Examination (SIE) | 09/2020
Financial Services Background for the Preceding Ten Years:
Wealth Management Group of North America LLC | Managing Member & Investment Advisor | 08/2024 – Present
Arkadios Capital |Registered Representative | 11/2024-present
Pruco Securities, LLC | Financial Planner | 11/2020 – 07/2024
Item 3: Disciplinary Information
As an Investment Advisor Representative, you are required to disclose all material facts regarding any legal or
disciplinary events that would be material in your evaluation.
Mr. Jacob P. Sapia has never been the subject of an administrative or self-regulatory organization proceeding; or any
other hearing or formal adjudication regarding a professional attainment, designation or license.
For more information about Mr. Jacob P. Sapia, please visit FINRA’s Broker Check at www.finra.org/brokercheckand/or
the SEC’s Investment Advisor Search at www.adviserinfo.sec.gov.
Item 4: Other Business Activities
Mr. Jacob P. Sapia is not actively engaged in any other investment advisory - related business or occupation at this time
(other than WMGNA, LLC).
Mr. Jacob P. Sapia has an active insurance license.
Item 5: Additional Compensation
Mr. Jacob P. Sapia does not receive any economic benefit from any person, company, or organization in the investment
advisory industry, outside of WMGNA, LLC.
Mr. Jacob P. Sapia has an active insurance license that allows him to discuss/offer/sell insurance products for
compensation.
Item 6: Supervision
As the Chief Compliance Officer (CCO) of WMGNA LLC, Mr. Brian Beck is responsible for the supervision of all investment
adviser representatives of WMGNA LLC. His contact information is on the cover page of this disclosure document. Mr.
Jacob P. Sapia adheres to all required regulations regarding the activities of an Investment Adviser Representative and
follows all policies and procedures outlined in the firm’s policies and procedures manual, the firm’s compliance manual,
including the code of ethics, and applicable securities regulatory requirements.
30