Overview
- Headquarters
- Schaumburg, IL
- Total Firm Assets
- $1.0 billion
- Average High-Net-Worth Client Portfolio Size
- $5.2 million
- Minimum Account Size
- $25,000
Fee Structure
Primary Fee Schedule (WORLD EQUITY GROUP ADV PART II A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $100,000 | 2.75% |
| $100,001 | $250,000 | 2.00% |
| $250,001 | $500,000 | 1.50% |
| $500,001 | $1,000,000 | 1.35% |
| $1,000,001 | $3,000,000 | 1.25% |
| $3,000,001 | and above | 1.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $16,250 | 1.62% |
| $5 million | $61,250 | 1.22% |
| $10 million | $111,250 | 1.11% |
| $50 million | $511,250 | 1.02% |
| $100 million | $1,011,250 | 1.01% |
Clients
- High-Net-Worth Share of Firm Assets
- 63.62%
- Number of High-Net-Worth Clients
- 122
- Total Client Accounts
- 2,999
- Discretionary Accounts
- 2,887
- Non-Discretionary Accounts
- 112
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 29087
Additional Brochure: REP MANAGER PROGRAM WRAP FEE BROCHURE (2026-06-09)
View Document Text
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AAAPPPPPPEEENNNDDDIIIXXX 111
WWWRRRAAAPPP FFFEEEEEE PPPRRROOOGGGRRRAAAMMM BBBRRROOOCCCHHHUUURRREEE
Offered by:
World Equity Group, Inc.
425 N Martingale Rd, Suite 1220
Schaumburg IL 60173
847-342-1700 (phone)
847-342-5056 (fax)
www.worldequitygroup.com
compliance@weg1.com
FIRM CRD/ IARD # 29087
SEC FILE # 801-56328
This wrap fee program brochure provides clients with information about the qualifications and
business practices of World Equity Group, Inc. and its Reps Choice Money Management Program
that should be considered before investing. If you have any questions about the contents of this
brochure, please contact us at (847) 342-1700 or compliance@weg1.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.
This brochure is given to program clients in addition to Form ADV Part 2. Form ADV Part 2
includes information that is not included in this brochure. Please review both documents carefully.
DATED JUNE 9,
2026
www.adviserinfo.sec.gov.
MMMAAATTTEEERRRIIIAAALLL CCCHHHAAANNNGGGEEESSS
he SEC adopted "Amendments to Form ADV" in July, 2010. This firm brochure is the disclosure
document prepared according to the SEC's new requirement and rules.
After our initial filing of this Wrap Brochure, World Equity Group, Inc. ("WEG") will periodically
provide Clients with a summary of new and/or updated information. WEG will inform clients of
specific changes based on the content of the updated information.
Consistent with the new rules, WEG will provide clients a summary of any material changes to this
and subsequent Wrap Brochures within 120 days of the close of our business' fiscal year ending
12/31. WEG will inform Clients of specific changes based on the content of the updated information.
Additionally, WEG will provide clients with other interim disclosures about material changes as may
be necessary.
This section only describes any material changes made to this brochure since the last update. The
last brochure was dated March 31, 2017. There have been two material changes. On or about May 2020,
WEG was purchased by Wentworth Management Services, LLC, a private company majority owned
indirectly by Alex Markowitz. A further change of ownership occurred on or about March 2024, as WEG
became a subsidiary of Binah Capital Group, Inc., a public company listed on NASDAQ under the
symbol BCG.
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 2 OF 11
Reps Choice Money Management
ADV Part 2A Appendix 1
Wrap Fee Program Brochure
6/30/2024
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SERVICES AND PROGRAMS.......................................................................................................................................... 4
FEES AND COMPENSATION .......................................................................................................................................... 5
ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................................................................ 7
PORTFOLIO MANAGER SELECTION AND EVALUATION ................................................................................... 7
CLIENT CONTACT & INFORMATION PROVIDED TO PORTFOLIO MANAGERS ........................................ 8
Code of Ethics…………………………………………………………………………………….8
Other Financial Industry Activities……………………………………………………………..9
ADDITIONAL INFORMATION ....................................................................................................................................... 9
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 3 OF 11
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World Equity Group (WEG) is a Registered Investment Advisor1 whose focus is to assist clients and their
families, business entities, non-profits and other financial institutions with investment planning and
management. WEG provides a variety of investment management services including actively managed
equity and bond market participation programs, asset allocation programs, customized programs and
financial planning services.
The Reps Choice Money Management Program is a separately managed account program sponsored by
WEG. Pursuant to the program, an Investment Advisor Representative associated with WEG, or
associated with an investment advisory firm who has been provided access to the Reps Choice Money
Management Program, assists clients with the allocation of funds among portfolio managers available in
the program. The allocation is based on the personal and financial data and investment objectives
provided by the client. In all cases, the selection of portfolio managers is made by the client. Funds
allocated to each portfolio manager will be held in a separate sub-account. Portfolio managers will have
authority to invest and reinvest the funds on a discretionary basis, in accordance with a model or
investment strategy maintained by the portfolio manager. Portfolio managers will invest only in
accordance with their model. In some cases involving mutual funds, the portfolio manager will provide a
signal to WEG, who will have limited discretion to invest the sub-account in accordance with the signal.
WEG will not have discretion to reallocate funds among accounts, but funds may be reallocated by the
client at any time.
This brochure is given to clients in addition to the Form ADV Part 2 Disclosure Brochure provided
by each program. The Form ADV Part 2 includes information that is not included in this brochure.
Please review both documents carefully. The Form ADV Part 2 should be given for each program
selected and each program is managed by an outside investment advisor that is not affiliated with WEG.
The ADV Part 2 Disclosure Brochure is available through your Investment Advisor Representative or by
contacting World Equity Group.
Managed accounts available under the Reps Choice Money Management Program include:
QFA, LLC.
Enhanced Income ETF Portfolio
TF Portfolio utilizes a diversified portfolio of Exchange Traded Funds
(ETFs). The dynamic ETF allocation is designed to achieve positive risk adjusted returns. An inverse
position is included that is expected to go up if the market goes down. In addition, QFA adds a thirty-day
covered call overlay to the ETF portfolio to enhance income. Selling covered calls is a strategy for
generating monthly cash flow while attempting to reduce downside risk.
VAN HULZEN ASSET MANAGEMENT
Covered Call Strategy
-
gy, investing in large cap equities and using
conservative option contracts to add additional yield and hedge downside exposure. The objective is to
out-perform the broad equity index (S&P 500 on a risk adjusted basis) over the long run while also
providing protection during market declines.
effectively trading a portion of the uncertain price appreciation of their holdings in return for much more
certain current period income.
tal screening criterion for securities focuses on
long term value creation and consistent cash flow returns.
1
Registered Investment A
d States Securities &
Exchange Commission and with such other regulatory agencies that may have limited regulatory jurisdiction over our business practices.
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 4 OF 11
SERVICES AND PROGRAMS
IRON FINANCIAL
Options Overlay Global Equity Strategy
Iron Financial s Options Overlay Global Equity Strategy Portfolio is comprised of equity index exchange
traded funds (ETFs) representing the global equities (US, developed, and emerging markets). Call options
are written on each of these ETFs and the written options are managed actively to generate incremental
returns on a risk-adjusted basis.
The strategy utilizes a systematic approach in selecting options with appropriate time to expiration and
probability of the option being called away. The written option positions are actively managed through
the use of IRON's proprietary roll strategies; the highlights include:
A majority of option positions are selected with time to expiration of 30 to 60 days
Options are selected with a low probability of expiring in the money
Targeted options carry relatively higher premiums that potentially contributes to additional
income consummate with the assumed options' volatility risk
The strategy makes no attempt to utilize additional leverage through the number of option
contracts
Determining when NOT to write options based on rigorous monitoring of market conditions and
their impact on the portfolio - example, when the option exercise probabilities sufficiently rise
with a rapidly rising market.
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on the
Reps Choice
value of all securities in the account.
These fees include advisory services of Portfolio Managers, as well as execution and custody. In addition
to these fees, Client may also incur other charges, including (i) any dealer markups or markdowns and
odd-lot differentials, SEC imposed fees and transfer taxes, (ii) charges imposed by broker-dealers other
than the firm, (iii) offering discounts, concessions, commissions and related fees in connection with
underwritten public offerings of securities, (iv) margin interest and operational fees and charges, (v) IRA
fees, (vi) any redemption fees, exchange fees or similar fees imposed in connection with mutual fund
expenses,
. All assets are held through a WEG
account, which is held in custody with TD Ameritrade Institutional, a division of TD Ameritrade, Inc.,
member FINRA/SIPC, 4211 South 102nd St., Omah
WEG Fee
Total Annual Fee
Assets Under
Management
Representative
Recommended Fee
$25,000 - $249,999.99
1.15%
1.25%
2.40%
$250,000 - $999,999.99
1.00%
1.00%
2.00%
$1,000,000+
.85%
.85%
1.70%
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 5 OF 11
FEES AND COMPENSATION
Fees are negotiable depending on the relationship and size of the account. All fees are paid quarterly in
advance. Fees will be prorated and the unearned portion returned upon written termination.
The Reps Choice Program may cost the client more or less than the client would pay if investment advice,
brokerage and other services were purchased separately. Program clients should consider the value of
these services when making comparisons. The combination of services may not be available separately or
may require multiple accounts, documentation and fees. In addition, certain portfolio managers may not
be available to certain clients outside the Reps Choice relationship either because of minimum account
sizes, fee schedules, geographic availability or other factors. Program clients should also consider the
amount of anticipated trading activity when selecting among programs and assessing the overall cost.
Fee-based programs typically assume a normal amount of trading activity and, therefore, under particular
circumstances, prolonged periods of inactivity or asset allocations with significant fixed income or cash
weightings may result in higher compensation than if commissions were paid separately for each
transaction.
The Investment Advisor Representative or advisory firm who recommends the Reps Choice Money
program. The
Management Program receives compensation as a result of a c
amount of this compensation may be more than what the advisory representative would receive if the
program client paid separately for investment advice, brokerage and other services. The Investment
Advisor Representative or advisory firm may therefore have a financial incentive to recommend the
program over other programs and services. WEG uses external portfolio managers and they receive
between 1/3 and 1/2 of the WEG advisory fee.
OTHER FEES
The annual fee rates indicated under each of the Reps Choice programs are all inclusive, wrapping both
brokerage and advisory fees into one. However, the asset-based fee does not pay for any of the
following: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges,
including electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-
lot differentials and mutual fund short-term redemption fees; and (iii) brokerage and execution costs
associated with non-eligible assets held in your account or with securities and other property held outside
of your managed account.
In addition, all fees paid to us for management services are separate from any fees and expenses charged
to shareholders of mutual fund shares by the investment company or by the investment advisor managing
the mutual fund portfolios. These expenses generally include management fees and various fund
expenses such as: 12b-1 fees, redemption fees, account fees, purchase fees, contingent deferred sales
charges, and other sales load charges may occur but are the exception within managed accounts at
institutional custodians. A complete explanation of these expenses charged by the mutual funds is
You are encouraged to carefully read the fund prospectus.
A client may invest in a money market fund or mutual funds directly without incurring the fee charged for
participation in the program. In addition, for certain accounts that hold a high percentage of investments
in money market or mutual funds, other advisory programs may be available through WEG for lower
advisory or other fees. Any non-sweep money market funds held in the account will be subject to
program fees. Program clients will receive a prospectus for each money market and mutual fund
purchased.
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 6 OF 11
FEES AND COMPENSATION
Certain ETFs pay advisory fees to their investment advisors, which reduces the net asset value of the
fund. Some ETFs are organized as unit investment trusts and do not have an investment advisor.
However, all ETFs do incur expenses related to their management and administration that are analogous
These expenses affect the value of the investment.
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WEG generally provides investment advice to individuals, pension and/or profit sharing plans, trusts,
estates, charitable organizations, corporations and other business entities. Requirements for opening an
account vary depending on the program selected. The account manager may, at their discretion, accept
accounts below the minimum required amount.
The minimum initial investment for each manager offered is:
Portfolio Manager
Required Minimum
QFA, LLC. - Enhanced Income ETF Portfolio
$100,000
Van Hulzen Asset Management Covered Call Strategy
$500,000
Iron Financial, LLC - Options Overlay Global Equity Strategies
$100,000
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Portfolio managers are selected for the program based primarily on their model, risk management
discipline, performance, and how the model fits with other models in the program. Additional reviews
and considerations include legal and regulatory background checks, interviews and meetings with
program managers, and inquiries to ensure compliance with regulatory standards. WEG reviews manager
performance information annually.
WEG may provide information to the client regarding the retention or replacement of the portfolio
manager if the manager changes its management style or t
WEG may
replace managers in the program if the model is changed or WEG believes another manager would be
more appropriate for the program.
needs, risk tolerance and goals. The Investment Advisor Representative assists the clients in selecting
appropriate managers based upon the specific needs of each client.
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 7 OF 11
PORTFOLIO MANAGER SELECTION AND EVALUATION
Neither WEG nor any Investment Advisor Representative associated with WEG assumes responsibility
for the conduct of unaffiliated portfolio managers, including their performance, performance reporting, or
compliance with laws or regulations. Neither WEG, nor any third party, independently verifies the
performance information provided to determine its accuracy or compliance with presentation standards.
Performance information may not be calculated on a uniform and consistent basis. Program clients are
(b) there are market and/or interest rate risk which may adversely aff
selections provided for accounts are guidelines only; there is no guarantee that they will be met or
exceeded. Once funds are allocated to a manager, the manager will manage the funds solely in
accordance with the model.
The portfolio manager option available under the program are unaffiliated Registered Investment
Advisors.
FREQUENCY AND NATURE OF REVIEWS
World Equity Group Investment Advisor Representatives review client accounts on an ongoing basis.
Representatives also may conduct more thorough reviews annually or quarterly, depending on the
program. WEG supervisory personnel conduct reviews to evaluate consistency of performance compared
REPORTS PROVIDED TO CLIENTS
Clients receive a quarterly performance evaluation, a monthly activity summary statement, confirmation
of all transactions as they occur, and a year-end tax summary. All reports are provided in writing.
Additional reports may be provided depending on the program and at the request of the client. All
account statements are sent to the client directly from the custodian.
CODE OF ETHICS, PARTICIPATION OR
INTEREST IN CLIENT TRANSACTIONS, &
PERSONAL TRADING
In accordance with SEC Rule 204a-1 of the Investment Advisers Act of 1940, the firm maintains and
enforces a Code of Ethics. The Code requires employee reporting of all securities holdings and
transactions and requires prior pre-clearance from the firm’s Chief Compliance Officer for certain
securities transactions. The Code contains requirements regarding employee compliance with all
Laws, Rules and Regulations, and it contains provisions for reporting violations of the Code to the
firm’s Chief Compliance Officer. All WEG investment advisor representatives are expected to be
honest and ethical, make full and accurate disclosures, remain in compliance with all applicable rules
and regulations, and be accountable for what they do.
WEG and your investment advisor representative act as fiduciaries for you. We have a duty to act in
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 8 OF 11
your best interests at all times.
WEG and/ or its investment advisory representatives may at any time own or invest in the same
securities it recommends to clients. All employees and IARs of WEG are required to submit to the
WEG compliance department duplicate copies of all trades and account statements for review. WEG
does not allow any IAR or employee to trade ahead of their clients. For individual securities such as
stocks and bonds, client orders are placed first or block traded where an average price is used.
To review a copy of the firm’s Code of Ethics, please make a written request to your investment
advisor representative, contact WEG toll free at 800-765-5004, or email compliance@weg1.com.
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PPPRRROOOVVVIIIDDDEEEDDD TTTOOO PPPOOORRRTTTFFFOOOLLLIIIOOO MMMAAANNNAAAGGGEEERRRSSS
If a client requests a consultation with one of the portfolio managers, the request has to be made to the
Investment Advisor Representative. The Investment Advisor Representative will facilitate the contact
with the manager and schedule either a teleconference or a meeting.
Client information provided to the portfolio managers includes the client s name, address, account
registration status, and contact information. Updated information will be provided to the portfolio
managers as needed and upon material changes.
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AAACCCTTTIIIVVVIIITTTIIIEEESSS &&& AAAFFFFFFIIILLLIIIAAATTTIIIOOONNNSSS
Affiliations
WEG is also registered as a FINRA member broker/dealer. Many Investment Adviser Representatives
("IARs") of WEG are also licensed as registered representatives of WEG’s broker/dealer. Many are
also licensed insurance agents representing various insurance companies. As such, IARs are able to
receive separate, yet customary commission compensation resulting from implementing securities and
insurance product transactions on behalf of investment advisory clients. The clients are not under any
obligation to engage IAR when considering whether to implement any investment advisory
recommendations. The implementation of any or all recommendations is solely at the discretion of the
client.
While WEG and its IARs endeavor at all times to put the interest of the clients first as part of our
fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a
conflict of interest and may affect the judgment of IARs when making recommendations.
Other Outside Business Activities
Some IARs own or are affiliated with other independent Registered Investment Adviser (“RIA”)
firms. These RIA firms are not affiliated with WEG and their activities of are not supervised by
WEG. Fees for financial advisory and planning services provided by the IAR through their own
independent RIA are separate and distinct from any fees paid to WEG in their capacity as an IAR of
WEG.
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 9 OF 11
Certain IARs may have other business activities and offer services, such as tax preparation,
accounting, legal, real estate, employee benefits consulting, or other businesses, that are outside
business activities from their registration as an IAR of WEG. WEG does not supervise or receive
compensation from these other outside business activities. IARs engaging in these other outside
business activities do so independently of their registration with WEG.
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RISKS ASSOCIATED WITH LEVERAGED AND/ OR INVERSE EXCHANGE TRADED FUNDS
Most leveraged Exchange Traded Funds (ETFs) seek to provide a multiple of the investment returns of a
given index or benchmark on a daily basis. Due to the effects of compounding and possible correlation
errors, leveraged ETFs may experience greater losses than one would ordinarily expect. Compounding
can also cause a widening differential between the performances of an ETF and its underlying index or
benchmark, so that returns over periods longer than one day can differ in amount and direction from the
target return of the same period. Consequently, these ETFs may experience losses even in situations
where the underlying index or benchmark has performed as hoped. Some specialized exchange-traded
funds can be subject to additional market risks. Investment returns will fluctuate and are subject to
market volatility, so that an investor's shares, when redeemed or sold, may be worth more or less than
their original cost. In a volatile market, compounding can result in leveraged longer-term returns that are
less than two times the return of the unleveraged investment.
INVESTMENT RISK
All investment strategies involve risk. There is no assurance that a positive return will be obtained in
any managed investment account program. Neither WEG Investment Advisor Representatives nor
portfolio managers guarantee the performance of the account,or promise any specific level of
performance, or promise that investment decisions, strategies or overall management of the account will
be successful. Any investment decisions portfolio managers may make are subject to various market,
currency, economic, political, interest rate and business risks, will not necessarily be profitable, and are
subject to investment risk, including possible loss of principal.
DISCIPLINARY INFORMATION
On August 23, 2018, World Equity Group signed a letter of Acceptance, Waiver and Consent ("AWC")
with FINRA agreeing to a $100,000 fine and was ordered to pay restitution in the amount of not less than
$380,000 to customers who purchased L-share class variable annuity contracts with long-term income
riders from the period of June I, 2013 through May 31, 2018. Additionally, from the period of April 2013
through March of 2017, the firm failed to establish, maintain and enforce a supervisory system and
written supervisory procedures reasonably designed to ensure that representatives' recommendation of
variable annuities complied with applicable securities laws and regulations and FINRA rules.
On March 1, 2017, World Equity Group signed a letter of Acceptance, Waiver and Consent ("AWC")
with FINRA and was censured and fined $15,000 for failing to report 83 TRACE Eligible corporate debt
securities transaction within the time frame required by FINRA Rule 6730.
On April 25, 2016, World Equity Group signed a letter of Acceptance, Waiver and Consent ("AWC")
with FINRA and was censured and fined $50,000. WEG failed to establish and maintain a supervisory
program designed to identify and prevent potentially unsuitable excessive trading of equity securities.
On February 3, 2015, World Equity Group signed a letter of Acceptance, Waiver and Consent with
FINRA and was censured and fined $225,000. WEG failed to implement a reasonably designed
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 10 OF 11
supervisory procedures regarding Anti-Money Laundering ("AML"), email retention, customer
dueiligence, trading non-traditional Exchange Traded Funds ("ETFs"), private placement due diligence,
non-traded Real Estate Investment Trusts ("REITs") due diligence, and house account supervision.
On September 25, 2014, World Equity Group signed a letter of Acceptance, Waiver and Consent
("A WC") with FINRA and censured and fined $7,500 for failing to report transactions in the Trade
Reporting and Compliance Engine ("TRACE") for Eligible Securitized Products to TRACE within the
time period required by Rule 6730.
On December 12, 2011, World Equity Group signed a letter of Acceptance, Waiver and Consent
(" AWC") with FINRA and was censured and fined $15,000. For failing to transmit all of its reportable
order events to the Order Audit Trail System ("OATS") for more than a year. The firm did not qualify for
exclusion from the OATS reporting requirements because it routed its orders through more than a single
reporting member.
On December 13, 2011, World Equity Group and Mr. Richard Babjak, President and an owner of WEG,
signed a letter of Acceptance, Waiver and Consent ("A WC") where the firm and Mr. Babjak were fined
and censured $50,000 jointly and severally. The A WC alleged specific deficiencies in regard to the
supervision of advertisements, communications with the public, licensing and registration occurring
between December 2007 and November 2008 and involved the supervision of advertising activities of one
representative relative to non-securities insurance products. The A WC was signed to settle the alleged
rules violations and was consented to without admitting or denying the findings. WEG and Mr. Babjak
were censured and fined jointly and severally. WEG and Mr. Babjak worked cooperatively and
proactively with FINRA in connection with the issues and the AWC.
On November 22, 2006, the National Association of Securities Dealers ("NASO") alleged that Mark
Lishchynsky failed to ensure that his previous member firm's offsite FINOP was aware of at least
$31,602.11 worth of liabilities and that the liabilities were properly recorded on the firm's books and
records in violation of NASO Rule 21 IO. Without admitting or denying the findings, Mr. Lishchynsky
consented to the described sanction and to the entry of findings and was fined $5,000. Subsequently, Mr.
Lishchynsky was late with the final payment of the monetary fine and as a result, his license was revoked
until final payment was made. The revocation occurred on June 16, 2009, and was lifted on June 19,
2009.
Additional disciplinary information about the above items can be found on the SEC's website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for WEG is 29087.
END OF DOCUMENT
ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE
PAGE 11 OF 11
Additional Brochure: WORLD EQUITY GROUP ADV PART II A (2026-06-09)
View Document Text
ADV PART 2A-APPENDIX 1
ADHESION MONEY MANAGEMENT
WRAP FEE PROGRAM BROCHURE
World Equity Group, Inc.
425 N Martingale Road Suite 1220
Schaumburg, IL 60173
847-342-1700 (phone)
847-342-5056 (fax)
www.worldequitygroup.com
compliance@weg I .com
FIRM CRD/ IARD # 29087
SEC FILE# 801-56328
This Adhesion Money Management wrap fee program brochure provides clients with information
about the qualifications and business practices of World Equity Group. Inc. that should be
considered before investing in the program. If you have any questions about the contents of this
brochure, please contact us al (847) 342-1700 or compliance@wegl.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.
DATED
June 9, 2026
This brochure is given to program clients in addition to Form ADV Part 2. Form ADV Part 2 includes
information that is not included in this brochure. Please review both documents carefully. Additional
information about World Equity Group also is available on the SEC's website at
www.adviserinfo.sec.gov.
Page 1 of 16
MATERIAL CHANGES
The SEC adopted "Amendments to Form ADV" in July, 2010. This firm brochure is the disclosure
document prepared according to the SEC's new requirements and rules.
After our initial filing of this Wrap Brochure, World Equity Group, Inc. ("WEG") will periodically
provide Clients with a summary of new and/or updated information. WEG will inform clients of specific
changes based on the content of the updated information.
Consistent with the new rules, WEG will provide clients a summary of any material changes to this and
subsequent Wrap Brochures within 120 days of the close of our business' fiscal year ending 12/31. WEG
will inform Clients of specific changes based on the content of the updated information. Additionally,
WEG will provide clients with other interim disclosures about material changes as may be necessary.
This section only describes any material changes made to this brochure since the last update. The last
brochure was dated March 31, 2017. There have been two material changes. On or about May 2020,
WEG was purchased by Wentworth Management Services, LLC, a private company majority owned
indirectly by Alex Markowitz. A further change of ownership occurred on or about March 2024, as WEG
became a subsidiary of Binah Capital Group, Inc., a public company listed on NASDAQ under the
symbol BCG.
Page 2 of 16
SERVICES AND PROGRAMS
World Equity Group, Inc. ("WEG") is registered as a Registered Investment Adviser ("RIA") with the
Securities and Exchange Commission ("SEC") and is also registered as a Broker/Dealer with the SEC and
the Financial Industry Regulatory Authority ("FINRA"). WEG is licensed to conduct business as a
Broker/Dealer and RIA in all 50 states, the District of Columbia, Puerto Rico and the U.S Virgin Islands.
WEG provides fee-based financial planning, and fee-based investment advisory portfolio and asset
management services to help its Clients meet their financial planning and investment goals and
objectives. WEG offers a variety of fee-based investment advisory asset management programs and
services including actively managed stock and bond market portfolios and programs, asset allocation
programs, and fee-based financial planning services.
Adhesion Money Management Wrap Fee Program
This brochure is given to clients in addition to World Equity Group's Form ADV Part 2 Disclosure
Brochure and the IARs Part 2B individual brochure. WEG's Form ADV Part 2 includes additional
information about WEG and its investment advisory business that is not included in this brochure.
Clients should read each document carefully before investing. The Form ADV Part 2 Disclosure Brochure
is
provided to you by your Investment Adviser Representative or by contacting World Equity Group.
A wrap account program is a fee-based investment advisory program that "wraps" all of the fees, charges
and expenses into one managed account. The Adhesion Money Management Program is a separately
managed investment advisory wrap account program that is sponsored by WEG and managed by
Adhesion Wealth Advisor Solutions ("Adhesion" or "Adhesion Program"). Clients' accounts are held at
Schwab & Co, a qualified Custodian. The Adhesion Program uses third-party money managers and the
WEG Investment Adviser Representative ("IAR") to manage the Client's assets in the account as
described in more detail below.
The Investment Adviser Representative ("IAR") will help the client to determine his or her current
financial situation, liquidity needs, goals and investment objectives, risk tolerance, and investment time
horizon. The IAR will use a Risk Tolerance Questionnaire to help determine the Client's investment
objectives, time horizon and tolerance for risk and then recommend an asset allocation portfolio for the
Client in the Adhesion Program.
Portfolios may be invested in mutual funds, Exchange Traded Funds ("ETFs"), stocks, bonds and other
securities either through models created by the third-party money managers or through individual
mutual funds and ETFs recommended by the IAR.
IARs may use a variety of methods to analyze a client's situation as well as economic factors to develop
investment advice and recommendations. These methods include charting, fundamental analysis,
technical analysis, cyclical analysis, quantitative analysis, qualitative analysis, and asset allocation. The IAR
will inform clients of their methods of analysis, sources of information, and investment strategies used by
the IAR in managing the Clients' accounts. The Client may impose reasonable restrictions on
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investing in certain types of securities or industry sectors in the Adhesion Program, provided however
that WEG may refuse to accept or continue to provide investment advisory services to the client if WEG
determines such restrictions are unreasonable or impracticable.
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The third-party money managers are granted discretionary authority by the Client to invest, allocate and
rebalance the Client's account as the third-party money manager deems necessary in accordance with an
investment model created and maintained by the third-party money manager. WEG IARs will also be
granted discretion by the Client to invest, allocate and rebalance the Client's account among the selected
third-party money managers or to change third-party money managers, and/or to recommend individual
stocks and bonds, mutual funds and ETFs that are not a part of the third-party money manager's model as
the IAR deems necessary based on prevailing market conditions and volatility, news, economic or
political circumstances, and the individual characteristics and performance of the securities held in the
client's portfolio. Clients may also request that their account be invested a certain way and be allocated or
rebalanced at any time.
As a wrap program, Adhesion includes investment advice, portfolio management, asset allocation,
rebalancing, transaction and execution, and custody all in one account. Adhesion implements trading
instructions received from the third-party money managers. The IAR will execute transactions separately
from the third-party money managers. The Adhesion Program's objective is to diversify the Client's
account through asset allocation, and also manage account rebalancing with a view towards tax
mitigation.
If the positions in the Client's account drift out of balance from the asset allocation model used by the
third-party money manager, the account will be rebalanced as the money manager deems appropriate. The
IAR may also rebalance the account as he or she deems appropriate. Clients may also elect to their
accounts rebalanced on either a quarterly or annual basis through the Periodic Rebalancing option if the
value of the assets in the Client's account in a particular asset allocation category deviates by more than
5% from the selected model. The third-party money manager or the IAR will have discretion to decide
which securities within an asset allocation category need to be purchased or sold. The Client
acknowledges and understands that the purchases and sales of securities will result in a taxable gain or
taxable loss. Unless the Client has elected to have the account managed in a tax-efficient manner as
described below, the Adhesion Program will not consider tax consequences when rebalancing the Client's
account.
If the Client requests tax management, the Adhesion Program will manage the assets in the Client's
account with the strategy to help minimize the potential tax consequences that would be the result of
realizing short-term capital gains in the Client's account. The Tax Overlay Management option is
available for an additional asset-based investment advisory fee. Using the Tax Overlay Management
option may require Adhesion to execute transactions in the Client's account that differ from the
transactions executed in other Clients' accounts where the Tax Overlay Management option has not been
selected. If the Client selects the Tax Overlay Management and the Periodic Rebalancing options,
Adhesion will consider the tax consequences when determining whether and how to rebalance the
positions in the Client's account. The Client understands that if Adhesion determines that the tax
consequences would outweigh the potential benefits of Periodic Rebalancing, the Client's account may
not be rebalanced in accordance with the rebalancing schedule that the Client selected.
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FEES AND COMPENSATION
Client's accounts in the Adhesion Money Management Program are charged an investment advisory
fee for assets under management based on the value of all securities held in the Client's account.
The investment advisory fee covers:
I. The initial analysis and periodic review of the Client's personal financial situation, investment
objectives, time horizon, and risk tolerance by the IAR
2. Discretionary management of the Client's account, asset allocation, rebalancing of the Client's
3.
account by the third-party money manager or the IAR
Investment advisory services, including the investment advisory fees charged by the third-party
money managers and Adhesion
4. Account statements, trade execution and settlement, and custody of the Client's assets.
All account assets are held by WEG's Custodian, Schwab & Co., Inc., member FINRA/SIPC, 1945
Northwestern Drive, El Paso, TX 79912
The annual wrap program investment advisory fee charged to Clients is based on a percentage of the
Custodian's reported value of the assets held within each individual Client's account(s). The total wrap
investment advisory and program fee charged to the Client's account may fluctuate with changes to the
third-party money managers. The total Adhesion Money Management Program wrap fee shall not exceed
250 basis points (2.50%).
The Adhesion Money Management Program investment advisory assets management wrap fee schedule
is as follows:
IARFee
Third-party Money
Manager Fee
WEG
Platform Fee
Client Assets
Under
Management
Optional Tax
Overlay
Management
Fee
.35%
*Varies
Negotiable
.12%
$25k - $75k
$75k- $750k
.30%
*Varies
Negotiable
.12%
$750k+
.27%
*Varies
Negotiable
.08%
* For specific third-party money manager fees, please refer to the third-party money manager's
investment advisory manager's fee, which is disclosed in the Adhesion Money Management Program's
Agreement.
For accounts under $50,000, the Adhesion Program offers an Exchange Traded Funds ("ETFs") Select
Model portfolio. The Select Model portfolio offers access to institutionally priced ETFs.
The fee schedule for the ETF Select model is as follows:
Assets Under Management
Annual Fee
$25,000 to $50,000
1.5%
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Fees are negotiable between the Client and IAR. All investment advisory and manager program fees are
paid quarterly in advance. If the Client makes a written request to WEG to terminate the Adhesion
Program agreement, the investment advisory and program fees will be prorated based on the termination
date and the unearned portion of the fees will be returned to the Client.
The Adhesion Money Management Program may cost the Client more or less than the Client would pay if
the investment advice, transaction and execution charges, and the account fees and charges for other
services were purchased separately. Adhesion Program Clients should consider and evaluate the value of
the Adhesion Program wrap account fees and costs and the services provided when making comparisons
to other programs. The combination of the services provided in the Adhesion Program may or may not be
available separately with other programs or the other options may require opening multiple accounts and
they may charge separate fees. Certain third-party money managers may not be available individually to
Clients outside the Adhesion Program because of minimum account sizes, fee schedules, geographic
availability or other factors. Adhesion Program Clients should also consider and evaluate the amount of
trading activity expected when selecting among different programs and assess the overall cost. Fee-based
investment advisory programs typically assume a certain amount of trading activity in the Client's
account. Therefore, prolonged periods of holding cash positions, limited trading activity and inactivity or
limited asset rebalancing which generally occur with holding individual bond positions may result in
higher fees than if the account was not holding cash positions and/or if the bonds were executed on a
commission basis separately for each transaction.
WEG and its JAR who recommends the Adhesion Money Management Program receives a part of the
investment advisory fees as a result of a Client's participation in the Adhesion Program. The amount of
the investment advisory fees received may be more than what WEG and its IAR, would receive if the
Adhesion Client paid separately for investment advice, transaction and execution charges and other
services. Therefore, the WEG and its IAR have a financial incentive and a conflict of interest to
recommend the Adhesion Program over other programs and services.
WEG may use both Compass, an affiliated internal money manager and/or third-party money managers
for the Adhesion Program. Each money manager receives a portion of the WEG investment advisory fee.
The use or non-use of Compass or third-party money managers does not change the amount charged by
the IAR or the investment advisory fee charged by WEG to the Client.
OTHER FEES
The annual investment advisory fee percentages shown under the Adhesion Program is all inclusive,
wrapping transaction and execution costs, investment advisory fees and other fees and charges into one
account. However, the Adhesion Program investment advisory fee does not pay for any of the following:
1. any stock exchange or SEC fees;
2.
3.
certain transfer taxes;
service or account charges, including electronic fund and wire transfer fees, auction fees, debit
balances, margin interest, certain odd-lot differentials and mutual fund short-term redemption
fees; and
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4.
transaction and execution costs associated with non-eligible assets held in the Client's account or with
securities and other property held outside of the Client's Adhesion Program managed account.
All investment advisory fees paid to WEG for management services are separate from any fees, charges and
expenses that are charged to shareholders of mutual fund shares by the investment company or by third-
party investment advisers managing the mutual fund portfolios. These expenses generally include fund
management fees and other fund expenses, including, but not limited to: l 2b- l fees, redemption fees, account
maintenance fees, sales load charges, contingent deferred sales charges, and other miscellaneous fees. A
complete explanation of these charges and expenses is contained in each mutual fund's prospectus. Clients
should read the prospectus carefully prior to investing.
A Client could invest in a money market fund or mutual funds directly without incurring the investment
advisory fees charged for participation in the Adhesion program. In addition, for certain accounts that may
hold a high percentage of the portfolio in money market or mutual funds, other investment advisory programs
may be available through WEG for a lower investment advisory fee or it may cost less to purchase mutual
funds on a commission basis in a commission-based brokerage account or the mutual funds may be able to be
purchased at Net Asset Value ("NAV"). Adhesion Program Clients will receive a current prospectus for each
money market and mutual fund purchased.
Exchange Traded Funds and Mutual Funds
Shares of Exchange Traded Funds ("ETFs") held in client accounts are purchased and sold directly on one of
the stock exchanges unlike open-end mutual funds, which are purchased and sold directly from the mutual
fund company. The price of ETFs shares will fluctuate with market conditions affecting the underlying Net
Asset Value ("NAV") per share value of the ETFs. Therefore, ETFs shares will trade at a discount or at a
premium to their NAVon a daily basis.
All fees paid to WEG for investment advisory services are separate and distinct from the fees and expenses
that may be charged by ETFs or mutual funds to their shareholders. These fees and expenses are described in
each ETFs or mutual fund's prospectus. Therefore, the Client should review both the fees charged by the ETFs,
mutual funds and WEG fees carefully to fully understand the total amount of fees that will be paid by the
Client.
Certain ETFs pay investment advisory fees to the Investment Advisers, which reduces the NAV of the ETFs.
Unit Investment Trusts ("UITs") often have fixed portfolios that are not actively traded or managed by the
third-party money manager. However, all ETFs and UITs do incur charges and expenses related to the
management and administration of the ETF or UITs. The charges and expenses are deducted from the ETFs
and UITs, and therefore they affect the overall return of the investment.
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ACCOUNT REQUIREMENTS AND
TYPES OF CLIENTS
WEG primarily provides investment advice and investment advisory services to individuals, pension and/
or profit-sharing plans, trusts, estates, charitable organizations, corporations and other business entities.
Requirements for opening an account vary depending on the investment advisory program selected, but
WEG generally has minimum account size requirements of between $25,000 and $100,000 depending on
type of program. The third-party money managers may at their discretion accept accounts below the
minimum required amount. Account minimums are discussed in more detail in each third-party money
manager's Form ADV or other disclosure document.
PORTFOLIO MANAGER
SELECTION AND EVALUATION
Third-party money managers are selected for the Adhesion Program based primarily on their specific type
of investment model, strategy, risk management discipline, performance, and how the model aligns with
other models in the Adhesion Program. Additional considerations on whether to include a manager in the
Adhesion Program are based on passing due diligence, legal and regulatory background checks, through
interviews and meetings with the third-party money manager, and verifying compliance with regulatory
standards. WEG reviews manager performance data at least annually.
The WEG sponsored Adhesion Money Management Program provides our Investment Adviser
Representatives with access to third-party investment advisory services offered by various turnkey asset
management providers and third-party managed account providers. For more information regarding each
third-party money manager, please refer to the third-party money manager's Form ADV or other
disclosure document.
WEG may provide information to the Client regarding the retention or replacement of a certain third-
party money manager if the manager changes its management style or if the Client's financial situation,
investment objectives, time horizon and/or risk tolerance changes. WEG may replace managers in the
Adhesion Program if the manager's model is changed or WEG believes another manager would be more
appropriate for the Adhesion Program.
Each Client has the ability to change between the managers based upon the Client's stated specific
investment objectives, time horizon, risk tolerance and goals. The IAR assists the Client in selecting
appropriate managers based upon the specific financial situation and needs of the Client.
Neither WEG or any or its IARs assumes responsibility for the unaffiliated third-party money managers,
including their performance, performance reporting, or compliance with laws or regulations. Neither
WEG, or any third party independently verifies the performance information provided by the third-party
money managers to determine its accuracy or compliance with presentation standards. Performance
information may not be calculated on a uniform and consistent basis. Adhesion Program Clients are
advised and should understand that:
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(a) such manager's past performance is no guarantee of future results;
(b) there are market and/or interest rate risks which may adversely affect any manager's objectives and
strategies and could cause a loss in a client's account, and
(c) any risk parameters or comparative index selections provided for accounts are guidelines only; there is
no guarantee that they will be met or exceeded. Once funds are allocated to a manager, the manager will
manage the funds in accordance with its model.
All third-party money manager options available under the program are Registered Investment Advisers
that are unaffiliated with WEG. The Compass program is also available outside of the Adhesion Program.
However, if the Client chooses to use Compass outside of the Adhesion Program, the Client will not
receive other benefits of the Adhesion Program, including the ability to allocate and reallocate to other
managers within an account.
Other Conflicts of Interest
WEG and its IARs may purchase or sell the same securities or different securities from those
recommended to clients for their personal accounts. It is the policy of WEG that no person associated
with the firm may purchase or sell any security immediately prior to a transaction(s) being implemented
for an investment advisory account in order to prevent such employees from benefiting from transactions
placed on behalf of investment advisory accounts. Because of the single fee charged to a Wrap Program
account, WEG may be regarded as having a conflict in interest as it may realize a greater profit on a Wrap
Program account with a relatively low rate of portfolio turnover compared to other types of accounts,
assuming the same level of fees.
Frequency and Nature of Reviews
World Equity Group's IARs review their Clients' accounts and performance and meet with each Client on
an ongoing periodic basis, but no less than annually. IARs also may conduct additional reviews and meet
with the Client more frequently such as monthly or quarterly, depending on the type of investment
advisory program. WEG conducts periodic reviews of the money managers to evaluate their performance
compared to the other money managers and to the Client's stated investment objective, time horizon and
risk tolerance.
Reports Provided to Clients
Clients receive a quarterly performance reports from WEG and monthly statements, from the Custodian
confirmations of all transactions executed in the Client's account, and a year-end tax summary.
Additional reports may be provided depending on the type of investment advisory program and at the
request of the Client. All account statements are sent to the Client's address of record directly from the
Custodian.
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CLIENT CONTACT & INFORMATION
PROVIDED TO PORTFOLIO MANAGERS
If a Client wishes to have a consultation with one of the third-party money managers, the request must be
made through his or her IAR. The IAR will set-up a conference call with the money manager.
Client information provided to the money managers includes the client's name, address, account
registration status, and contact information. Updated information will be provided to the money managers as
changes are made.
ADDITIONAL INFORMATION
Investment Risk
All investment strategies involve risk. There can be no assurance that a positive return will be obtained in any
managed investment account program. Neither WEG or its IARs or the third-party money managers can
guarantee the investment performance in the account, guarantee any specific level of performance,
guarantee that investment decisions, strategies or that the overall management of the account will be
successful. Any investment decisions the money managers or IAR may make are subject to various market,
currency, economic, political, interest rate and business risks and may not necessarily be profitable, and are
subject to investment risk, including possible loss of principal.
Financial Industry Affiliations
Investment Adviser Representatives ("IARs") of WEG are dually licensed as registered representatives of
World Equity Group, Inc. Most are also licensed insurance agents representing various insurance companies.
As such, IARs are able to receive separate, yet customary commission compensation resulting from
implementing securities and insurance product transactions on behalf of investment advisory clients. The clients
are not under any obligation to engage the IAR when considering whether to implement any investment
advisory recommendations. The implementation of any or all recommendations is solely at the discretion of
the client.
While WEG and its IARs endeavor at all times to put the interest of the clients first as part of our fiduciary
duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest,
and may affect the judgment of IARs when making recommendations.
Other Outside Business Activities
Some IARs own or are affiliated with independent Registered Investment Adviser ("RIA") firms. These
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firms are not affiliated with WEG and their activities are not supervised by WEG. IARs that own or
are affiliated with an independent RIA may only offer and provide similar or different programs than
those offered by WEG. The programs may cost more or less than the Adhesion Program.
Fees for financial planning services provided by the IAR through their own independent RIA are separate
and distinct from any fees paid to WEG in their capacity as an IAR of WEG.
Clients that engage an IAR through an independent RIA firm will receive a copy of that firm's disclosure
documents and execute a Financial Planning Client agreement specifying the financial planning services
to be provided and fees to be charged by the independent RIA.
Certain IARs may have other business activities and offer services, such as tax preparation, accounting,
legal, real estate, employee benefits consulting, or other businesses, that are outside business activities
from their registration as an IAR of WEG. WEG does not supervise or receive compensation from these
other outside business activities. IARs engaging in these other outside business activities do so
independently of their registration with WEG.
WEG may also enter into certain arrangements to offer brokerage and investment advisory services to the
clients of independent unaffiliated financial institutions (credit unions, credit union service organizations,
banks and savings banks). A portion of the client's investment advisory fee will be paid by WEG to the
financial institution pursuant to a fee sharing arrangement as long as the agreement with the institution is
in effect. The financial institution does not provide any investment advisory services to the client.
Disciplinary Information
On August 23, 2018, World Equity Group signed a letter of Acceptance, Waiver and Consent ("A WC")
with FINRA agreeing to a $100,000 fine and was ordered to pay restitution in the amount of not less
$380,000 to customers who purchased L-share class variable annuity contracts with long-term income
riders from the period of June I, 2013 through May 31, 2018. Additionally, from the period of April 2013
through March of 2017, the firm failed to establish, maintain and enforce a supervisory system and
written supervisory procedures reasonably designed to ensure that representatives' recommendation of
variable annuities complied with applicable securities laws and regulations and FINRA rules.
On March 1, 2017, World Equity Group signed a letter of Acceptance, Waiver and Consent ("AWC")
with FINRA and was censured and fined $15,000 for failing to report 83 TRACE Eligible corporate debt
securities transaction within the time frame required by FINRA Rule 6730.
On April 25, 2016, World Equity Group signed a letter of Acceptance, Waiver and Consent ("AWC")
with FINRA and was censured and fined $50,000. WEG failed to establish and maintain a supervisory
program designed to identify and prevent potentially unsuitable excessive trading of equity securities.
On February 3, 2015, World Equity Group signed a letter of Acceptance, Waiver and Consent with
FINRA and was censured and fined $225,000. WEG failed to implement a reasonably designed
supervisory procedures regarding Anti-Money Laundering ("AML"), email retention, customer due
diligence, trading non-traditional Exchange Traded Funds ("ETFs"), private placement due diligence,
non-traded Real Estate Investment Trusts ("REITs") due diligence, and house account supervision.
On September 25, 2014, World Equity Group signed a letter of Acceptance, Waiver and Consent
("AWC") with FINRA and censured and fined $7,500 for failing to report transactions in the Trade
Reporting and Compliance Engine ("TRACE") for Eligible Securitized Products to TRACE within the
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time period required by Rule 6730.
On December 12, 2011, World Equity Group signed a letter of Acceptance, Waiver and Consent
("AWC") with FINRA and was censured and fined $15,000. For failing to transmit all of its reportable
order events to the Order Audit Trail System ("OATS") for more than a year. The firm did not qualify for
exclusion from the OATS reporting requirements because it routed its orders through more than a single
reporting member.
On December 13, 2011, World Equity Group and Mr. Richard Babjak, President and an owner of WEG,
signed a letter of Acceptance, Waiver and Consent ("AWC") where the firm and Mr. Babjak were fined
and censured $50,000 jointly and severally. The AWC alleged specific deficiencies in regard to the
supervision of advertisements, communications with the public, licensing and registration occurring
between December 2007 and November 2008 and involved the supervision of advertising activities of one
representative relative to non-securities insurance products. The AWC was signed to settle the alleged
rules violations and was consented to without admitting or denying the findings. WEG and Mr. Babjak
were censured and fined jointly and severally. WEG and Mr. Babjak worked cooperatively and
proactively with FINRA in connection with the issues and the AWC.
On November 22, 2006, the National Association of Securities Dealers ("NASO") alleged that Mark
Lishchynsky failed to ensure that his previous member firm's offsite FINOP was aware of at least
$31,602.11 worth of liabilities and that the liabilities were properly recorded on the firm's books and
records in violation of NASO Rule 21 IO. Without admitting or denying the findings, Mr. Lishchynsky
consented to the described sanction and to the entry of findings and was fined $5,000. Subsequently, Mr.
Lishchynsky was late with the final payment of the monetary fine and as a result, his license was revoked
until final payment was made. The revocation occurred on June 16, 2009, and was lifted on June 19,
2009.
Additional disciplinary information about the above items can be found on the SEC's website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for WEG is 29087.
Code of Ethics, Participation or Interest
in Client Transactions & Personal Trading
In accordance with SEC Rule 204a-1 of the Investment Advisers Act of 1940, the firm
maintains and enforces a Code of Ethics. The Code requires employee reporting of all
securities holdings and transactions and requires prior pre-clearance from the firm’s Chief
Compliance Officer for certain securities transactions. The Code contains requirements
regarding employee compliance with all Laws, Rules and Regulations, and it contains
provisions for reporting violations of the Code to the firm’s Chief Compliance Officer.
All WEG investment advisor representatives are expected to be honest and ethical, make
full and accurate disclosures, remain in compliance with all applicable rules and
regulations, and be accountable for what they do.
WEG and your investment advisor representative act as fiduciaries for you. We have a
duty to act in your best interests at all times.
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WEG and/ or its investment advisory representatives may at any time own or invest in the
same securities it recommends to clients. All employees and IARs of WEG are required to
submit to the WEG compliance department duplicate copies of all trades and account
statements for review. WEG does not allow any IAR or employee to trade ahead of their
clients. For individual securities such as stocks and bonds, client orders are placed first or
block traded where an average price is used.
To review a copy of the firm’s Code of Ethics, please make a written request to your
investment advisor representative, contact WEG toll free at 800-765-5004, or email
compliance@weg1.com.
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