Overview
- Headquarters
- Lincroft, NJ
- Average Client Assets
- $2.6 million
- SEC CRD Number
- 208512
Fee Structure
Primary Fee Schedule (PART 2A - WEALTH)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 3.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $30,000 | 3.00% |
| $5 million | $150,000 | 3.00% |
| $10 million | $300,000 | 3.00% |
| $50 million | $1,500,000 | 3.00% |
| $100 million | $3,000,000 | 3.00% |
Clients
- HNW Share of Firm Assets
- 8.00%
- Total Client Accounts
- 35,849
- Discretionary Accounts
- 32,863
- Non-Discretionary Accounts
- 2,986
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection, Educational Seminars
Regulatory Filings
Additional Brochure: PART 2A - RETIREMENT (2026-03-31)
View Document Text
Item 1 – Cover Page
World Investment Advisors, LLC
437 Newman Springs Road
Lincroft, New Jersey 07738
Phone: (800) 833-1862
http://www.worldadvisors.com
March 31, 2026
This Brochure provides information about the qualifications and business practices of World Investment
Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at (800)
833-1862 or email compliance@worldadvisors.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.
World Investment Advisors, LLC is a Registered Investment Adviser. Registration of an Investment Adviser
does not imply any level of skill or training. This Brochure is intended, in part, to provide information which
can be used to make a determination to hire or retain an Adviser.
Additional information about World Investment Advisors, LLC also is also available on the SEC’s website
at www.adviserinfo.sec.gov.
(Please see page 10 for WIA’s Privacy Policy)
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Item 2 – Summary of Material Changes
The Firm has the following material changes to report since the last annual brochure dated March 31,
2025.
• WIA has changed its principal place of business to 437 Newman Springs Road, Lincroft, New Jersey
07738.
The Firm has made the following clarification within the Brochure:
• Additional clarification for Item 10 with more information about our relationship with Goldman
Sachs.
Each year, we will provide each client with (i) a free updated Brochure that either includes a summary of
material changes or is accompanied by a summary of material changes, or (ii) a summary of material
changes that includes an offer to provide a copy of the updated Brochure and information on how clients
may obtain the Brochure.
Our Brochure may be requested by contacting us toll-free at (800) 833-1862 or by sending an email to
compliance@worldadvisors.com.
Additional information about World Investment Advisors, LLC is also available via the SEC’s website at
http://www.adviserinfo.sec.gov. The SEC’s website provides information about any persons affiliated with
World Investment Advisors, LLC who are registered, or are required to be registered, as investment
adviser representatives of World Investment Advisors, LLC.
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Item 3 -Table of Contents
Item 1 – Cover Page ....................................................................................................................................... i
Item 2 – Summary of Material Changes ....................................................................................................... ii
Item 3 -Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ........................................................................................................................... 1
Item 5 – Fees and Compensation ................................................................................................................. 3
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 4
Item 7 – Types of Clients ............................................................................................................................... 4
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 5
Item 9 – Disciplinary Information ................................................................................................................. 6
Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 6
Item 11 – Code of Ethics ............................................................................................................................... 7
Item 12 – Brokerage Practices ...................................................................................................................... 8
Item 13 – Review of Accounts....................................................................................................................... 8
Item 14 – Client Referrals and Other Compensation .................................................................................... 8
Item 15 – Custody ......................................................................................................................................... 9
Item 16 – Investment Discretion .................................................................................................................. 9
Item 17 – Voting Client Securities ............................................................................................................... 10
Item 18 – Financial Information .................................................................................................................. 10
Privacy Policy .............................................................................................................................................. 10
iii
Item 4 – Advisory Business
World Investment Advisors, LLC (“WIA” or “Adviser”) was established in March 2015. WIA is a wholly
owned subsidiary of World Associates Holdings, LLC. WIA is an Investment Adviser registered with the U.S.
Securities and Exchange Commission under the Investment Advisers Act of 1940.
WIA provides advisory services to Retirement Plans including, 401(k) Plans, 403(b) Plans, pensions and
profit-sharing plans, non-qualified plans, foundations, endowments, corporations, or other businesses not
listed above, collectively (“Client,” “Plan Client,” or “Plan”). Approximately 70% of WIA advisory fee
revenue is derived from the continuous and regular investment supervisory services rendered to Plan
Clients, however, this is typically done on a non-discretionary basis. WIA willingly accepts the designation
as a “Co-Fiduciary” under ERISA 3(21)(A) or ERISA 3(38) as part of its normal course of business.
WIA also provides Wealth Management Services which are disclosed in a separate Disclosure Brochure
(Form ADV Part 2A) which represents approximately 30% of advisory fee revenue.
WIA will require each Plan Client to make a selection of services in writing as part of the Retirement Plan
Advisory Agreement(s) (RPAA), which sets forth the rights and obligations of WIA and the Client. The
RPAA is customized to state the negotiated fee.
Retirement Plan Advisory Services include, but are not limited to:
Non-Discretionary ERISA 3(21) Investment Adviser
Fiduciary Services
Discretionary ERISA 3(38)
Investment Manager Fiduciary Services
Development of Investment Policy Statement
Investment Performance Measurement and Analysis
NON-DISCRETIONARY
DISCRETIONARY
Advice on the Selection, Monitoring & Replacement
of Designated Investment Alternatives (DIAs)
Selection, Monitoring & Replacement of
Designated Investment Alternatives (DIAs)
Advice on the Selection, Monitoring & Replacement
of Qualified Default Investment Alternative(s) (QDIAs)
Selection, Monitoring & Replacement of Qualified
Default Investment Alternative(s) (QDIAs)
Advice on Model Asset Allocation Portfolios
Creation and Maintenance of Model Asset
Allocation Portfolios
Managed Account Services
Non-Fiduciary Services
Plan Administration Support
Service Provider Support
Investment Monitoring Support
Financial Wellness and Education
WIA provides investment advisory services and typically acts in a “non-discretionary” basis (serving as a
"fiduciary" as defined by §3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 ("ERISA")).
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If requested, WIA may also serve on a discretionary basis and thus will serve as an “investment manager”
as defined by §3(38) of ERISA. In either case, WIA provides specific investment advice to Client with regard
to the selection of investment manager(s) and/or investment vehicles available to the Plan within the
platform provided by the Plan's Administrator.
WIA also offers a web-based, managed account service to eligible Plan Clients whose recordkeeping
platform can accommodate this service. The managed account service is for participants who wish to
have an investment manager select their investments from among the Plan’s available investment options
and manage their participant account for them. Participants receive a personalized investment portfolio
that reflects the managed account service investment options based upon the Participants retirement
time horizon, life stage, risk tolerance and general financial circumstance, including assets held outside
the Plan, to the extent the Participant elects to provide this information, all of which may be taken into
consideration when determining the allocation of assets within the participant’s account. The managed
account service does not provide advice for, recommend allocations of, or manage a participant’s outside
or non-Plan assets. The managed account service does not include management services for individual
stocks, self-directed brokerage accounts, guaranteed certificate funds, employer-directed monies, or in-
plan annuities.
WIA has discretionary authority over allocating the participant’s account without prior participant
approval of each transaction through the managed account service. Assets will be monitored, rebalanced,
and reallocated periodically to respond to market fluctuations. Participants will receive and can update
personal information at any time by calling the Plan’s toll-free customer service number or by visiting the
Plan’s website.
Participants utilizing the managed account service must allocate their entire balance to the service, and
participants may cancel their participation in the service at any time.
Additionally, WIA advisors may recommend the use of the WealthPath Smart Risk series of managed
models to Plan Clients. These models are organized as Collective Investment Trusts (“CITs”) and are
managed by WealthPath Advisors, LLC and offered through Alta Trust Company. WealthPath advisors are
registered as Investment Advisor Representatives of WIA. When offered to their own Plan Clients there
are no additional fees; however, when offered to the Plan Clients of other advisors (including other WIA
advisors), there is a separate share class which does include a fee that is paid to WealthPath in exchange
for its investment management services. This fee is paid directly to WealthPath. WIA as a firm does not
retain any of the compensation related to this investment management service so as to avoid any
conflicted recommendations.
CITs are bank maintained and are not registered with the Securities and Exchange Commission. CITs are
also not mutual funds registered under the Investment Company Act of 1940, as amended (“1940 Act”)
or other applicable law, and unit holders are not entitled to the protections of the 1940 Act. Regulations
applicable to CITs are different from those applicable to a mutual fund. Additionally, CITs are not securities
registered under the Securities Act of 1933, as amended, or applicable securities laws of any state or other
jurisdiction.
Plan Clients may choose to name their Financial Advisor (an Investment Adviser Representative of WIA)
as “broker of record” in their capacity as a Registered Representative of WIA’s affiliated broker/dealer,
World Investments, LLC (“WI”), for the purpose of capturing product revenue to reduce (or offset)
investment advisory fees for the Plan Client. Many Plan Clients consider this a “value-added” service
because it provides the Plan Sponsor flexibility in utilizing product fees to pay for plan expenses in the
absence of an ERISA Budget Account.
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However, if a Plan Client does not engage WIA through an RPAA, the Financial Advisor, when appointed
as a “broker of record”, is truly acting as an agent (or Registered Representative) and not as an Investment
Advisory Representative with respect to the Plan Client, in that case, WIA will not act as a Co-Fiduciary to
the Plan.
Consultations. Adviser may occasionally furnish investment advice on a consulting basis with a Plan
Sponsor or Fiduciary Committee. To the extent it is requested to do so, Adviser may provide its Clients
with investment advisory and consultation services on a “fee for service” basis. Fees for such consultations
will be quoted to the Client prior to engagement.
Unless approved by the firm’s Chief Compliance Officer in advance, Adviser does not offer advice on
private placements, REITs, Business Development Companies and/or limited partnerships that are
considered “alternative investments.” Adviser may offer advice on private equity funds that contain
investments in equities, futures, options, and other securities. Any such recommendation will be made
only when determined to be suitable and must be accompanied by or preceded by prospectus or offering
memorandum. This type of advice is rendered to Wealth Clients or Nonqualified Plan or other institutional
clients, not 401(k) or 403(b) plans.
In performing its services, WIA shall not be required to verify or audit the information received from the
Plan Client or from the Plan Client’s other professionals and is expressly authorized to rely thereon. If
requested by the Client, WIA shall recommend the services of other professionals for implementation
purposes. The Client is under no obligation to engage the services of any such recommended professional.
The Client retains absolute discretion over all such implementation decisions and is free to accept or reject
any recommendation from WIA. It is each Client’s responsibility to promptly notify WIA if there is ever
any change in the Client’s financial situation or investment objectives.
As of December 31, 2025, the Firm had $31,700,168,817 in discretionary assets under management and
$39,941,015,822 in non-discretionary assets under management.
Item 5 – Fees and Compensation
WIA will require each Plan Client to make a selection of services in writing as part of the Retirement Plan
Advisory Agreement(s) (RPAA), which sets forth the rights and obligations of WIA and the Client. Fees for
Retirement Plan Advisory Services are negotiated prior to the signing of the RPAA. The RPAA is then
customized to state the negotiated fee, which, in general, is expressed as a percentage of total Plan assets
and will not exceed 3.00%.
In general, fees charged for investment advisory services are payable quarterly or monthly as dictated by
the third-party administrator, recordkeeper or custodian, in arrears, and are based upon the market value
of the Client’s Plan assets on the last business day of the calendar month or quarter, as the case may be.
In some instances, fees are payable in advance, rather than in arrears; however, this will always be
disclosed in the RPAA. Fees may be direct billed to the Client or to a third-party administrator (“TPA”) or
custodian at the Client’s instruction. Fees for Plan Clients engaging WIA mid-period will be prorated and
calculated on a per diem basis.
The RPAA will continue in effect until terminated by either party upon thirty (30) days written notice to
the other party.
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If any advisory relationship terminates before the last day of a month or quarter, fees are prorated
accordingly, and the Adviser will refund any unearned fees due to the Client.
Flat/Fixed Fee Service. To the extent so engaged by Client, the Adviser may charge a Flat or Fixed fee for
investment advisory and consultation services. Fixed fees are negotiable, but generally range from $1,000
to $250,000 on an annual basis, depending upon the level and scope of the services required. Fixed fee(s)
will be charged quarterly in advance unless otherwise noted, (calculated on a per diem basis) upon the
signing of an RPAA by the Client. Fees for Clients engaging Adviser mid-quarter will be prorated on a per
diem basis. Occasionally, advisory services will be quoted on an hourly or per diem basis.
In cases where Plan Clients have elected to appoint a WIA Financial Advisor as “broker of record”, WI will
be compensated by general promotion, advertising, and distribution fees (12b-1 fees) in relation to Client
purchases and sales of mutual fund shares. However, these 12b-1 fees will be taken into account when
calculating the Plan Client advisory fee for service for a particular period and the typical fee reduced based
on the 12b-1 fees received by WI. In some cases, the mutual funds the Firm could recommend offer a
variety of share classes, including some that do not charge 12(b)-1 fees and are, therefore, less expensive.
Typically, WIA does not recommend mutual funds that charge 12(b)-1 fees when other share classes are
available. However, there are instances in which the WIA Financial Advisor would recommend a mutual
fund that carries a 12(b)-1 fee, even when a lower-cost share class is available for the same fund. For
example, a lower-cost class share may not be available to the Client due to investment minimums or
recordkeeping platform restrictions. In other cases, retirement plan fund line-ups containing mutual funds
charging 12(b)-1 fees are taken over by WIA from another firm, in which case the Firm may recommend
the Client holds the existing share class initially, instead of selling the fund and buying a lower-cost share,
due to ERISA participant disclosure timing requirements.
Fees charged may be higher than otherwise available elsewhere. A portion of the fees charged by WIA for
advisory services are paid to Investment Advisor Representatives of WIA. All fees described herein may
be subject to negotiation depending on a range of factors including, but not limited to, plan size and
overall range of services requested.
WIA’s fees are exclusive of other related costs and expenses which shall be incurred by the Plan Client.
For example, Clients may incur certain charges imposed by custodians, brokers, third party investment
and other third parties such as fees charged by managers, record-keeping/custodial fees, sales charges,
redemption fees, wire transfer and electronic fund fees, and other fees and/or taxes. Mutual funds and
exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to WIA’s fee, and WIA shall not receive
any portion of these other fees or costs.
Item 6 – Performance-Based Fees and Side-By-Side Management
WIA does not charge any performance-based fees (fees based on a share of capital gains on or capital
appreciation of the assets of a Client).
Item 7 – Types of Clients
WIA provides advisory services to Retirement Plans including, 401(k) Plans, 403(b) Plans, pensions and
profit-sharing plans, non-qualified plans, foundations, endowments, corporations or other businesses not
listed above. WIA also provides investment advisory services to individuals (“Wealth Clients”), on a
continuous and regular basis, but those services are disclosed separately, in WIA’s Wealth Advisory
Services Disclosure Brochure.
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For Plan Clients, Adviser does not require a minimum account size, but may impose a minimum annual
consulting fee.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Investment recommendations are based on an analysis of the Plan Client’s specific needs and are drawn
from research and analysis. Each Plan is analyzed separately paying particular attention to the limitations
on the investment lineup as determined by the Plan documents, the Plan’s current service
providers/platform and whether
the Plan’s current platform has an open or closed
architecture. However, in general, security analysis methods include fundamental analysis as well as
quantitative and qualitative research on a given investment vehicle. Information for this analysis may be
drawn from financial newspapers, magazines and databases, research materials prepared by others,
annual reports, corporate filings and prospectuses. Additional sources of information utilized by WIA
include meetings and discussions with Investment Managers employed by Investment Companies,
statistical summaries and analyses, and other such sources WIA personnel deem appropriate. WIA may
utilize services of sub-advisers and established third-party research services to assist WIA with formulating
asset allocation, industry and sector selection, and investment recommendations in managing the Plan
Client’s funds. Technical Analysis may be used when analyzing indices and/or securities other than open-
ended mutual funds.
It is important to note that investing in securities involves certain risks that are borne by the investor. For
any risks associated with Investment Company products, please refer to the prospectuses for additional
details about these risks. WIA’s investment approach constantly keeps the risk of loss in mind. In general,
risks associated with investing include, but are not limited to:
•
Interest-rate Risk: Fluctuations in interest rates cause investment prices to fluctuate. For example,
when interest rates rise, yields on existing bonds become less attractive, causing their market
values to decline.
•
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of a
security’s particular underlying circumstances. For example, political, economic and social
conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar
next year, because purchasing power is eroding at the rate of inflation.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed
income securities.
•
• Business Risk: These risks are associated with a particular industry or a particular company within
an industry. For example, oil-drilling companies depend on finding oil and then refining it, a
lengthy process, before they can generate a profit. They carry a higher risk of profitability than an
electric company, which generates its income from a steady stream of customers who buy
electricity no matter what the economic environment is like.
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets
are more liquid if many traders are interested in a standardized product. For example, Treasury
Bills are highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times and bad.
5
During periods of financial stress, the inability to meet loan obligations may result in bankruptcy
and/or a declining market value.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to an evaluation of WIA or the integrity of WIA’s management. WIA has
no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
WIA is a wholly owned subsidiary of WIA Holdings, LLC. Under the common control of WIA Holdings, LLC,
WIA is affiliated with Goldman Sachs & Co., LLC, a FINRA broker-dealer (Member SIPC) and SEC Registered
Investment Adviser, and World Investments, LLC, a FINRA broker dealer (Members SIPC), WIA is also
affiliated with World Insurance Associates, LLC, Scotts American, LLC, Keating, LLC, ESA Associates, LLC,
FastComp, LLC, Hamond Safety Management, LLC, Pacific Coast NCA Premium Finance, LLC, and World
Insurance Programs, LLC, all insurance agencies engaging in Life, Health, Long Term Care, Variable, and
various other Insurance business.
Recommendations for Goldman Sachs investment products are limited to a small subset of products
approved by WIA. No incentives are provided to WIA or WIA Investment Advisor Representatives to
recommend Goldman Sachs products over other investment products.
WIA is also affiliated with other financial services companies, but does not have any shared business
dealings, operations, referral programs, clients, representatives, or premises with these other companies,
and has no reason to believe the firm’s relationship with them otherwise creates a conflict of interest with
WIA clients. A full list of WIA’s affiliates will be provided upon request.
Investment Adviser Representatives (“IARs”) of WIA may effect securities transactions for Clients as
registered representatives of St. Bernard Securities, LLC (“St. Bernard”), or World Investments, LLC.
(“WI”), all FINRA broker-dealers. WIA is affiliated with WI through the common control and ownership
by WIA Holdings, LLC. WIA has no affiliation with St. Bernard. Advisors that are registered representatives
of these firms may recommend either of the two firms with whom they are registered for broker-dealers
services. Factors for such a recommendation may be when transaction compensation is seen as a benefit
to the client. For broker-dealer services, St. Bernard, WI, or their associated persons may receive
compensation, which is separate and distinct from compensation related to investment advisory services.
Commissions paid to advisors for broker-dealer services may be higher or lower than those paid by other
brokers. All FINRA, SEC, and other regulatory agencies disclosure requirements and policies are observed
for all transactions. If a trade error were to occur, it may result in profit or loss to the firm. The firm has
controls in place to limit such trade errors. Investment Advisers will not participate in any profits resulting
from such errors.
Many WIA Advisors are life insurance licensed in order to act as “agent of record” for those Plan Clients
whose retirement plans are funded with group variable insurance products. Additionally, Financial
Advisors at WIA may occasionally recommend fixed or variable annuities or life insurance to their Wealth
Clients when assisting them in executing their financial plan. Variable Annuities will be offered through
WI, while fixed annuities or other life insurance products may be offered through an independent
insurance agency. Insurance products are separate and distinct from advisory services offered. In general,
product revenue associated with Plan Client assets is captured to reduce the plan advisory fee pursuant
to the terms of the RPAA.
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Some Investment Adviser Representatives (“IARs”) of WIA may also be registered as IARs of Acrisure
Investment Advisory Solutions, LLC (“Acrisure”). However, these IARs do not effect any transactions
through Acrisure. One WIA Advisor is also registered as an Advisor with Nexus338, an advisory firm
providing technology-based retirement plan managed account services to non-WIA clients. WIA is not
affiliated with Acrisure, or Nexus338.
WIA may recommend recordkeepers to Plan Clients. American Pension Benefits (“APB”) is a recordkeeper
that is owned and operated by certain Investment Advisor Representatives of WIA. All revenue earned by
APB is separate and distinct from WIA fees. WIA and APB are not affiliated and WIA does not receive
remuneration for referrals to APB.
WIA also serves as a 3(38) discretionary investment manager to the Architect PEP. The pooled employer
plan (“PEP”) combines plan administration services with investment management services for
participating employers. WIA has no affiliation with the Pooled Plan Provider, Finway Group, and receives
levelized compensation based on assets under management within the PEP.
Individuals licensed as Registered Representatives or Insurance Agents may spend as much as 50% of their
time on these non-advisory activities. In their capacities as registered representatives or as independent
insurance agents, clients will be charged separately from their advisory services. Clients have the option
to purchase investment products that we recommend through other brokers or agents that are not
affiliated with WIA.
Please Note: Item 12 includes additional details regarding brokerage practices and related disclosures.
Item 11 – Code of Ethics
Personal transactions in securities by directors, officers, and employees of WIA who have access to
nonpublic information regarding Clients’ purchase and sale of securities, are involved in making securities
recommendations to Clients, or who have access to such non-public recommendations (“access persons”)
are subject to the restrictions and procedures in WIA’s Code. All supervised persons at WIA must
acknowledge the terms of the Code of Ethics annually, or as amended.
The Code addresses, among other things, the following: (i) general principles that address WIA’s fiduciary
obligations to its Clients, (ii) personal securities trading procedures restricting the purchase and sale, by
access persons for their own accounts, of specific securities; (iii) provisions relating to the confidentiality
of Client information; (iv) a prohibition on insider trading; and (v) restrictions on the acceptance of
significant gifts and the reporting of certain gifts and business entertainment.
Occasionally, access persons of Adviser may recommend that Clients buy or sell the same securities or
investment products that access persons of the Adviser also own. In such circumstances, Adviser shall give
precedence to Client transactions. WIA’s employees and persons associated with WIA are required to
follow the Code of Ethics. The Code of Ethics is designed to assure that the personal securities
transactions, activities and interests of the employees of WIA will not interfere with (i) making decisions
in the best interest of advisory Clients and (ii) implementing such decisions while, at the same time,
allowing employees to invest for their own accounts. Under the Code certain classes of securities have
been designated as exempt transactions, based upon a determination that these would not materially
interfere with the best interest of WIA’s Clients. In addition, the Code requires pre-approval of specific
types of transactions, and restricts trading in close proximity to client trading activity. Nonetheless,
because the Code of Ethics in some circumstances would permit employees to invest in the same
securities as Clients, there is a possibility that employees might benefit from market activity by a Client.
7
Employee trading is monitored under the Code of Ethics to reasonably prevent conflicts of interest
between WIA and its Clients.
Because all trading for Plan Clients is done by the Plan’s recordkeeper, WIA does not effect any block or
bunched trades.
WIA’s Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting the
Compliance Department at (800) 833-1862 or by sending an email to compliance@worldadvisors.com.
Item 12 – Brokerage Practices
WIA is affiliated with World Investments, LLC (“WI”) (registered Broker/Dealer with FINRA) under the
common control and ownership of WIA Holdings, LLC. WI collects 12b-1 fees or product commissions that
may be used to offset WIA advisory fees. In this case, WIA tracks all 12b-1 or product revenue (by plan
Client) that is actually received by WI and offsets advisory fees on a monthly or quarterly basis as the case
may be, in accordance with the RPAA. In the absence of an RPAA, a Plan Client may appoint a WIA Financial
Advisor (only in his/her capacity as registered representative of a FINRA broker-dealer) as the “Broker of
Record” in order to compensate the WIA Financial Advisor solely with product revenue. Consequently,
Investment Adviser Representatives, who are also Registered Representatives of WI, may receive
compensation in the form of commissions for each transaction if that Registered Representative is named
as “Broker or Agent of Record” to investment company products that the Plan Client is invested in.
Therefore, on rare occasions, a Registered Representative may be compensated by 12b-1 fees or direct
commissions only.
Brokerage Practices affecting Wealth Clients are separately disclosed in its Wealth ADV Part 2A. Wealth
disclosures include that Investment Adviser Representatives may effect securities transactions for Clients
as registered representatives of a broker/dealer. All FINRA, SEC, and other regulatory agencies disclosure
requirements and policies are observed for all transactions. Associated persons may receive
compensation for such transactions, where such compensation is separate and distinct from Adviser’s
compensation related to its investment advisory services. As stated in Item 5, any product revenue
stemming from an RPAA with an ERISA Plan Client captured by WI will be used to offset WIA advisory fees.
Item 13 – Review of Accounts
Plan Client Accounts are reviewed by their Financial Advisor, the Investment Advisor Representatives
(“IAR”) responsible for performing periodic reviews and consulting with the respective Client. Additionally,
monthly or quarterly statements are provided by the Plan Client’s custodian or recordkeeper, but
additional reports may be provided by Third Party Administrators employed by the Plan Client.
Plan Clients agree to inform the WIA in writing of any material changes to the Plan Client’s financial
circumstances that may affect advice being rendered to the Plan. Plan Clients may contact the Adviser
during normal business hours to consult with the firm concerning any such material changes.
Item 14 – Client Referrals and Other Compensation
WIA, in some instances, may compensate third-party promoters for Client referrals. In order for a
promoter to be compensated by WIA for referring a Client to WIA, the promoter must be engaged by WIA
under a Promoter or Referral Agreement (“Agreement”) in compliance with Section 206(4)-1 of the
Investment Advisers Act of 1940. In general, a promoter is compensated by a percentage of the advisory
fee collected for a limited period specified in the Agreement. The Client pays no additional fee for the
referral over and above WIA’s quoted advisory fee; to the contrary, the fee the Adviser earns is reduced
8
by the amount of the compensation to the promoter. A Client who is referred by a promoter will receive
the promoter’s separate Disclosure Statement describing the nature of the arrangement in detail.
Clients may request details regarding a particular Agreement by contacting us toll-free at (800) 833-1862
or by emailing compliance@worldadvisors.com.
Certain mutual fund companies, recordkeepers, or other third parties (“Third Parties”) will periodically
sponsor educational seminars for participating financial advisors designed to facilitate and promote
professional development and product knowledge. To encourage participation, Third Parties will cover
travel related expenses for certain financial advisors to attend these meetings. Such expense
reimbursements are only permissible by WIA when pre-approved, and after review of the agenda and
estimated costs. WIA will not approve expense reimbursements by the Third Parties for travel unless the
travel expenses appear reasonable and customary; lavish expenses will not be approved. WIA Advisors
do not base recommendations on the expectation of such conference and travel.
In addition, WIA or its Advisors may host events where Third Parties “sponsor” a specific portion of the
event, e.g., the cost of a dinner. WIA Advisors do not base recommendations on the expectation of such
conferences, travel or event sponsorship.
Item 15 – Custody
WIA is deemed to have custody of client funds because investment advisory fees are directly debited from
some Client accounts. Debiting of fees is done pursuant to authorization provided by the Client. Clients
should receive statements at least quarterly from the selected qualified Custodian that holds and
maintains client’s investment assets. WIA urges clients to carefully review such statements and compare
the official custodial records to the account statements that WIA may provide. WIA’s statements may vary
from custodial statements based on accounting procedures, reporting dates, or valuation methodologies
of certain securities.
WIA is also deemed to have custody of client assets as a result of certain Clients’ authorization for WIA
and/or its IARs to distribute assets from their account(s) to a specific named recipient on demand in
accordance with a standing letter of instruction. WIA complies with the SEC No-Action Letter dated
2/21/2017 (Investment Adviser Association) allowing firms complying with the provisions of the No-Action
Letter to forego an annual surprise custody examination with respect to those assets.
Item 16 – Investment Discretion
WIA most often acts in a non-discretionary capacity as an ERISA 3(21) fiduciary. As such, WIA will make
recommendations of investments to plan sponsors, but does not have the authority to make decisions on
behalf of the Plan. The plan sponsor/trustee retains ultimate decision‐making authority for investments
and may accept or reject the recommendations. The plan sponsor is responsible for the selection and
monitoring of the 3(21) fiduciary and implementation of any of the 3(21) fiduciary’s investment
recommendations and assumes responsibility and liability for any decisions made.
For certain WIA Clients, the discretionary RPAA (Retirement Plan Advisory Agreement) gives WIA the
authority to take discretion over the investment selection in a Plan. This service elevates WIA’s fiduciary
role to that of an ERISA 3(38) “investment manager.” In that circumstance, the plan sponsor has the
obligation to select and monitor WIA as a 3(38) investment manager.
WIA’s separate Disclosure Brochure for its Wealth Management Services discloses the level of authority
and discretion WIA is granted, in general, for its Wealth Management clients.
9
Adviser may have the authority to negotiate fees on behalf of the Plan Client with its other service
providers. Specifically, in its efforts to perform “Request(s) For Proposals” (RFPs) on behalf of Plan Clients,
Adviser assists the Plan Client in determining the most suitable fee for services structure that can be
obtained within the constraints of the Retirement Plan Document(s). However, WIA does not have any
“control” over the fees or commissions charged by custodians or investment companies for the products
or services they provide. Consequently, the Plan Client may pay fees or commissions higher than
obtainable elsewhere for similar products or services.
Item 17 – Voting Client Securities
WIA typically does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and
voting proxies for any and all securities maintained in client portfolios. Clients should contact their
financial advisor if they have any questions and/or to obtain this information. Clients will receive their
proxies directly from their custodian or transfer agent.
In limited circumstances, WIA will agree to vote proxies on securities on behalf of a Retirement client. In
all such instances, proxies will be voted in accordance with the terms of the client’s Investment Advisory
Agreement. WIA has adopted procedures that are designed to ensure client securities are voted in the
best interests of the firm’s clients, and to avoid potential conflicts of interest that may arise between
WIA’s interests and those of the firm’s clients. The firm will analyze the proxy issues and execute votes in
accordance with the firm’s established proxy voting guidelines. Any issues regarding potential material
conflicts will be raised with the firm’s Compliance Officer. If a conflict of interest is identified, the client
will be contacted to provide guidance on voting the proxy in an appropriate manner. To the extent the
guidelines do not address a proxy issue, the company will vote that proxy in the best interest of WIA’s
client.
A copy of WIA’s Proxy Voting Policies and Procedures and/or the record of proxies that have been voted
for the client are available to clients upon their request.
Item 18 – Financial Information
Registered Investment Advisers are required to provide certain financial information or disclosures about
their financial condition. WIA has no financial commitment that impairs its ability to meet contractual and
fiduciary commitments to Clients and has not been the subject of any bankruptcy proceedings.
Privacy Policy
World Investment Advisors, LLC (“WIA”) recognizes that its Clients have an expectation that WIA and its
affiliates will maintain the confidentiality of Clients’ nonpublic personal information. Consequently, WIA
has adopted this Privacy Policy concerning information obtained during the servicing of Client’s
account(s).
Nonpublic Information: Nonpublic information obtained by WIA for purposes of providing services
hereunder will not be furnished to third parties for any other purpose other than in furtherance of the
services to be provided hereunder. Notwithstanding the foregoing, WIA may disclose nonpublic
information (i) to the extent such disclosure is required by court order or by a valid order of a
governmental body governmental or quasi-governmental agency (such as FINRA) (ii) after the time of
disclosure such information becomes part of the public knowledge or literature, not as a result of any
inaction or action of WIA, (iii) reasonably necessary for WIA to enforce its legal rights in any dispute with
that Client; or (iv) is approved by Client, in writing, for release. WIA does not disclose nonpublic personal
information about its Clients to any party except as permitted by law.
10
Sources of Personal Information: WIA collects Personal Information about its Clients from meetings with
Clients and on applications or other forms Clients have submitted to WIA, as well as information about
Clients’ investments or transactions with WIA or others (such as third-party service providers or fund
companies) from other sources.
How WIA Protects the Confidentiality of Clients’ Nonpublic Personal Information: WIA does not sell or
trade Clients’ information with nonaffiliated companies. When information is provided to third party
service providers, safeguards are in place to assure that information is used only for the purpose it is
provided. WIA maintains its records on secured computers. Prospective employees are screened for
criminal convictions. Once hired, employees are made aware of WIA’s Privacy Policy and of the
confidential nature of the information they handle. Employees are limited to accessing only that customer
information that is necessary to perform their job functions.
To Whom This Policy Applies: This Notice applies to all WIA Clients who enter into an Advisory Services
Agreement or Customer Agreement with WIA. For Former Clients: WIA’s Privacy Policy continues to apply
even to Clients that have terminated services with the firm.
Internet Cookies: An internet “cookie” is a small amount of data that is placed on to your electronic
device by a website and stored in your internet browser. Cookies allow websites to store things like
preferences, so that it can recognize users when returning to the site and respond appropriately. When
individuals access the Worldadvisors.com website, WIA makes use of cookies to improve the load times
and functionality of the website, and in some cases registration pages. WIA may from time to time also
utilize data tracking software to assist in spotting trends and areas of improvement on the website. By
accessing the Worldadvisors.com site and embedded web pages, users are providing their express
approval allowing WIA to utilize these technologies to improve services provided. WIA may also use
various third-party cookies to report usage statistics of the service, or to authenticate users and prevent
fraudulent access of user accounts.
Access to and Correction of Information: Upon the written request of Clients, WIA will make available
for review any file that may be maintained for their personal Information; provided, however, that any
Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be
made available. If Clients notify WIA that any Information is incorrect, the information will be reviewed.
If WIA agrees the information is incorrect, records will be corrected. If WIA disagrees, Clients may submit
a short statement of dispute, which will be included in any future disclosure of the disputed Information.
Additional California Privacy Disclosures: Please consult the supplemental WIA Privacy Notice for
California Residents for additional disclosures pertinent to California residents.
Further Information: WIA reserves the right to change this Privacy Policy at any time. The examples
contained within this Privacy Policy are illustrations and are not intended to be exclusive. This Policy
attempts to comply with federal and state regulations regarding privacy. Clients may have additional
rights under other foreign or domestic laws that may apply to them.
If the financial advisor servicing a client account leaves WIA to join another firm, the advisor is permitted
to retain copies of client information so that he/she can assist with the transfer of the client account and
continue to serve the client at their new firm.
by
calling
(800)
833-1862
or
by
an
email
“Opting Out” of Third-Party Disclosures: If a client does not want a financial advisor to retain copies of
client sensitive information when he/she leaves WIA to join another firm, the client may contact the WIA
Compliance Department
to
sending
compliance@worldadvisors.com to request further information regarding this policy.
11
Additional Brochure: PART 2A - WEALTH (2026-03-31)
View Document Text
Item 1 – Cover Page
World Investment Advisors, LLC
437 Newman Springs Road
Lincroft, New Jersey 07738
Phone: (800) 833-1862
http://www.worldadvisors.com
March 31, 2026
This Brochure provides information about the qualifications and business practices of World Investment
Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at (800)
833-1862 or email compliance@worldadvisors.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.
World Investment Advisors, LLC, is a Registered Investment Adviser. Registration of an Investment Adviser
does not imply any level of skill or training. This Brochure is intended, in part, to provide information which
can be used to make a determination to hire or retain an Adviser.
Additional information about World Investment Advisors, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
(Please see page 16 for WIA’s Privacy Policy)
i
Item 2 – Material Changes
The Firm has the following material changes to report since the last annual brochure dated March 31,
2025:
• WIA has changed its principal place of business to 437 Newman Springs Road, Lincroft, New Jersey
07738.
The Firm has made the following clarification within the Brochure:
•
•
Item 4 – added disclosure regarding Insurance and Annuity Exchange
Item 5 – additional detail regarding procedures applicable to account termination
Each year, we will provide each client with (i) a free updated Brochure that either includes a summary of
material changes or is accompanied by a summary of material changes, or (ii) a summary of material
changes that includes an offer to provide a copy of the updated Brochure and information on how clients
may obtain the Brochure.
Our Brochure may be requested by contacting us toll-free at (800) 833-1862 or by sending an email to
compliance@worldadvisors.com.
Additional information about World Investment Advisors, LLC is also available via the SEC’s website at
www.adviserinfo.sec.gov. The SEC’s website provides information about any persons affiliated with World
Investment Advisors, LLC who are registered, or are required to be registered, as investment adviser
representatives of World Investment Advisors, LLC.
ii
Item 3 - Table of Contents
Table of Contents
Item 1 – Cover Page ....................................................................................................................................... i
Item 2 – Material Changes ............................................................................................................................ ii
Item 3 - Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ........................................................................................................................... 1
Item 5 – Fees and Compensation ................................................................................................................. 5
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................ 10
Item 7 – Types of Clients ............................................................................................................................. 10
Item8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 10
Item 9 – Disciplinary Information ............................................................................................................... 11
Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 12
Item 12 – Brokerage Practices .................................................................................................................... 13
Item 13 – Review of Accounts .................................................................................................................... 14
Item 14– Client Referrals and Other Compensation ................................................................................... 15
Item 15 – Custody ....................................................................................................................................... 15
Item 16 – Investment Discretion ................................................................................................................. 15
Item 17 – Voting Client Securities ............................................................................................................... 16
Item 18 – Financial Information .................................................................................................................. 16
Privacy Policy .............................................................................................................................................. 16
iii
Item 4 – Advisory Business
World Investment Advisors, LLC (“WIA” or “Adviser”) was established in March 2015. WIA is a wholly
owned subsidiary of WIA Holdings, LLC. WIA is an Investment Adviser registered with the U.S. Securities
and Exchange Commission under the Investment Advisers Act of 1940.
In addition to the Programs described in this Brochure, WIA also offers wrap fee programs, which are
disclosed in separate Wrap Fee Brochures. Our wrap fee programs include portfolio management services
including mutual funds and exchange traded funds (“ETFs”), along with high quality individual fixed income
and equity securities.
In a wrap fee program, clients are charged an all-inclusive wrap fee on Program Assets that covers advisory,
execution, custodial and reporting services on Eligible Assets. A portion of these fees will be paid to WIA
for advisory services. In a non-wrap fee program, WIA’s fees are exclusive of brokerage commissions,
transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may
incur certain charges imposed by custodians, brokers, technology platforms, third party investment and
other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Mutual funds and exchange traded funds also charge internal
management fees, which are disclosed in the fund’s prospectus. Such charges, fees and commissions are
exclusive of and in addition to WIA’s fee, WIA shall not receive any portion of these commissions, fees, and
costs.
As of December 31, 2025, the Firm had $31,700,168,817 in discretionary assets under management and
$39,941,015,822 in non-discretionary assets under management.
WIA Wealth
WIA provides advisory services through its Wealth Program, giving continuous advice based on the client’s
individual needs. Through personal discussions with our clients regarding their goals and objectives the
firm will typically develop a personal investment policy based upon which a Client Profile is created and
we manage the portfolio according to the criteria in the profile. Through its advisor as portfolio manager
program, WIA advisors can deliver customized portfolio solutions through their access to online tools that
streamline the process of managing client accounts, including rebalancing and liquidity tools, client-level
security restrictions, trading tools, alerts, and integrated reporting functions.
Third-Party Money Management
WIA has access to a wide range of non-affiliated investment advisors (“Third-Party Money Managers”) via
the Envestnet ENV2 platform to offer asset allocation and asset management services to WIA advisory
clients. Each IAR shall assist their client in formulating a strategic investment portfolio based on the client's
investment objectives. Once formulated, if appropriate for the client, a suitable Third-Party Money
Manager is selected to implement and continually manage the portfolio by the advisor. In preparing the
portfolio, each IAR may set restrictions or limitations on the management of the account and will explain
to the client the continual account activity transacted by the Third-Party Money Manager. Also, WIA will
periodically review the current and historical performance record of each Third-Party Money Manager.
WIA has also entered into additional agreements with Third-Party Money Managers not available on the
Envestnet ENV2 platform to offer asset allocation and asset management services to WIA advisory clients.
In the same way as mentioned above, each IAR shall assist their client in formulating a strategic investment
portfolio based on the client's investment objectives. Once formulated, a suitable Third-Party Money
1
Manager is selected to implement and continually manage the portfolio. In preparing the portfolio, each
IAR may set restrictions or limitations on the management of the account and will explain to the client the
continual account activity transacted by the Third-Party Money Manager. Also, WIA will periodically review
the current and historical performance record of each Third-Party Money Manager.
The relationship of WIA with any Third-Party Money Manager will be clearly communicated to all clients
in the Third-Party Money Manager’s Client Services Agreement and/or other similar documentation. Each
Third-Party Money Manager is required to provide WIA and the IAR with a disclosure document statement,
typically a copy of their Form ADV 2A. The Third-Party Money Manager’s Form ADV 2A will be provided to
the client by the IAR.
Additionally, WIA advisors may recommend the use of WealthPath models to Clients. These models are
managed by WealthPath Advisors, LLC. WealthPath advisors are registered as investment advisor
representatives of WIA. When offered to their own clients, there are no additional fees; however, when
offered to the clients of other advisors (including other WIA investment advisor representatives), a portion
of the total advisory fee charged is paid to WealthPath in exchange for their investment management
services. Although the fee paid by the Client is not impacted, WIA receives additional remuneration when
WealthPath is selected as the manager of the Clients’ assets because WealthPath is not an outsourced
Third-Party Money Manager. WIA’s fiduciary responsibility is to always choose the manager or portfolio
that is in the best interest of the client. Additionally, WIA does not promote or endorse the exclusive use
of WealthPath as a Third Party Money Manager but will recommend the use WealthPath as a Third Party
Money Manager when it’s in the best interest of the client.
Reasonable Restrictions
Each client has the ability to impose reasonable restrictions, in writing, on the management of his/her
account, including the designation of particular securities or types of securities that should not be
purchased for the account, or that should not be sold if held in the account. If a client’s instructions are
unreasonable or an investment advisor representative believes that the instructions are inappropriate for
the client, WIA will notify the client that, unless the instructions are modified, it may cancel the instructions
in the client’s account. A client will not be able to provide instructions that prohibit or restrict the
investment adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale
of specific securities or types of securities within the fund.
Financial Planning & Analysis
As an extension of its wealth advisory services, WIA may provide advice in the form of a Financial Plan.
Clients may receive a written plan, providing the client with a detailed financial plan designed to achieve
their stated financial goals and objectives. In general, the plan will address any or all of the following:
• Personal: Family records, budgeting, personal liability, estate information and financial goals.
•
Tax and Cash Flow: Income tax, spending analysis and planning for past and future years.
• Death and Disability: Cash needs at death, income needs of surviving dependents, estate
planning.
• Retirement: Strategies and investment plans to help client achieve their retirement goals.
•
Investments: Analysis of investment alternatives and their effect on a client’s portfolio.
Information on clients will be gathered through in-depth personal interviews and review of personal
financial information. Gathering data concerning current financial status, future requirements, risk
appetite and goals is essential. In some instances, this information may be incorporated into eMoney or
2
another technology solution offering a goals-based approach to financial planning and analysis. The
financial management process begins with an in-depth evaluation of the client’s current financial goals
and objectives. Once overall objectives have been established, the Advisor will focus on the client’s specific
goals.
WIA may work with other professionals such as attorneys, certified public accountants, trust officers,
mortgage analysts, etc., to offer financial and estate planning advice but does not provide legal or tax
advice. WIA specializes in the areas of investment, finance, estate, risk management, retirement, and
business continuation planning.
eMoney
In addition to the aforementioned services, WIA offers investment data storage and periodic
comprehensive reporting services which can incorporate all of the client’s investment assets, including
those investment assets that are not part of the assets managed by WIA (the “Excluded Assets”). Should
the client utilize these reporting services, the client acknowledges and understands that with respect to
the Excluded Assets, WIA’s service is limited to reporting and data storage services only and does not
include investment management, review, monitoring services, investment recommendations nor advice.
As such, WIA will not be responsible for the investment performance of the Excluded Assets. If the client
requests WIA to provide investment management services with respect to the Excluded Assets, the client
may engage WIA to do so for a separate and additional fee.
Insurance and Annuity Exchange (FIDx)
The Insurance and Annuity Exchange, powered by Envestnet, provides end-to-end management of annuity
solutions from pre- to post-issuance. Advisors can plan, research, generate proposals, open policies,
manage in-force transactions, and create client reports within the Envestnet platform. Insurance and
Annuity Exchange is a way to offer long-term protection solutions to clients through a single, unified
platform.
WorldMAP Program Overview
World Managed Account Platform (“WorldMAP”) is an asset management platform offered by WIA to its
clients. WorldMAP provides clients with access to professionally managed portfolios that are designed to
achieve certain investment objectives and/or to comply with specific risk limitations and other constraints.
The investment manager typically makes investment decisions based on a strategy the manager has
developed to meet those objectives and constraints. Typically, the manager creates and maintains a
“model portfolio,” that is, a portfolio consisting of certain securities in specific allocations that can be
implemented widely in the separate accounts of those clients who subscribe to that manager’s strategy.
In some cases, the client’s advisor will create and manage a customized portfolio, rather than a model.
Whether managing a model portfolio or a customized portfolio, the manager maintains the portfolio by
making decisions to buy and sell securities and to adjust the allocation among the securities held in the
portfolio on an ongoing basis. Investment management services under the WorldMAP program are
implemented through a portal, or “platform,” to which WIA has been provided access under agreements
with Vestmark Advisory Solutions, Inc. and its affiliates (“VAS”).
WorldMAP offers WIA clients access to: (a) model or customized portfolios managed by the client’s advisor
(Advisor-Managed Portfolios or “AMP”); (b) model portfolios managed by Cota Street Investment
Management, WIA’s investment management team (“Cota Street Models”); and (c) model portfolios made
available to WIA pursuant to a sub-advisory agreement between WIA and VAS that are managed by third-
3
party managers (Third-Party Manager Models). Clients participating in the WorldMAP program will
typically hold investments based on one or more of these types of model or customized portfolios.
Additionally, through participation in WorldMAP, a client may choose to receive certain tax strategy
services and direct indexing services for accounts for which those services are appropriate.
Additionally, VAS publishes its own Form ADV, Part 2A, which describes the VAS platform and services in
more detail. The current brochure for VAS will be delivered to clients who participate in the WorldMAP
program, and we encourage our clients to review that brochure. The decision to liquidate security issues
or mutual funds may result in tax consequences that should be discussed with the client’s tax advisor.
Factors that may affect the orderly and efficient manner would be size and types of issues, liquidity of the
markets, and market makers’ abilities. Should the necessary securities’ markets be unavailable, and trading
suspended, efforts to trade will be done as soon as possible following their reopening, due to the
administrative processing time needed to terminate client’s
investment advisory services and
communicate.
WorldMAP Advisor Managed Portfolios (AMP)
Accounts participating in AMP are managed and traded by the client’s advisor. Model portfolios created
by advisors will vary from one advisor to the next in terms of investment objectives, risk, trading restraints
and other factors. Advisors may also offer customized portfolios under the AMP program. AMP offers
clients and their advisor the flexibility to structure portfolios in any manner deemed suitable for each
client. Whether in a model or customized portfolio, allowable investments include, but are not limited to,
equities, fixed income securities, mutual funds, partnership interests, certain unit investment trusts
(“UITs”), managed futures funds, ETFs, options or any combination thereof.
Portfolios are constructed based on the investment goals established by the client. Prior to opening an
account, the client and the advisor will discuss the client’s investment objectives and risk tolerance. From
that information, the advisor will either recommend a model portfolio or will construct a portfolio that
best matches the client’s individual needs which will be managed by the advisor. The client may impose
reasonable restrictions on investing in certain securities or types of securities. After the client’s initial
investment, the advisor performs ongoing monitoring and due diligence to ensure the portfolio continues
to meet the relevant investment objectives for which the portfolio was originally designed, making changes
as needed.
AMP accounts can include many combinations of securities and strategies. As such, the advisor will discuss
the risks associated with the account holdings and/or strategy to ensure the client understands each asset
and/or technique used to manage the account.
WorldMAP Cota Street Models
For the Cota Street Models, the WIA Investment Team analyzes securities and then selects and allocates
those securities that the team believes to be the best choices to achieve each model’s objectives within
its constraints. These models are made available to the entire network of WIA advisors, but there is no
obligation for any advisor to use the models. The models are monitored and reviewed regularly by WIA to
ensure they continue to meet the investment standards, objectives and constraints for which they were
originally selected and allocated. The team will make changes to the models as necessary.
4
WorldMAP Third-Party Manager Models
The WIA Investment Team also analyzes Third-Party Manager Models available on the VAS platform and
selects certain of those models to be made available to WIA clients. These are made available to the entire
network of WIA advisors, but there is no obligation for any advisor to use the models. These models are
available for all WIA advisors and WIA clients, subject to client suitability and investment objectives.
After the initial approval of the models, the WIA Investment Team performs ongoing monitoring and due
diligence of these models to ensure they continue to meet their investment standards and adhere to the
investment philosophy and process for which they were originally selected. If a particular Third-Party
Manager Model materially deviates from its stated objectives and/or constraints, and/or performance or
risk is materially different from the WIA Investment Team’s expectations for the model, the WIA
Investment Team may decide to remove the model from the WorldMAP Model Program. Additionally, the
WIA Investment Team may remove a Third-Party Manager Model for any reason at any time without
advance notice. The WIA Investment Team will provide recommendation(s) for replacement of those
models the WIA Investment Team removes from the WorldMAP Model Program. It is possible that a
client’s account will be adversely affected if this should happen, as WIA would no longer follow the trading
activity of the portfolio manager. In those instances, clients have the option to have their account invested
in a new model, or clients may elect to hold one or more securities that were dictated by the discontinued
model while not continuing to follow the model in its entirety. In these scenarios, the advisor will discuss
alternatives with the client.
WorldMAP Tax-Managed Overlay (TMO)
WorldMAP Tax-Managed Overlay (TMO) is available via the VAS platform for clients seeking potential
benefits from active tax management of their non-qualified accounts. TMO is a service by which the
client’s portfolio is actively managed to generate capital losses to help offset capital gains generated in the
subscribing account throughout the tax year. TMO also includes tax transition services for assets being
transferred into the account. The tax transition service helps to move client assets from another model or
strategy into the WorldMAP model in a tax-efficient manner based on each client's individual tax situation.
TMO is optional to clients and available for an additional fee (TMO Fee), over and above the Program Fee.
WorldMAP (Cota Street Direct Indexing)
WorldMAP Cota Street Direct Indexing (CSDI) is available to clients seeking potential benefits from active
tax management and/or personalization of their non-tax-qualified accounts. CSDI is an investment service
in which WIA buys and sells securities to replicate the performance and risk characteristics of a specified
equity index, while simultaneously harvesting securities to create capital losses to help offset capital gains
generated in the client account. To participate in the CSDI program, TMO is also required for the entire
subscribing client account. CSDI is optional to clients and is available for a fee (CSDI Fee) that is in addition
to the Program Fee and TMO Fee, both of which are described below.
Item 5 – Fees and Compensation
WIA Wealth
The specific manner in which fees are charged by the Firm is established in a client’s written agreement
(“Agreement”). Fees, for accounts custodied at Schwab, are generally based on a percentage of assets
under management as of the last day in the previous month, calculated at an annual rate and billed
monthly in advance based on the number of days in that particular month. If the account is custodied at
Fidelity the fees are generally based on a percentage of assets under management as of the last day in the
5
previous month, calculated at an annual rate, divided by 12 and billed monthly in advance. In some
instances, other methodologies for calculations of fees (i.e., fees payable in arrears or on a quarterly basis)
may be employed and will be specifically outlined in the client’s Agreement. WIA IARs may also use a
custodian other than Schwab or Fidelity, which will be made clear to the client prior to any accounts being
opened. Fees are based on the assets in the account, will never exceed 3.00% and in some instances, may
be negotiated. WIA may be under a flat-fee or tiered structure as described in more detail in the client
Agreement.
The firm, in its sole discretion, may waive or charge a lesser investment advisory fee based upon certain
criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future
additional assets, dollar amounts of assets to be managed, related accounts, account composition,
negotiations with clients, etc.).
If a client’s Agreement becomes effective as of a day other than the first day of a billing period or if a
termination of a client’s Agreement is effective on a day other than the last day of a billing period, the Fees
for that billing period shall be prorated (calculated on a per diem basis) and the applicable amount
promptly paid by Client to WIA or refunded by WIA to Client, as the case may be. Fees will be deducted
from the account directly unless the Client requests to be billed separately. Generally, no further proration
is done for additions or withdrawals made during the fee period.
Fees may be reduced or waived for WIA employees.
Financial Planning
WIA may charge a fixed agreed upon rate or an hourly rate for any agreed upon financial planning work.
This rate may vary depending on the requested task; however, the client will be provided with an estimate
in advance. In some instances, clients may elect to engage in ongoing financial planning for which an
ongoing fee will be charged. In these instances, the client will be notified in advance of the cost of the
ongoing financial planning, and details about the recurring fee will be specifically outlined in the client’s
Agreement.
Financial planning fees will be charged at an agreed upon fixed fee, generally ranging from $1,000 to
$5,000, or on an hourly basis, generally ranging from $100 to $275 per hour, depending on the nature and
complexity of each client's circumstances. In certain instances, financial planning fees may exceed these
rates, typically in cases of highly complex circumstances. The firm may also, in its sole discretion, waive or
charge a lesser financial planning fee based upon certain criteria (e.g., historical relationship, anticipated
future earning capacity, anticipated future additional assets, related accounts, negotiations with clients,
etc.). When charging an hourly financial planning fee, an estimate for the total hours will be determined
at the start of the advisory relationship. Up to 50% of the estimated fee may be due upon signing the
Agreement, with the balance (based on actual hours) due upon presentation of the plan to the client.
Typically, the financial plan will be presented to the client within 90 days of the contract date, provided
that all of the relevant information needed to prepare the financial plan has been promptly provided by
the client. The client may terminate its arrangement at any time, in writing, and will be refunded a portion
of the fee based upon a pro-rated calculation related to the time and expense expended by the firm.
WorldMAP-Related Fees and Conflicts of Interest
Program Fee. WIA charges a Program Fee on all accounts managed in the WorldMAP program (“Program
Fee”). From the Program Fee, WIA pays a variety of types of fees to VAS, such as asset-based fees for
access to technology, model trading services, back-office services such as account setup and maintenance,
6
and fees for other services provided under WIA’s agreements with Vestmark and VAS. However, the fees
payable to Vestmark and VAS will be less than the Program Fee, meaning that a portion of the Program
Fee will be retained by WIA. This creates an incentive for WIA to recommend participation in the
WorldMAP program, which presents a conflict of interest. This conflict of interest is mitigated through
disclosure to clients and by assuring that all client recommendations are made in the client’s best interest,
considering all relevant factors, including fees.
The way in which WIA compensates our advisors represents an additional conflict of interest with respect
to possible recommendations to participate in the WorldMAP program. Specifically, our advisors typically
receive a portion of the investment advisory fees WIA receives for management of our clients’ accounts.
But an amount equal to the Program Fee will be deducted from the advisory fee prior to calculating the
portion of the fee that the advisor would otherwise receive. That means that an advisor has a disincentive
to recommend participation in the WorldMAP Program because he or she will receive less compensation
for participating accounts.
Additionally, if the advisor does recommend the WorldMAP program to a client, he or she has an incentive
to raise the client’s investment advisory fee for that client by the amount of the Program Fee, so that the
net compensation to the advisor is equal or approximately equal to that which the adviser receives for
both WorldMAP and non-WorldMAP clients. In other words, some advisors will pass on to their client the
cost of participating in the program. In some cases, advisors will incur administrative or other expenses for
clients participating in the WorldMAP programs. These expenses will sometimes be passed on to the client
in the form of increased investment advisory fees. This will vary from one advisor to the next.
The conflicts of interest discussed above are mitigated through disclosure to clients and by assuring that
all client recommendations are made in the client’s best interest, considering all relevant factors, including
fees. WIA anticipates that many advisors will, in fact, charge a higher advisory fee for WorldMAP-
participating clients than for non-WorldMAP participating clients. Clients should discuss with their advisor
the amount of fees incurred in connection with participating in WorldMAP, whether the costs of
participating in the program are being passed on to clients, and whether the client’s advisory fee is
reasonable in relation to the benefits provided by participating in a WorldMAP model.
Strategy Fee. Clients will pay an additional Strategy Fee for some but not all model portfolios or strategies.
Unlike the Program Fee, which is paid out of the advisory fee the client is charged, the Strategy Fees are
charged in addition to the client’s advisory fee. The Strategy Fee is paid to Vestmark who, in turn, pays
the fee to the relevant strategist or third-party manager. The amount of the Strategy Fee varies depending
on the strategy. Strategy fees for approved managers will be published as “Guide to Fees” on a regular
basis to https://worldadvisors.com/important-disclosures.
In the case of Cota Street Model Portfolios, the Strategy Fee is paid to WIA. This creates a conflict of interest
in the form of an economic incentive for WIA and its advisors to recommend Cota Street strategies or
models. This conflict of interest is mitigated through disclosure to clients and by assuring that all client
recommendations are made in the client’s best interest, considering all relevant factors, including fees.
In the case of advisor created model portfolios, the Strategy Fee is paid to the advisor. This creates a conflict
of interest in the form of an economic incentive for WIA advisors to recommend their own strategies or
models. This conflict of interest is mitigated through disclosure to clients and by assuring that all client
recommendations are made in the client’s best interest, considering all relevant factors, including fees.
7
Tax Management Fee (TMO). The TMO Fee is charged to the subscribing client account by WIA. Unlike the
Program Fee, which is paid out of the advisory fee the client is charged, the TMO Fee is charged in addition
to the client’s advisory fee. WIA pays a variety of types of fees to VAS in connection with accounts that
subscribe to TMO, but WIA retains a portion of the TMO Fee. This creates a conflict of interest because it
incentivizes WIA and its advisors to recommend the TMO service to clients for their eligible accounts. WIA
mitigates this conflict of interest through disclosure and by assuring that all investment recommendations
are made in the client’s best interest. The Tax Management fee will be published within the “Guide to
Fees” on a regular basis to https://worldadvisors.com/important-disclosures.
Direct Indexing Fee (CSDI Fee). The CSDI Fee is charged to the subscribing client account by WIA. Unlike
the Program Fee, which is paid out of the advisory fee the client is charged, the CSDI Fee is charged in
addition to the client’s advisory fee. WIA pays a variety of types of fees to VAS in connection with accounts
that subscribe to CSDI, but WIA retains a portion of the CSDI Fee. This creates a conflict of interest because
it incentivizes WIA and its advisors to recommend the CSDI service to clients for their eligible accounts.
WIA mitigates this conflict of interest through disclosure and by assuring that all investment
recommendations are made in the client’s best interest. The Direct Indexing fee will be published within
the “Guide to Fees” on a regular basis to https://worldadvisors.com/important-disclosures.
General Fee Information
The advisory fees and transaction charges do not cover charges imposed by third parties for investments
held in the account, such as contingent deferred sales charges or 12(b)-1 trails on mutual funds. In
addition, each mutual fund or Third-Party Money Manager charges asset management fees, which are in
addition to the advisory fees charged by our firm. The fees charged by such funds or managers are
disclosed in the advisory agreement that the client signs and each fund’s prospectus or Manager’s ADV
Part 2A. Accounts may require a minimum advisory fee or quarterly maintenance fee that will be detailed
in the applicable advisory agreement. The Management Fee also does not cover custodial or platform fees
and charges in connection with debit balances; margin interest; odd-lot differentials; IRA fees; transfer
taxes; exchange fees; wire transfers; extensions; non-sufficient funds; mailgrams; legal transfers; bank
wires; postage; costs associated with exchanging foreign currencies; and SEC fees or other fees or taxes
required by law.
Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees.
12b-1 fees come from fund assets, therefore, indirectly from client assets. Some mutual funds within this
program pay 12(b)-1 service fees (typically 0.25% per year) to the Custodian. For certain ERISA accounts,
12b-1 fees in whole or in part are credited back to the account to offset fees charged. The mutual funds
the Firm could purchase or recommend offer a variety of share classes, including some that do not charge
12(b)-1 fees and are, therefore, less expensive. Typically, WIA does not recommend mutual funds that
charge 12(b)-1 fees when other share classes are available. However, there are instances in which WIA
would recommend a mutual fund that carries a 12(b)-1 fee, even when a lower-cost share class is available
for the same fund. For example, a lower-cost class share may not be available to WIA due to investment
minimums, or the chosen custodian may make available certain funds which do not carry a transaction
fee. WIA does not receive any part of the fees charged by Mutual Funds, and as a fiduciary to your account,
will select the most appropriate fund share class.
In addition to the fees outlined above, a separate fee of up to 0.05% (5 basis points) may be levied by
Envestnet or Tamarac, the firm's technology platforms used for billing and reporting (“Platform Fee”). This
Platform Fee may be levied in addition to the advisory fee assessed for investment management services
8
and is not billed as a separate line item. The annual Envestnet/Tamarac Platform Fee will not exceed 0.05%
or a $100.00 minimum annual fee, prorated monthly, whichever is greater. Accordingly, a client might pay
an effective rate greater than the rate specified in the fee schedule on their Advisory Agreement. The
$100.00 fee is reset annually based on the month the account was originally opened. In the event a Third-
Party Money Manager is implemented in a client portfolio, the annual Envestnet/Tamarac Platform Fee
will not exceed 0.15% or a $150.00 minimum annual fee, prorated monthly, whichever is greater. This fee
may be reduced based on the amount of investable assets and is in addition to the advisory fee assessed
by WIA and the Third-Party Money Manager for investment management services.
Although WIA believes its fees are reasonable considering the services provided, clients should be aware
that such fees may be more or less than the fees and commissions associated with investment advisory
and brokerage services purchased separately. The comparison is dependent upon several factors, including
the frequency of brokerage activity in the client’s account, the size of the account under management, and
any negotiated fee arrangements with respect to the account. An investor should consider these factors
prior to opening an Advisory Account with WIA. Transaction fees charged may be higher than those
otherwise available if the services were provided separately for a discrete fee or if an Investment Advisor
were to select brokerage and negotiate commissions in the absence of the extra consulting service
provided. Clients should consider the value of the additional consulting services when making such
comparisons. The combination of custodial, consulting, and brokerage services may not be available
separately or may require multiple accounts, documentation, and fees. All fees described herein may be
subject to negotiation depending on a range of factors including, but not limited to, account size and
overall range of services requested.
Clients have the option to purchase investment products that WIA and its IARs recommend through other
brokers or agents that are not affiliated with WIA.
Account Termination
Upon notification of the death of a client, WIA will cease advisory services. No additional trading or
liquidations will occur, and the account will be frozen until the necessary documents are provided to
transfer the account to the individual’s estate, joint owner, or beneficiary, as applicable based on the
account type and instructions set up by the client. In addition, all POAs will be canceled. Any prepaid,
asset-based fees will be prorated to the date the Firm was notified and rebated to the client.
The firm may initiate termination of the contract, with or without cause, upon not less than 30 days’ prior
written notice provided to the Client. The contract termination will be effective on the date specified in
the notice, provided it is at least 30 days after the client’s receipt of such. WIA does not charge a fee for
terminating the contract, but the custodian may charge a termination fee.
Upon written receipt of notice from the client to terminate its client Agreement, and unless specific
transfer instructions are received, WIA and its representative(s) will immediately cease advisory services.
Should the client provide specific instructions to liquidate, WIA will proceed with liquidation of the client’s
account in an orderly and efficient manner. There will not be a charge by WIA for such redemption;
however, the client should be aware that certain securities impose redemption fees as stated in each
company’s prospectus. Additionally, custodians may assess additional redemption fees for short-term
liquidations. Clients must keep in mind that the decision to liquidate security issues or mutual funds may
result in tax consequences that should be discussed with the client’s tax advisor. Factors that may affect
the orderly and efficient manner would be size and types of issues, liquidity of the markets, and market
makers’ abilities. Should the necessary securities’ markets be unavailable, and trading suspended, efforts
9
to trade will be done as soon as possible following their reopening. Due to the administrative processing
time needed to terminate client’s investment advisory services and communicate the instructions to
client’s Investment Advisor, termination orders received from clients are not market orders; it may take
several business days under normal market conditions to process the client’s request. During this time, the
client’s account is subject to market risk. WIA and its representative(s) are not responsible for market
fluctuations in the client’s account from time of written notice until complete liquidation. All efforts will
be made to process the termination in an efficient and timely manner.
Item 6 – Performance-Based Fees and Side-By-Side Management
WIA does not charge any performance-based fees (fees based on a share of capital gains on or capital
appreciation of the assets of a client).
Item 7 – Types of Clients
WIA provides advisory services to Individuals and Retirement Plans including, 401(k) Plans, 403(b) Plans,
pensions and profit-sharing plans, non-qualified plans, foundations, endowments, corporations, or other
businesses not listed above. For Wealth Clients, Adviser generally does not require a minimum account
size but may impose a minimum annual consulting fee.
Certain Third-Party Money Managers may require a higher minimum account size as disclosed in the
individual manager’s Firm Brochure. Under certain circumstances, the minimum may be waived, including
related accounts that may be combined to meet the minimum if the services involved may otherwise be
provided.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
WIA’s investment strategy begins with an understanding of a client’s financial goals. Advisors use
demographic and financial information provided by the client to assess the client’s risk profile and
investment objectives in determining an appropriate plan for the client’s assets. Investment strategies
ordinarily include long- or short-term purchases of stock portfolios, mutual funds, fixed income securities
and third-party money managers, if appropriate. Should the client’s risk profile and/or objectives change
during the advisory relationship, the client must notify the advisor accordingly.
Investment recommendations are based on an analysis of the client’s individual needs and are drawn from
research and analysis. Security analysis methods may include the following:
•
•
Fundamental analysis: WIA attempts to measure the intrinsic value of a security by looking at
economic and financial factors to determine if the company is underpriced or overpriced.
Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk, as the price of a security can move up or down along with the overall market regardless of
the economic and financial factors considered in evaluating the stock.
Technical analysis and charting: WIA attempts to determine the trend of a security by studying
past market data, including price and volume. This presents a potential risk, as the price of a
security can change direction at any time and past performance is not a guarantee of future
performance.
• Cyclical analysis: WIA attempts to identify the industry cycle of a company to determine whether
the company is in a market introduction phase, growth phase or maturity phase. Generally
projected revenues, growth potential and business risk may fluctuate based on the company’s
cycle stage.
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Information for this analysis may be drawn from financial newspapers, websites, and magazines, research
materials prepared by others, annual reports, corporate filings, prospectuses, company press releases,
and/or corporate ratings services.
It is important to note that investing in securities involves a risk that clients should be prepared to bear.
For any risks associated with Investment Company products, please refer to the prospectuses for
additional details about these risks. WIA’s investment approach constantly keeps the risk of loss in mind.
These risks include, but are not limited to:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
•
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of a
security’s particular underlying circumstances. For example, political, economic, and social
conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar
next year, because purchasing power is eroding at the rate of inflation.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed
income securities.
•
•
• Business Risk: These risks are associated with a particular industry or a particular company within
an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy
process, before they can generate a profit. They carry a higher risk of profitability than an electric
company, which generates its income from a steady stream of customers who buy electricity no
matter what the economic environment is like.
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets
are more liquid if many traders are interested in a standardized product. For example, Treasury
Bills are highly liquid, while real estate properties are not.
Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times and bad.
During periods of financial stress, the inability to meet loan obligations may result in bankruptcy
and/or a declining market value.
Item 9 – Disciplinary Information
Registered investment Advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to an evaluation of WIA or the integrity of WIA’s management. WIA has no
disclosable information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
WIA is a wholly owned subsidiary of WIA Holdings, LLC. Under the common control of WIA Holdings, LLC,
WIA is affiliated with Goldman Sachs & Co., LLC, a FINRA broker-dealer (Member SIPC) and SEC Registered
Investment Adviser, and World Investments, LLC, a FINRA broker dealer (Members SIPC), WIA is also
affiliated with World Insurance Associates, LLC, Scotts American, LLC, Keating, LLC, ESA Associates, LLC,
FastComp, LLC, Hamond Safety Management, LLC, Pacific Coast NCA Premium Finance, LLC, and World
Insurance Programs, LLC, all insurance agencies engaging in Life, Health, Long Term Care, Variable, and
various other Insurance business.
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Recommendations for Goldman Sachs investment products are limited to a small subset of products
approved by WIA. No incentives are provided to WIA or WIA Investment Advisor Representatives to
recommend Goldman Sachs products over other investment products.
WIA is also affiliated with other financial services companies, but does not have any shared business
dealings, operations, referral programs, clients, representatives, or premises with these other companies,
and has no reason to believe the firm’s relationship with them otherwise creates a conflict of interest with
WIA clients. A full list of WIA’s affiliates will be provided upon request.
Investment Adviser Representatives (“IARs”) of WIA may effect securities transactions for Clients as
registered representatives of World Investments, LLC. (“WI”) or St. Bernard Securities, LLC (“St. Bernard”),
both FINRA broker-dealers. WIA is affiliated with WI through the common control and ownership by WIA
Holdings, LLC. WIA has no affiliation with St. Bernard. Advisors that are registered representatives of these
firms may recommend either of the two firms with whom they are registered for broker-dealers services.
Factors for such a recommendation may be when transaction compensation is seen as a benefit to the
client. For broker-dealer services, WI or St. Bernard, or their associated persons, may receive
compensation, which is separate and distinct from compensation related to investment advisory services.
Commissions paid to advisors for broker-dealer services may be higher or lower than those paid by other
brokers.
All FINRA, SEC, and other regulatory agencies disclosure requirements and policies are observed for all
transactions. If a trade error were to occur, it may result in profit or loss to the firm. The firm has controls
in place to limit such trade errors. Investment Advisers will not participate in any profits resulting from
such errors.
Some IARs of WIA may also be registered as IARs of Acrisure Investment Advisory Solutions, LLC
(“Acrisure”). However, these IARs do not effect any transactions through Acrisure. One WIA Advisor is also
registered as an Advisor with Nexus338, an advisory firm providing technology-based retirement plan
managed account services to non-WIA clients. WIA is not affiliated with Acrisure or Nexus338.
Individuals may also write Insurance business through Pensionmark Partners Insurance Services, LLC
(“PPIS”) as independent insurance agents. PPIS is affiliated with WIA through common control and
ownership. PPIS is an insurance producer group engaging in Life, Health, Long Term Care and Variable
Insurance business. Variable insurance products will be offered exclusively through WI, while fixed
products will be offered directly with an insurance carrier through the producer group contracts.
Compensation will be paid directly by these entities.
Individuals licensed as Registered Representatives or Insurance Agents may spend as much as 50% of their
time on these non-advisory activities. When a client’s Advisor is acting in their capacity as registered
representatives or independent insurance agents, clients will be charged separately from their advisory
services. Clients have the option to purchase investment products that we recommend through other
brokers or agents that are not affiliated with WIA.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
WIA has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of
business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the
confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering,
restrictions on the acceptance of significant gifts and the reporting of certain gifts and business
12
entertainment items, and personal securities trading procedures, among other things. All supervised
persons at WIA must acknowledge the terms of the Code of Ethics annually, or as amended.
Advisors of WIA may buy or sell securities that are recommended to clients. WIA’s employees and persons
associated with WIA are required to follow the Code of Ethics. Subject to satisfying this policy and
applicable laws, officers, directors and employees of WIA and its affiliates may trade for their own accounts
in securities which are recommended to and/or purchased for WIA’s clients. The Code of Ethics is designed
to assure that the personal securities transactions, activities and interests of the employees of WIA will
not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such
decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code,
certain classes of securities have been designated as exempt transactions, based upon a determination
that these would not materially interfere with the best interest of WIA’s clients. In addition, the Code
requires pre-approval of many transactions and restricts trading in close proximity to client trading activity.
Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the
same securities as clients, there is a possibility that employees might benefit from market activity by a
client. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts
of interest between WIA and its clients.
Advisors may recommend and trade in the same securities with clients and/or related accounts at or about
the same time. Generally, this would pose a conflict if the Advisor or related account were given a better
price than the client. To mitigate this conflict, it is procedure to not trade an Advisors account or related
persons account on the same day as a client unless the client gets the better price.
Trades may be done on an aggregated basis when consistent with WIA's obligation of best execution. In
such circumstances, the Advisor (or related account) and client accounts will share commission costs
equally and receive securities at a total average price. WIA will retain records of the trade order (specifying
each participating account) and its allocation, which will be completed prior to the entry of the aggregated
order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will
be allocated on a pro rata basis. Any exceptions will be explained on the order confirmation.
WIA’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting WIA at
(800) 833-1862 or by sending an email to compliance@worldadvisors.com.
Item 12 – Brokerage Practices
WIA generally recommends that clients establish brokerage accounts with Charles Schwab & Co., Fidelity
Institutional Wealth Services, Pershing LLC or Pershing Advisory Services (“Schwab”, “Fidelity”, “Pershing”,
or collectively, “the Custodian(s)”), SEC registered broker-dealers, members FINRA /SIPC, to maintain
custody of clients’ assets and to effect trades for their accounts. In some instances, WIA may recommend
clients establish brokerage accounts with other custodians. We recommend the services of the Custodian
based on several factors including financial strength, reputation, execution, pricing, responsiveness, fees,
research, and other services. Although WIA may recommend that clients establish accounts at the
Custodian, it is the client’s decision to custody assets with the Custodian.
WIA does not direct brokerage to a particular venue for execution but rather relies on the Custodian (with
the exception of bond trades that may be directed to a third-party available to WIA through the
Custodians’ Platform). Fees and commissions charged by the Custodian may be higher or lower than
obtainable elsewhere. Circumstances occasionally arise when the Custodian must impose a separate or
special handling or custodial charge for acting as custodian for an exempt security or private placement
13
that was recommended by WIA to a WIA Advisory Client. On a case-by-case basis, WIA may cover the cost
of this type of fee on a “value-added” basis by having the fee directly billed to WIA rather than the Client
or by reimbursing the Client. WIA is independently owned and operated and not affiliated with any
Custodian.
Custodians may make products and services available to WIA that benefit WIA but may not directly benefit
its clients’ accounts. Many of these products and services are used to service all or a substantial number
of WIA accounts. Some of these products and services provided include software and other technology
that provides access to client account data (such as trade confirmations and account statements); provides
research, pricing, and other market data; facilitates payment of fees from clients’ accounts; and assists
with back-office functions, recordkeeping, and client reporting.
WIA clients can benefit when trades are aggregated to obtain volume discounts on execution costs. Trade
aggregation refers to the practice of combining orders for execution. When consistent with WIA’s duty to
obtain best execution, multiple client transactions will be aggregated into a single order to obtain the best
price for clients. In such circumstances, the accounts will share commission costs equally and receive
securities at a total average price. WIA will retain records of the trade order (specifying each participating
account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed
orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a
pro-rata basis. Any exceptions will be explained on the order. Trade aggregation will typically be done at
the branch level.
For Third-Party Money Managers WIA recommends, WIA does not direct brokerage in these accounts.
Brokerage practices of separately managed accounts are disclosed separately in their Brochure(s).
Item 13 – Review of Accounts
Accounts are assigned to who are responsible for performing periodic reviews and consulting with the
respective client. Accounts are reviewed no less than annually by the Advisor. Factors that are considered
during such reviews include, but are not limited to, the following: investment objectives, targeted
allocation, current allocation, suitability, performance, monthly distributions, concentrated positions,
diversification, and outside holdings. Examples of situations that may impact Client’s account would be
the following: performance that is not in line with the client’s “downside risk tolerance,” change in
investment objective, the client making a significant addition or withdrawal of capital from the account,
rebalancing of the portfolio if current allocation and targeted allocation are not consistent, concentrated
position(s) that could lead to volatility, etc. Accounts may also be subject to a secondary review by a
designated supervisor. Such supervisory reviews will be done on a periodic basis. The supervisor will
oversee the selected accounts for the same triggering factors as mentioned above.
Advisor has the ability to provide performance reports for assets under advisement through data
aggregation and portfolio reporting tools (e.g., Envestnet and Tamarac). For data aggregation purposes,
these reports may include information on assets managed by the Adviser for both commissionable and
fee-based accounts.
The client agrees to inform the firm in writing of any material changes to the information included in the
Client Profile or any other change in the client’s financial circumstances that might affect the manner in
which the client’s assets should be invested. Clients may contact the firm during normal business hours to
consult with the firm concerning the management of the client’s account(s).
14
Item 14– Client Referrals and Other Compensation
WIA, in some instances, may compensate third-party promoters for Client referrals. For a promoter to be
compensated by WIA for referring a Client to WIA, the promoter must be engaged by WIA under a
Promoter or Referral Agreement (“Agreement”) in compliance with Section 206(4)-1 of the Investment
Advisers Act of 1940. In general, a promoter is compensated by a percentage of the advisory fee collected
for a limited period specified in the Agreement. The Client pays no additional fee for the referral over and
above WIA’s quoted advisory fee; on the contrary, the fee the Adviser earns is reduced by the amount of
the compensation to the promoter. A Client who is referred by a promoter will receive the promoter’s
separate Disclosure Statement describing the nature of the arrangement in detail.
Clients may request details regarding a particular Agreement by contacting us toll-free at (800) 833-1862
or by emailing compliance@worldadvisors.com.
Certain mutual fund companies, recordkeepers, or other third parties (“Third Parties”) will periodically
sponsor educational seminars for participating financial advisors designed to facilitate and promote
professional development and product knowledge. To encourage participation, Third Parties will cover
travel-related expenses for certain advisors to attend these meetings. Such expense reimbursements are
only permissible by WIA when pre-approved, and after review of the agenda and estimated costs. WIA will
not approve expense reimbursements by the Third Parties for travel unless the travel expenses appear
reasonable and customary; lavish expenses will not be approved. WIA Advisors do not base
recommendations on the expectation of such conference and travel.
In addition, WIA or its Advisors may host events where Third Parties “sponsor” a specific portion of the
event, e.g., the cost of a dinner. WIA Advisors do not base recommendations on the expectation of such
event sponsorship.
Item 15 – Custody
WIA is deemed to have custody of client funds because investment advisory fees are directly debited from
some Client accounts. Debiting fees is done pursuant to authorization provided by the Client. Clients
should receive statements at least quarterly from the selected qualified Custodian that holds and
maintains client’s investment assets. WIA urges clients to carefully review such statements and compare
the official custodial records to the account statements that WIA may provide. WIA’s statements may vary
from custodial statements based on accounting procedures, reporting dates, or valuation methodologies
of certain securities.
WIA is also deemed to have custody of client assets as a result of certain Clients’ authorization for WIA
and/or its IARs to distribute assets from their account(s) to a specific named recipient on demand in
accordance with a standing letter of instruction. WIA complies with the SEC No-Action Letter dated
2/21/2017 (Investment Adviser Association) allowing firms complying with the provisions of the No Action
Letter to forego an annual surprise custody examination with respect to those assets.
Item 16 – Investment Discretion
WIA typically acts in a discretionary capacity for its Wealth Clients but may act in a non-discretionary
capacity. Discretionary authority provides the WIA Advisor with the authority to determine, without
obtaining specific Client consent, both the securities to be bought and sold in their accounts as well as the
dollar amount/quantity of securities to be bought and sold.
15
If discretionary authority is granted to select the identity and amount of securities to be bought or sold,
clients must authorize such discretion in writing in the advisory agreement. In all cases, such discretion is
to be exercised in a manner consistent with the stated investment objectives for the particular client
account. When selecting securities and determining amounts, WIA observes the investment policies,
limitations, and restrictions of the clients for which it advises. Investment guidelines and restrictions must
be provided to WIA in writing.
WIA may recommend Third-Party Money Managers. When acting in a discretionary capacity, the firm can
evaluate managers and may switch money managers or reallocate assets among managers without
consulting the client. When acting
in a non-discretionary capacity, the Advisor will make
recommendations, but only the client has the authority to hire or switch money managers or reallocate
assets between programs. In all cases, the Advisor will monitor the performance of the Third-Party Money
Manager and will make recommendations consistent with the client’s investment objectives and risk
tolerance.
Item 17 – Voting Client Securities
As a matter of firm policy and practice, WIA does not vote proxies on behalf of WIA Wealth advisory clients.
Clients retain the responsibility for receiving and voting proxies for all securities maintained in client
portfolios. Clients should contact their financial advisor if they have any questions and/or to obtain this
information. Clients will receive their proxies directly from their custodian or transfer agent.
Clients can authorize third-party investment managers to vote proxy requests on their behalf in their client
agreements. Please refer to the respective investment manager's Form ADV for a full disclosure of its proxy
voting policies and procedures.
Item 18 – Financial Information
Registered Investment Advisers are required to provide certain financial information or disclosures about
their financial condition. WIA has no financial commitment that impairs its ability to meet contractual and
fiduciary commitments to Clients and has not been the subject of any bankruptcy proceedings.
Privacy Policy
World Investment Advisors, LLC (“WIA”) recognizes that its Clients have an expectation that WIA and its
affiliates will maintain the confidentiality of Clients’ nonpublic personal information. Consequently, WIA
has adopted this Privacy Policy concerning information obtained during the servicing of Client’s account(s).
Nonpublic Information: Nonpublic information obtained by WIA for purposes of providing services
hereunder will not be furnished to third parties for any other purpose other than in furtherance of the
services to be provided hereunder. Notwithstanding the foregoing, WIA may disclose nonpublic
information (i) to the extent such disclosure is required by court order or by a valid order of a governmental
body governmental or quasi-governmental agency (such as FINRA) (ii) after the time of disclosure such
information becomes part of the public knowledge or literature, not as a result of any inaction or action
of WIA, (iii) reasonably necessary for WIA to enforce its legal rights in any dispute with that Client; or (iv)
is approved by Client, in writing, for release. WIA does not disclose nonpublic personal information about
its Clients to any party except as permitted by law.
16
Sources of Personal Information: WIA collects Personal Information about its Clients from meetings with
Clients and on applications or other forms Clients have submitted to WIA, as well as information about
Clients’ investments or transactions with WIA or others (such as third-party service providers or fund
companies) from other sources.
How WIA Protects the Confidentiality of Clients’ Nonpublic Personal Information: WIA does not sell or
trade Clients’ information with nonaffiliated companies. When information is provided to third party
service providers, safeguards are in place to assure that information is used only for the purpose it is
provided. WIA maintains its records on secured computers. Prospective employees are screened for
criminal convictions. Once hired, employees are made aware of WIA’s Privacy Policy and of the confidential
nature of the information they handle. Employees are limited to accessing only that customer information
that is necessary to perform their job functions.
To Whom This Policy Applies: This Notice applies to all WIA Clients who enter into an Advisory Services
Agreement or Customer Agreement with WIA. For Former Clients: WIA’s Privacy Policy continues to apply
even to Clients that have terminated services with the firm.
Internet Cookies: An internet “cookie” is a small amount of data that is placed on to your electronic device
by a website and stored in your internet browser. Cookies allow websites to store things like preferences,
so that it can recognize users when returning to the site and respond appropriately. When individuals
access the worldadvisors.com website, WIA makes use of cookies to improve the load times and
functionality of the website, and in some cases registration pages. WIA may from time to time also utilize
data tracking software to assist in spotting trends and areas of improvement on the website. By accessing
the worldadvisors.com site and embedded web pages, users are providing their express approval allowing
WIA to utilize these technologies to improve services provided. WIA may also use various third-party
cookies to report usage statistics of the service, or to authenticate users and prevent fraudulent access of
user accounts.
Access to and Correction of Information: Upon the written request of Clients, WIA will make available for
review any file that may be maintained for their personal Information; provided, however, that any
Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be
made available. If Clients notify WIA that any information is incorrect, the information will be reviewed.
If WIA agrees the information is incorrect, records will be corrected. If WIA disagrees, Clients may submit
a short statement of dispute, which will be included in any future disclosure of the disputed Information.
Additional California Privacy Disclosures: Please consult the supplemental WIA Privacy Notice for
California Residents for additional disclosures pertinent to California residents.
Further Information: WIA reserves the right to change this Privacy Policy at any time. The examples
contained within this Privacy Policy are illustrations and are not intended to be exclusive. This Policy
attempts to comply with federal and state regulations regarding privacy. Clients may have additional rights
under other foreign or domestic laws that may apply to them.
If the financial advisor servicing a client account leaves WIA to join another firm, the advisor is permitted
to retain copies of client information so that he/she can assist with the transfer of the client account and
continue to serve the client at their new firm.
17
“Opting Out” of Third-Party Disclosures: If a client does not want a financial advisor to retain copies of
client sensitive information when he/she leaves WIA to join another firm, the client may contact the WIA
Compliance Department by phone at (800) 833-1862 or by email at compliance@worldadvisors.com to
request further information regarding this policy.
18
Additional Brochure: WRAP FEE BROCHURE (2026-03-31)
View Document Text
Item 1 – Pensionmark Portfolio Cover Page
World Investment Advisors, LLC
437 Newman Springs Road
Lincroft, New Jersey 07738
Phone: (800) 833-1862
http://www.worldadvisors.com
March 31, 2026
This wrap fee brochure provides information about the qualifications and business practices of World
Investment Advisors, LLC. If you have any questions about the contents of this Brochure, please contact
us at (800) 833-1862 or email compliance@worldadvisors.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.
World Investment Advisors, LLC is a Registered Investment Adviser. Registration of an Investment Adviser
does not imply any level of skill or training. This Brochure is intended, in part, to provide information which
can be used to make a determination to hire or retain an Adviser.
Additional information about World Investment Advisors, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
(Please see page 12 for WIA’s Privacy Policy)
i
Item 2 - Material Changes
The Firm has the following material changes to report since the last annual brochure dated March 31,
2025:
• WIA has changed its principal place of business to 437 Newman Springs Road, Lincroft, New Jersey
07738.
The Firm has made the following clarification within the Brochure:
• Additional clarification for the section ”Other Financial Industry Activities and Affiliations” with
more information about our relationship with Goldman Sachs.
Each year, we will provide each client with (i) a free updated Brochure that either includes a summary of
material changes or is accompanied by a summary of material changes, or (ii) a summary of material
changes that includes an offer to provide a copy of the updated Brochure and information on how clients
may obtain the Brochure.
Our Brochure may be requested by contacting us toll-free at (800) 201-5488 or by sending an email to
compliance@worldadvisors.com.
Additional information about World Investment Advisors, LLC is also available via the SEC’s website at
www.adviserinfo.sec.gov. The SEC’s website provides information about any persons affiliated with World
Investment Advisors, LLC who are registered, or are required to be registered, as investment adviser
representatives of World Investment Advisors, LLC.
ii
Item 3 - Table of Contents
ITEM 1 – COVER PAGE ............................................................................................................................................. I
ITEM 2 - MATERIAL CHANGES ................................................................................................................................ II
ITEM 3 - TABLE OF CONTENTS ............................................................................................................................... III
ITEM 4 - SERVICES, FEES AND COMPENSATION ...................................................................................................... 1
THIRD-PARTY MONEY MANAGEMENT ................................................................................................................................ 1
REASONABLE RESTRICTIONS ............................................................................................................................................. 2
FEES AND COMPENSATION ............................................................................................................................................... 2
ACCOUNT TERMINATION ................................................................................................................................................. 5
ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS .................................................................................. 5
ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION ............................................................................. 5
ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ................................................................ 7
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................ ERROR! BOOKMARK NOT DEFINED.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ........................................ ERROR! BOOKMARK NOT DEFINED.
VOTING CLIENT SECURITIES ................................................................................................ ERROR! BOOKMARK NOT DEFINED.
ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS ...................................................................................... 7
ITEM 9 - ADDITIONAL INFORMATION .................................................................................................................... 7
DISCIPLINARY INFORMATION ............................................................................................................................................ 7
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................................................................................... 7
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............................................... 8
REVIEW OF ACCOUNTS .................................................................................................................................................. 10
CLIENT REFERRALS AND OTHER COMPENSATION ................................................................................................................ 10
INVESTMENT DISCRETION .............................................................................................................................................. 11
FINANCIAL INFORMATION .............................................................................................................................................. 12
PRIVACY POLICY ................................................................................................................................................... 12
iii
Item 4 - Services, Fees and Compensation
World Investment Advisors, LLC (“WIA” or “Adviser”) was established in March 2015. WIA is a wholly
owned subsidiary of WIA Holdings, LLC.
WIA sponsors a wrap fee program (“Pensionmark Portfolio”) that is custodied with Schwab Institutional
(“Schwab”), a division of Charles Schwab & Co, Inc. WIA provides advisory services, giving continuous
advice based on the client’s individual needs. Through personal discussions in which goals and objectives
based upon the client’s personal objectives are established, the firm will develop a personal investment
policy based upon the WIA Client Profile and manage the portfolio according to the criteria.
Through Pensionmark Portfolio, WIA provides investment recommendations based upon a review of the
client’s investment goals, financial situation and risk tolerance. Pensionmark Portfolio accounts may be
managed on a discretionary or non-discretionary basis, as specified in the written advisory agreement
(“Agreement”). Clients have the option of accepting WIA’s recommendations or selecting alternative
investments for their accounts. WIA offers periodic rebalancing of the securities or upon the client’s
direction. We may also provide monitoring and reporting of portfolio performance to clients on a periodic
basis.
Third-Party Money Management
WIA has access to a wide range of non-affiliated investment advisors (“Third-Party Money Managers”) via
the Envestnet ENV2 platform to offer asset allocation and asset management services to WIA advisory
clients. Each IAR shall assist their client in formulating a strategic investment portfolio based on the client's
investment objectives. Once formulated, if appropriate for the client, a suitable Third-Party Money
Managers is selected to implement and continually manage the portfolio. In preparing the portfolio, each
IAR may set restrictions or limitations on the management of the account and will explain to the client the
continual account activity transacted by the Third-Party Money Managers. Also, WIA will periodically
review the current and historical performance record of each Third-Party Money Managers.
WIA has also entered into additional agreements with various non-affiliated Third-Party Money Managers
not available on the Envestnet ENV2 platform to offer asset allocation and asset management services to
WIA advisory clients. In the same way as mentioned above, each IAR shall assist their client in formulating
a strategic investment portfolio based on the client's investment objectives. Once formulated, a suitable
Third-Party Money Managers is selected to implement and continually manage the portfolio. In preparing
the portfolio, each IAR may set restrictions or limitations on the management of the account and will
explain to the client the continual account activity transacted by the Third-Party Money Managers. Also,
WIA will periodically review the current and historical performance record of each Third-Party Money
Managers.
The relationship of WIA with a Third-Party Money Managers will be clearly communicated to all clients in
the Third-Party Money Manager’s Client Services Agreement and/or other similar documentation. Each
Third-Party Money Managers is required to provide WIA and the IAR with a disclosure document
statement, typically a copy of their Form ADV 2A. The Third-Party Money Manager ’s Form ADV 2A will be
provided to the client by IAR.
Additionally, WIA advisors may recommend the use of WealthPath models to Clients. These models are
managed by WealthPath Advisors, LLC. WealthPath advisors are registered as investment advisor
representatives of WIA. When offered to their own clients there are no additional fees; however, when
offered to the client of other advisors (including other WIA advisors), a portion of the total advisory fee
1
charged is paid to WealthPath in exchange for their investment management services. This may create a
conflict of interest, because although the fee paid by the Client is not impacted, WIA receives additional
remuneration when WealthPath is selected as the manager of the Clients’ assets because WealthPath is
not an outsourced Third-Party Money Manager. WIA’s fiduciary responsibility is to always choose the
manager or portfolio that is in the best interest of the client, and WIA does not promote or endorse the
exclusive use of WealthPath as a Third Party Money Manager but will recommend the use WealthPath as
a Third Party Money Manager when it’s in the best interest of the client.
WIA may recommend stocks, bonds, mutual funds, or other assets of any kind, consistent with the client’s
investment objectives. Most types of securities are eligible for purchases in the Pensionmark Portfolio
account including but not limited to, common and preferred stocks, exchange traded funds, closed end
funds, unit investment trusts, corporate and government bonds, certificate of deposit, mutual funds, and
certain wrap class alternative investments, such as hedge funds.
WIA also offers a non-wrap program, WIA Wealth, which is described in the firm’s ADV Part 2A. In a wrap
fee program, clients are charged an all-inclusive wrap fee on Program Assets that covers advisory,
execution, custodial and reporting services on Eligible Assets. A portion of these fees will be paid to WIA
for advisory services. Clients may incur certain charges imposed by custodians, brokers, and other third
parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions. Mutual funds and exchange traded funds also charge internal management fees,
which are disclosed in the fund’s prospectus. Such charges, fees and commissions are exclusive of and in
addition to WIA’s fee, and WIA shall not receive any portion of these commissions, fees, and costs.
Reasonable Restrictions
Each client has the ability to impose reasonable restrictions on the management of his/her account,
including the designation of particular securities or types of securities that should not be purchased for
the account, or that should not be sold if held in the account. If a client’s instructions are unreasonable or
an investment advisor representative believes that the instructions are inappropriate for the client, WIA
will notify the client that, unless the instructions are modified, it may cancel the instructions in the client’s
account. A client will not be able to provide instructions that prohibit or restrict the Investment Adviser
of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities
or types of securities within the fund.
Fees and Compensation
Fees for the Pensionmark Portfolio program will cover advisory services, performance measurement,
transaction costs, custody services, and trading. These fees do not cover the fees and expenses of any
underlying funds purchased in the account. Fees are based on the assets in the account and are generally
assessed monthly.
Pensionmark Portfolio accounts are charged an all-inclusive “wrap fee” on Program Assets that covers
advisory, execution, custodial and reporting services on Eligible Assets. Clients pay all Pensionmark
Portfolio’s usual and customary commissions, transaction fees and other charges for transactions on
Excluded Assets. Commissions and fees on Excluded Assets and other charges will be assessed against a
client’s account on or about the transaction date or such other date assessed by the Pensionmark Portfolio
Program. See the Program Fees and Account Minimums section below for details of fee exclusions,
calculations, refunds and other information. The imposition of the minimum fees may cause the effective
Program Fee rate (expressed as a percentage) to be greater than the fee rates specified in the table below.
2
The specific manner in which fees are charged by the Firm is established in a client’s written agreement. Fees
are generally based on a percentage of assets under management as of the last day in the previous billing
period, calculated at an annual rate, and billed in advance based on the number of days in that particular
period. In some instances, other methodologies for calculations of fees (i.e., fees payable in arrears or on a
quarterly basis) may be employed and will be specifically outlined in the client’s Agreement. Fees are usually
based on the assets in the account per the schedule below and in some instances, may be negotiated. WIA may
also engage with clients under a flat-fee structure; however, the fees assessed will not exceed the percentage
fees outlined below.
Fee Schedule
Gross Market Value
$0 - $500,000
$500,001 - $1,000,000
$1,000,001 - $2,000,000
$2,000,001 - $5,000,000
Over $5,000,001
Maximum Annual Fee
3.00%
2.75%
2.50%
2.25%
2.00%
A minimum annual fee of $30 per quarter ($120 annually) will be charged. Accordingly, a client may pay an
effective rate greater than the rate specified in the fee schedule shown above. The firm, in its sole discretion,
may waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g.,
historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets,
dollar amounts of assets to be managed, related accounts, account composition, client negotiations, etc.).
In addition to the fees outlined above, a separate fee of up to 0.05% (5 basis points) may be levied by Envestnet
or Tamarac, the firm's technology platforms used for billing and reporting (“Platform Fee”). This Platform Fee
may be levied in addition to the advisory fee assessed for investment management services and is not billed as
a separate line item. The annual Envestnet/Tamarac Platform Fee will not exceed 0.05% or a $100.00 minimum
annual fee, prorated monthly, whichever is greater. Accordingly, a client might pay an effective rate greater
than the rate specified in the fee schedule on their Advisory Agreement. The $100.00 fee resets annually based
on the month the account was originally opened. In the event a Third-Party Money Manager is implemented
in a client portfolio, the annual Envestnet/Tamarac Platform Fee will not exceed 0.15% or a $150.00 minimum
annual fee, prorated monthly, whichever is greater. This fee may be reduced based on the amount of investable
assets and is in addition to the advisory fee assessed by WIA and the Third-Party Money Manager for
investment management services.
If a client’s Agreement becomes effective as of a day other than the first day of a billing period or if a
termination of a client’s Agreement is effective on a day other than the last day of a billing period, the Fees for
that billing period shall be prorated (calculated on a per diem basis) and the applicable amount promptly paid
by Client to WIA or refunded by WIA to Client, as the case may be. Fees will be deducted from the account
directly unless the Client requests to be billed separately. Generally, no further proration is done for additions
or withdrawals made during the fee period.
A portion of the fees described herein will be paid to WIA Financial Advisors in connection with the
provision of investment advice and/or client-related services within those programs. This compensation
may be more than WIA’s Financial Advisors would receive if clients paid separately for investment advice,
brokerage, and other services and therefore, WIA Financial Advisors may have a financial incentive to
recommend the program services over other programs or services.
Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees.
12b-1 fees come from fund assets, therefore, indirectly from client assets. Some mutual funds within this
3
program pay 12(b)-1 service fees (normally 0.25% per year) to the Custodian. For certain ERISA accounts,
12b-1 fees in whole or in part are credited back to the account to offset fees charged. The mutual funds
the Firm could purchase or recommend offer a variety of share classes, including some that do not charge
12(b)-1 fees and are, therefore, less expensive. Typically, WIA does not recommend mutual funds that
charge 12(b)-1 fees when other share classes are available. However, there are instances in which WIA
would recommend a mutual fund that carries a 12(b)-1 fee, even when a lower-cost share class is available
for the same fund. For example, a lower-cost class share may not be available to WIA due to investment
minimums, or the custodian may make available certain funds which do not carry a transaction fee. WIA
does not receive any part of the fees charged by Mutual Funds, and as a fiduciary to your account, will
select the most appropriate fund share class.
The wrap program may cost the client more or less than purchasing such services separately and will
depend on the trading activity in the client’s account. The cost of non-wrapped investment advisory
services may be lower than investment advisory services provided under the wrap program. Because WIA
may receive more compensation from a client from the client’s participation in the Program than if the
client received advisory services and brokerage services separately, WIA may have a financial incentive to
recommend the Program to clients over other types of advisory services.
WIA may give advice to others that may be different from the advice given to Program clients. Clients
should consider the value of the additional consulting services when making such comparisons. The
combination of custodial, consulting, and brokerage services may not be available separately or may
require multiple accounts, documentation, and fees. In addition, certain advisors may not be available to
certain clients outside the consulting relationship because of minimum account sizes, fee schedules,
geographic availability, or other factors. A non-wrapped pricing arrangement may be more cost effective
for accounts that do not experience frequent trading activity. Because of the single fee charged to a
Program account, WIA may be regarded as having a conflict of interest in that it may realize a greater
profit on a Program account with a relatively low rate of portfolio turnover compared to other types of
accounts, assuming the same level of fees. However, WIA is constrained by fiduciary principles to act in
its clients’ best interests.
All fees may be subject to negotiation. When negotiating fees, factors considered include, but are not
limited to: (i) clients with multiple accounts; (ii) size of the account; (iii) a prior or existing relationship;
and (iv) a client’s particular needs or financial characteristics. Because fees may vary, clients with existing
accounts may be charged fees which differ from the foregoing fee schedules, or the fees paid by other
clients.
Other costs that may be assessed and that are not part of those outlined above include fees for portfolio
transactions executed away from the broker/custodian selected by the client, dealer mark-ups, electronic
fund and wire transfers, spreads paid to market-makers, and exchange fees, among others.
Brokers/custodians may charge clients certain additional and/or minimum fees.
The Program wrap fee does not include: (i) annual account fees or other administrative fees, such as wire
fees, charged by custodians (ii) certain odd-lot differentials, transfer taxes, transaction fees mandated by
the Securities Act of 1934, and charges imposed by law with regard to transactions in the client’s account;
and (iii) advisory fees, expenses or sales charges (loads) of mutual funds (including money market funds),
closed-end investment companies or other managed investments, if any, held in client’s account.
4
Account Termination
Client and/or the firm may initiate termination of the contract at any time by sending written notice to
the contra party and will be accepted the day that it is received by the contra party. WIA does not charge
a fee for terminating the account, but the custodian may charge a termination fee.
Upon written receipt of notice to terminate its client Agreement, and unless specific transfer instructions are
received, WIA and its representative(s) will immediately cease advisory services. Should the client provide
specific instructions to liquidate, WIA will proceed with liquidation of the client’s account in an orderly and
efficient manner. There will not be a charge by WIA for such redemption; however, the client should be aware
that certain securities impose redemption fees as stated in each company’s prospectus. Additionally,
custodians may assess additional redemption fees for short-term liquidations. Clients must keep in mind that
the decision to liquidate security issues or mutual funds may result in tax consequences that should be
discussed with the client’s tax advisor. Factors that may affect the orderly and efficient manner would be size
and types of issues, liquidity of the markets, and market makers’ abilities. Should the necessary securities’
markets be unavailable, and trading suspended, efforts to trade will be done as soon as possible following their
reopening. Due to the administrative processing time needed to terminate client’s investment advisory
services and communicate the instructions to client’s Investment Advisor, termination orders received from
clients are not market orders; it may take several business days under normal market conditions to process the
client’s request. During this time, the client’s account is subject to market risk. WIA and its representative(s)
are not responsible for market fluctuations of the client’s account from time of written notice until complete
liquidation. All efforts will be made to process the termination in an efficient and timely manner.
Item 5 - Account Requirements and Types of Clients
WIA provides advisory services to Individuals and Retirement Plans including, 401(k) Plans, 403(b) Plans,
pensions and profit-sharing plans, non-qualified plans, foundations, endowments, corporations, or other
businesses not listed above. For Wealth Clients, Adviser generally does not require a minimum account
size, but may impose a minimum annual consulting fee.
Certain Third-Party Money Managers may require a higher minimum account size as disclosed in the
individual manager’s Firm Brochure. Under certain circumstances, the minimum may be waived, including
related accounts that may be combined to meet the minimum if the services involved may otherwise be
provided.
Item 6 - Portfolio Manager Selection and Evaluation
WIA serves as the portfolio manager in the wrap fee program. WIA may outsource its portfolio
management by using outside portfolio managers for the referenced Program. WIA uses industry
standards to measure the performance of its portfolio managers; however, the firm does not use a third-
party auditor to review and verify the performance of its portfolio managers.
Performance-Based Fees and Side-By-Side Management
WIA does not charge any performance-based fees (fees based on a share of capital gains on or capital
appreciation of the assets of a client).
Methods of Analysis, Investment Strategies and Risk of Loss
Investment recommendations are based on an analysis of the client’s individual needs and are drawn from
research and analysis. Security analysis methods may include the following:
• Fundamental analysis: WIA attempts to measure the intrinsic value of a security by looking at
economic and financial factors to determine if the company is underpriced or overpriced.
5
Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market
regardless of the economic and financial factors considered in evaluating the stock.
• Technical analysis and charting: WIA attempts to determine the trend of a security by studying
past market data, including price and volume. This presents a potential risk, as the price of a
security can change direction at any time and past performance is not a guarantee of future
performance.
• Cyclical analysis: WIA attempts to identify the industry cycle of a company to determine whether
the company is in a market introduction phase, growth phase or maturity phase. Generally
projected revenues, growth potential and business risk may fluctuate based on the company’s
cycle stage.
Information for this analysis may be drawn from financial newspapers and magazines, research materials
prepared by others, annual reports, corporate filings, prospectuses, company press releases and
corporate ratings services.
It is important to note that investing in securities involves a risk that clients should be prepared to bear.
For any risks associated with Investment Company products, please refer to the prospectuses for
additional details about these risks. Our investment approach constantly keeps the risk of loss in mind.
These risks include, but are not limited to:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
•
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of a
security’s particular underlying circumstances. For example, political, economic, and social
conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar
next year, because purchasing power is eroding at the rate of inflation.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed
income securities.
•
• Business Risk: These risks are associated with a particular industry or a particular company within
an industry. For example, oil-drilling companies depend on finding oil and then refining it, a
lengthy process, before they can generate a profit. They carry a higher risk of profitability than an
electric company, which generates its income from a steady stream of customers who buy
electricity no matter what the economic environment is like.
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets
are more liquid if many traders are interested in a standardized product. For example, Treasury
Bills are highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times and bad.
During periods of financial stress, the inability to meet loan obligations may result in bankruptcy
and/or a declining market value.
6
Voting Client Securities
As a matter of firm policy and practice, WIA does not vote proxies on behalf of Pensionmark Portfolio
advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities
maintained in client portfolios. Clients should contact their financial advisor if they have any questions
and/or to obtain this information. Clients will receive their proxies directly from their custodian or transfer
agent.
Clients can authorize investment managers to vote proxy requests on their behalf in their client
agreements. Please refer to the respective investment manager's Form ADV for a full disclosure of its
proxy voting policies and procedures.
Item 7 - Client Information Provided to Portfolio Managers
WIA is usually both your registered investment adviser and your portfolio manager. WIA may outsource
its portfolio management by using outside portfolio managers for the referenced Programs. In some
cases, your portfolio manager has the same access to your information as WIA. This information may
include, among other things, income, net worth, risk tolerance, and investment objectives. Portfolio
Managers use this information to determine an appropriate asset allocation and manage investments.
When a client updates their information with WIA, portfolio managers will be provided with the same
updated information.
Item 8 - Client Contact with Portfolio Managers
Clients may communicate with portfolio managers directly during normal business hours. Consultations
beyond normal business practices may require additional negotiated fees.
Item 9 - Additional Information
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to an evaluation of WIA or the integrity of WIA’s management. WIA has
no information applicable to this Item.
Other Financial Industry Activities and Affiliations
WIA is a wholly owned subsidiary of WIA Holdings, LLC. Under the common control of WIA Holdings, LLC,
WIA is affiliated with Goldman Sachs & Co., LLC, a FINRA broker-dealer (Member SIPC) and SEC Registered
Investment Adviser, and World Investments, LLC., FINRA broker-dealers (Members SIPC), and Financial
Planning Concepts of America, Inc., all SEC Registered Investment Advisers. WIA is also affiliated with
World Insurance Associates, LLC, Scotts American, LLC, Keating, LLC, ESA Associates, LLC, FastComp, LLC,
Hamond Safety Management, LLC, Pacific Coast NCA Premium Finance, LLC, and World Insurance
Programs, LLC, all insurance agencies engaging in Life, Health, Long Term Care, Variable, and various other
Insurance business.
Recommendations for Goldman Sachs investment products are limited to a small subset of products
approved by WIA. No incentives are provided to WIA or WIA Investment Advisor Representatives to
recommend Goldman Sachs products over other investment products.
WIA is also affiliated with other financial services companies, but does not have any shared business
dealings, operations, referral programs, clients, representatives, or premises with these other companies,
and has no reason to believe the firm’s relationship with them otherwise creates a conflict of interest with
WIA clients. A full list of WIA’s affiliates will be provided upon request.
7
Investment Adviser Representatives (“IARs”) of WIA may effect securities transactions for Clients as
registered representatives of St. Bernard Securities, LLC (“St. Bernard”), or World Investments, LLC.
(“WI”), all FINRA broker-dealers. WIA is affiliated with WII through the common control and ownership
by WIA Holdings, LLC. WIA has no affiliation with St. Bernard. Advisors that are registered representatives
of these firms may recommend either of the two firms with whom they are registered for broker-dealers
services. Factors for such a recommendation may be when transaction compensation is seen as a benefit
to the client. For broker-dealer services, St. Bernard, WI, or their associated persons may receive
compensation, which is separate and distinct from compensation related to investment advisory services.
Commissions paid to advisors for broker-dealer services may be higher or lower than those paid by other
brokers.
All FINRA, SEC, and other regulatory agencies disclosure requirements and policies are observed for all
transactions. If a trade error were to occur, it may result in profit or loss to the firm. The firm has controls
in place to limit such trade errors. Investment Advisers will not participate in any profits resulting from
such errors.
Some Investment Adviser Representatives (“IARs”) of WIA may also be registered as IARs of Acrisure
Investment Advisory Solutions, LLC (“Acrisure”). However, these IARs do not effect any transactions
through Acrisure. One WIA Advisor is also registered as an Advisor with Nexus338, an advisory firm
providing technology-based retirement plan managed account services to non-WIA clients . WIA is not
affiliated with Acrisure, or Nexus338.
Individuals may also write Insurance business through Pensionmark Partners Insurance Services, LLC
(“PPIS”) as independent insurance agents. PPIS is affiliated with WIA through common control and
ownership. PPIS is an insurance producer group engaging in Life, Health, Long Term Care and Variable
Insurance business. Variable insurance products will be offered exclusively through WI, while non-variable
products will be offered directly with an insurance carrier through the producer group contracts.
Compensation will be paid directly by these entities.
Individuals licensed as Registered Representatives or Insurance Agents may spend as much as 50% of their
time on these non-advisory activities. When a client’s Advisor is acting in their capacities as registered
representatives or independent insurance agents, clients will be charged separately from their advisory
services. Clients have the option to purchase investment products that we recommend through other
brokers or agents that are not affiliated with WIA.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
WIA has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of
business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the
confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering,
restrictions on the acceptance of significant gifts and the reporting of certain gifts and business
entertainment items, and personal securities trading procedures, among other things. All supervised
persons at WIA must acknowledge the terms of the Code of Ethics annually, or as amended.
Advisors of WIA may buy or sell securities that are recommended to clients. WIA’s employees and persons
associated with WIA are required to follow the Code of Ethics. Subject to satisfying this policy and
applicable laws, officers, directors, and employees of WIA and its affiliates may trade for their own
accounts in securities which are recommended to and/or purchased for WIA’s clients. The Code of Ethics
is designed to assure that the personal securities transactions, activities, and interests of the employees
of WIA will not interfere with (i) making decisions in the best interest of advisory clients and (ii)
8
implementing such decisions while, at the same time, allowing employees to invest for their own
accounts. Under the Code certain classes of securities have been designated as exempt transactions,
based upon a determination that these would not materially interfere with the best interest of WIA’s
clients. In addition, the Code requires pre-approval of many transactions, and restricts trading in close
proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would
permit employees to invest in the same securities as clients, there is a possibility that employees might
benefit from market activity by a client. Employee trading is continually monitored under the Code of
Ethics to reasonably prevent conflicts of interest between WIA and its clients.
Advisors may recommend and trade in the same securities with clients and/or related accounts at or about
the same time. Generally, this would pose a conflict if the Advisor or related account were given a better
price than the client. To mitigate this conflict, it is procedure to not trade an Advisors account or related
persons’ account on the same day as a client unless the client gets the better price.
Trades may be done on an aggregated basis when consistent with WIA's obligation of best execution. In
such circumstances, the Advisor (or related account) and client accounts will share commission costs
equally and receive securities at a total average price. WIA will retain records of the trade order (specifying
each participating account) and its allocation, which will be completed prior to the entry of the aggregated
order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will
be allocated on a pro rata basis. Any exceptions will be explained on the order.
WIA’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting WIA at
(800) 833-1862 or by sending an email to compliance@worldadvisors.com.
Brokerage Services
WIA generally recommends that clients establish brokerage accounts with Charles Schwab & Co., Fidelity
Institutional Wealth Services, or Pershing Advisory Services (“Schwab”, “Fidelity”, “Pershing”, or
collectively, “the Custodian(s)”), FINRA registered broker-dealers, members SIPC, to maintain custody of
clients’ assets and to effect trades for their accounts. In some instances, WIA may recommend clients
establish brokerage accounts with other custodians. We recommend the services of the Custodian based
on several factors including financial strength, reputation, execution, pricing, responsiveness, fees,
research, and other services. Although WIA may recommend that clients establish accounts at the
Custodian, it is the client’s decision to custody assets with the Custodian.
WIA does not direct brokerage to a particular venue for execution, but rather relies on the Custodian
(with the exception of bond trades that may be directed to a third party available to WIA through the
Custodian’s Platforms). Fees and commissions charged by Fidelity or Schwab may be higher or lower than
obtainable elsewhere. Circumstances occasionally arise when Schwab or Fidelity must impose a separate
or special handling or custodial charge for acting as custodian for an exempt security or private
placement that was recommended by WIA to a WIA Advisory Client. On a case-by-case basis, WIA may
cover the cost of this type of fee on a “value‐added” basis by having the fee directly billed to WIA rather
than the Client or by reimbursing the Client. WIA is independently owned and operated and not affiliated
with Schwab or Fidelity.
Custodians may make products and services available to WIA that benefit WIA but may not directly benefit
its clients’ accounts. Many of these products and services are used to service all or a substantial number
of WIA accounts. Some of these products and services provided includes software and other technology
that provides access to client account data (such as trade confirmations and account statements);
9
provides research, pricing, and other market data; facilitates payment of fees from clients’ accounts; and
assists with back-office functions, recordkeeping, and client reporting.
WIA clients can benefit when trades are aggregated to obtain volume discounts on execution costs. Trade
aggregation refers to the practice of combining orders for execution. When consistent with WIA’s duty
to obtain best execution, multiple client transactions will be aggregated into a single order in order to
obtain the best price for clients. In such circumstances, the accounts will share commission costs equally
and receive securities at a total average price. WIA will retain records of the trade order (specifying each
participating account) and its allocation, which will be completed prior to the entry of the aggregated
order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will
be allocated on a pro rata basis. Any exceptions will be explained on the order. Trade aggregation will
typically be done at the branch level.
For Third-Party Money Managers WIA recommends, WIA does not direct brokerage in these accounts.
Brokerage practices of separately managed accounts are disclosed separately in their Brochure(s).
Review of Accounts
Accounts are assigned to IARs who are responsible for performing periodic reviews and consulting with
the respective client. Accounts are reviewed no less than annually by the Advisor. Factors that are
considered during such reviews include, but are not limited to, the following: investment objectives,
targeted allocation, current allocation, suitability, performance, monthly distributions, concentrated
positions, diversification, and outside holdings. Examples of situations that may impact Client’s account
would be the following: performance that is not in line with the client’s “downside risk tolerance,” change
in investment objective, the client making a significant addition or withdrawal of capital from the account,
rebalancing of the portfolio if current allocation and targeted allocation are not consistent, concentrated
position(s) that could lead to volatility, etc. Accounts may also be subject to a secondary review by a
designated supervisor. Such supervisory reviews will be done on a periodic basis. The supervisor will
oversee the selected accounts for the same triggering factors as mentioned above.
Advisor has the ability to provide performance reports for assets under advisement through the Envestnet
and Tamarac data aggregation and portfolio reporting tools. For data aggregation purposes, these reports
may include information for assets managed by the Adviser for both commissionable and fee-based
accounts.
The client agrees to inform the firm in writing of any material changes to the information included in the
Client Profile or any other change in the client’s financial circumstances that might affect the manner in
which client’s assets should be invested. Clients may contact the firm during normal business hours to
consult with the firm concerning the management of the client’s account(s).
Client Referrals and Other Compensation
WIA, in some instances, may compensate third-party promoters for Client referrals. For a promoter to be
compensated by WIA for referring a Client to WIA, the promoter must be engaged by WIA under a
Promoter or Referral Agreement (“Agreement”) in compliance with Section 206(4)-1 of the Investment
Advisers Act of 1940. In general, a promoter is compensated by a percentage of the advisory fee collected
for a limited period specified in the Agreement. The Client pays no additional fee for the referral over and
above WIA’s quoted advisory fee; to the contrary, the fee the Adviser earns is reduced by the amount of
the compensation to the promoter. A Client who is referred by a promoter will receive the promoter’s
separate Disclosure Statement describing the nature of the arrangement in detail.
10
Clients may request details regarding a particular Agreement by contacting us toll-free at (888) 679-6067
or by emailing compliance@worldadvisors.com.
Certain mutual fund companies, record keepers or other third parties (“Third Parties”) will periodically
sponsor educational seminars for participating financial advisors designed to facilitate and promote
professional development and product knowledge. To encourage participation, Third Parties will cover
travel-related expenses for certain advisors to attend these meetings. Such expense reimbursements are
only permissible by WIA when pre-approved, and after review of the agenda and estimated costs. WIA
will not approve expense reimbursements by the Third Parties for travel unless the travel expenses appear
reasonable and customary; lavish expenses will not be approved. WIA Advisors do not base
recommendations on the expectation of such conference and travel.
In addition, WIA or its Advisors may host events where Third Parties “sponsor” a specific portion of the
event, e.g., the cost of a dinner. WIA Advisors do not base recommendations on the expectation of such
event sponsorship.
Custody
WIA is deemed to have custody of client funds because investment advisory fees are directly debited from
some Client accounts. Debiting of fees is done pursuant to authorization provided by the Client. Clients
should receive statements at least quarterly from the selected qualified Custodian that holds and
maintains client’s investment assets. WIA urges clients to carefully review such statements and compare
the official custodial records to the account statements that WIA may provide. WIA’s statements may vary
from custodial statements based on accounting procedures, reporting dates, or valuation methodologies
of certain securities.
WIA is also deemed to have custody of client assets as a result of certain Clients’ authorization for WIA
and/or its IARs to distribute assets from their account(s) to a specific named recipient on demand in
accordance with a standing letter of instruction. WIA complies with the SEC No-Action Letter dated
2/21/2017 (Investment Adviser Association) allowing firms complying with the provisions of the No-Action
Letter to forego an annual surprise custody examination with respect to those assets.
Investment Discretion
WIA typically acts in a discretionary capacity for its Wealth Clients but may act in a non-discretionary
capacity. Discretionary authority provides the WIA Advisor with the authority to determine, without
obtaining specific Client consent, both the securities to be bought and sold in their accounts as well as
the dollar amount/quantity of securities to be bought and sold.
If discretionary authority is granted to select the identity and amount of securities to be bought or sold,
clients must authorize such discretion in writing in the advisory agreement. In all cases, such discretion is
to be exercised in a manner consistent with the stated investment objectives for the particular client
account. When selecting securities and determining amounts, WIA observes the investment policies,
limitations, and restrictions of the clients for which it advises. Investment guidelines and restrictions must
be provided to WIA in writing.
WIA may recommend Third-Party Money Managers. When acting in a discretionary capacity, the firm can
evaluate managers and may switch money managers or reallocate assets among managers without
in a non-discretionary capacity, the Advisor will make
consulting the client. When acting
recommendations, but only the client has the authority to hire or switch money managers or reallocate
assets between programs. In all cases, the Advisor will monitor the performance of the third-party money
11
manager and will make recommendations consistent with the client’s investment objectives and risk
tolerance.
Financial Information
Registered Investment Advisers are required to provide certain financial information or disclosures about
WIA’s financial condition. WIA has no financial commitment that impairs its ability to meet contractual
and fiduciary commitments to clients and has not been the subject of any bankruptcy proceedings.
Privacy Policy
World Investment Advisors, LLC (“WIA”) recognizes that its Clients have an expectation that WIA and its
affiliates will maintain the confidentiality of Clients’ nonpublic personal information. Consequently, WIA
has adopted this Privacy Policy concerning information obtained during the servicing of Client’s
account(s).
Nonpublic Information: Nonpublic information obtained by WIA for purposes of providing services
hereunder will not be furnished to third parties for any other purpose other than in furtherance of the
services to be provided hereunder. Notwithstanding the foregoing, WIA may disclose nonpublic
information (i) to the extent such disclosure is required by court order or by a valid order of a
governmental body governmental or quasi-governmental agency (such as FINRA) (ii) after the time of
disclosure such information becomes part of the public knowledge or literature, not as a result of any
inaction or action of WIA, (iii) reasonably necessary for WIA to enforce its legal rights in any dispute with
that Client; or (iv) is approved by Client, in writing, for release. WIA does not disclose nonpublic personal
information about its Clients to any party except as permitted by law.
Sources of Personal Information: WIA collects Personal Information about its Clients from meetings with
Clients and on applications or other forms Clients have submitted to WIA, as well as information about
Clients’ investments or transactions with WIA or others (such as third-party service providers or fund
companies) from other sources.
How WIA Protects the Confidentiality of Clients’ Nonpublic Personal Information: WIA does not sell or
trade Clients’ information with nonaffiliated companies. When information is provided to third party
service providers, safeguards are in place to assure that information is used only for the purpose it is
provided. WIA maintains its records on secured computers. Prospective employees are screened for
criminal convictions. Once hired, employees are made aware of WIA’s Privacy Policy and of the
confidential nature of the information they handle. Employees are limited to accessing only that customer
information that is necessary to perform their job functions.
To Whom This Policy Applies: This Notice applies to all WIA Clients who enter into an Advisory Services
Agreement or Customer Agreement with WIA. For Former Clients: WIA’s Privacy Policy continues to apply
even to Clients that have terminated services with the firm.
Internet Cookies: An internet “cookie” is a small amount of data that is placed on to your electronic
device by a website and stored in your internet browser. Cookies allow websites to store things like
preferences, so that it can recognize users when returning to the site and respond appropriately. When
individuals access the Worldadvisors.com website, WIA makes use of cookies to improve the load times
and functionality of the website, and in some cases registration pages. WIA may from time to time also
utilize data tracking software to assist in spotting trends and areas of improvement on the website. By
accessing the Worldadvisors.com site and embedded web pages, users are providing their express
approval allowing WIA to utilize these technologies to improve services provided. WIA may also use
12
various third-party cookies to report usage statistics of the service, or to authenticate users and prevent
fraudulent access of user accounts.
Access to and Correction of Information: Upon the written request of Clients, WIA will make available
for review any file that may be maintained for their personal Information; provided, however, that any
Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be
made available. If Clients notify WIA that any Information is incorrect, the information will be reviewed.
If WIA agrees the information is incorrect, records will be corrected. If WIA disagrees, Clients may submit
a short statement of dispute, which will be included in any future disclosure of the disputed Information.
Additional California Privacy Disclosures: Please consult the supplemental WIA Privacy Notice for
California Residents for additional disclosures pertinent to California residents.
Further Information: WIA reserves the right to change this Privacy Policy at any time. The examples
contained within this Privacy Policy are illustrations and are not intended to be exclusive. This Policy
attempts to comply with federal and state regulations regarding privacy. Clients may have additional
rights under other foreign or domestic laws that may apply to them.
If the financial advisor servicing a client account leaves WIA to join another firm, the advisor is permitted
to retain copies of client information so that he/she can assist with the transfer of the client account and
continue to serve the client at their new firm.
by
calling
(800)
833-1862
or
by
an
email
“Opting Out” of Third-Party Disclosures: If a client does not want a financial advisor to retain copies of
client sensitive information when he/she leaves WIA to join another firm, the client may contact the WIA
to
sending
Compliance Department
compliance@worldadvisors.com to request further information regarding this policy.
13
Additional Brochure: WRAP FEE BROCHURE - WORLD ADVISORS WRAP (2026-03-31)
View Document Text
Item 1 World Advisors Wrap Cover Page
World Investment Advisors, LLC
437 Newman Springs Road
Lincroft, New Jersey, 07738
Phone: (800) 833-1862
http://www.worldadvisors.com
March 31, 2026
This wrap fee brochure provides information about the qualifications and business practices of
World Investment Advisors, LLC. If you have any questions about the contents of this Brochure,
please contact us at (800) 833-1862 or email compliance@worldadvisors.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.
World Investment Advisors, LLC is a Registered Investment Adviser. Registration of an Investment
Adviser does not imply any level of skill or training. This Brochure is intended, in part, to provide
information which can be used to make a determination to hire or retain an Adviser.
Additional information about World Investment Advisors, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov
(Please see page 29 for WIA’s Privacy Policy)
Item 2 Material Changes
The Firm has the following material changes to report since the last brochure dated November
26, 2025:
• WIA has changed its principal place of business to 437 Newman Springs Road, Lincroft, New
Jersey 07738.
Each year, we will provide each client with (i) a free updated Brochure that either includes a
summary of material changes or is accompanied by a summary of material changes, or (ii) a
summary of material changes that includes an offer to provide a copy of the updated Brochure
and information on how clients may obtain the Brochure.
Our Brochure may be requested by contacting us toll-free at (800) 201-1862 or by sending an
email to compliance@worldadvisors.com.
Additional information about World Investment Advisors, LLC is also available via the SEC’s web
site www.adviserinfo.sec.gov. The SEC’s website provides information about any persons
affiliated with World Investment Advisors, LLC who are registered, or are required to be
registered, as investment adviser representatives of World Investment Advisors, LLC.
Item 3 Table of Contents
Item 1 Cover Page ...................................................................................................................................................................i
Item 2 Material Changes ....................................................................................................................................................... ii
Item 3 Table of Contents ..................................................................................................................................................... iii
Item 4 Services, Wrap Fees, and Compensation ................................................................................................................... 4
Item 5 Account Requirements and Types of Clients ........................................................................................................... 19
Item 6 - Portfolio Manager Selection and Evaluation .......................................................................................................... 19
Item 7 - Client Information Provided to Portfolio Managers ............................................................................................... 22
Item 8 - Client Contact with Portfolio Managers ............................................................................................................... 22
Item 9 - Additional Information ............................................................................................................................................ 22
Privacy Policy ......................................................................................................................................................................... 29
iii
Item 4 Services, Wrap Fees, and Compensation
World Investment Advisors, LLC (“WIA” or “Adviser”) was established in March 2015. WIA is a
wholly owned subsidiary of WIA Holdings, LLC.
WIA sponsors this wrap fee program (“World Advisors Wrap”) that is custodied with Pershing,
LLC, a non-affiliated clearing broker dealer for custodial and transaction services for client
accounts. WIA provides advisory services, giving continuous advice based on the client’s
individual needs. Through personal discussions in which goals and objectives based upon the
client’s personal objectives are established, the firm will develop a personal investment policy
based upon the WIA Client Profile and manage the portfolio according to the criteria. We provide
a wide array of advisory services to our clients in which both proprietary and non-proprietary
investment options are made available. We may manage these advisory accounts on a
discretionary and/or non-discretionary basis.
We offer these services to individuals, pension and profit-sharing plans, trusts, estates and/or
charitable organizations and also corporations and/or other business entities.
WIA participates in advisory programs as portfolio manager, advisor, co-advisor or solicitor
depending on the program and depending on the needs or direction of its clients. Clients should
discuss with their advisor what roles are appropriate, and what programs are appropriate for
their investment objectives and risk tolerances. WIA also may select other investment advisors
for its clients, in particular by advising clients regarding Independent Managers or Third-Party
Asset Management Programs ("TAMPs") or by referral arrangements. To the extent WIA utilizes
an Independent Manager or a Third-Party Money Manager, WIA shall provide the Independent
Manager or Third-Party Money Manager with each client's particular investment objective and
risk tolerance. Any changes in the client's financial situation or investment objectives reported
by the client to WIA shall be communicated to the Independent Manager or Third-Party Money
Manager within a reasonable period of time.
Of the funds managed by and/or through the services provided by WIA, the majority are
considered "Investment Supervisory Services", meaning we provide continuing advice as to the
investment of funds on the basis of the individual needs of each client. These services will
generally include the following types of asset management services:
•
Individual Portfolio Management - we provide asset management of client funds based
on the individual needs of the client. The Investment Advisor Representative initially
determines the client's financial objectives, time horizons, restrictions, etc; develops the
client's personal investment plan; then creates and manages a customized portfolio based
on that plan.
• Model Portfolio Management - we provide portfolio management services to clients
using model asset allocation portfolios. Each model portfolio is designed to meet a
particular investment goal. The Investment Advisor Representative initially determines
the client's financial objectives, time horizons, restrictions, etc; and determines if the
model portfolio is suitable for the client. Once a suitable model is determined, the
portfolio is managed based on the portfolio's goals, rather than on each client's individual
needs.
4
• Third-Party Money Managers - WIA does not directly manage these client assets. Each
Investment Advisor Representative may outsource the management of client funds to an
outside money manager who may utilize an investment strategy, which after discussions
with the client, may be deemed the closest in line with the client's investment goals and
objectives.
• Financial Planning and Consulting Services - financial planning is a comprehensive
evaluation of a client's current and future financial state by using currently known
variables to predict future cash flows, asset values and withdrawal plans. Through the
financial planning process, all questions, information and analysis are considered as they
impact and are impacted by the entire financial and life situation of the client.
Outside of the specific mention in the contract, these types of compensation tend to
indicate that the advisory services provided are temporary in nature or based upon time
spent with the client and not indicative of continuous and regular supervisory or
management services. WIA offers these types of services, but they represent a very small
part of our advisory business.
Third-Party Asset Management Programs ("TAMPS")
WIA participates in advisory programs as portfolio manager, advisor, co-advisor or solicitor
depending on the program and depending on the needs or direction of its clients. Clients should
discuss with their advisor what roles are appropriate, and what programs are appropriate for
their investment objectives and risk tolerances. WIA also may select other investment advisors
for its clients, in particular by advising clients regarding Independent Managers or Third-Party
Asset Management Programs ("TAMPs") or by choosing from available managers on the
Envestnet Asset Management, Inc. ("Envestnet") platform.
To the extent WIA utilizes an Independent Manager or a Third-Party Money Manager, the
Registrant shall provide the Independent Manager or Third-Party Money Manager with each
client's particular investment objective and risk tolerance. Any changes in the client's financial
situation or investment objectives reported by the client to WIA shall be communicated to the
Independent Manager or Third-Party Money Manager within a reasonable period of time.
The following provides in more detail, the full depth & breadth of the advisory services WIA offers
to our clients.
INVESTMENT SUPERVISORY SERVICES ("ISS")
Individual Portfolio Management
Our firm provides continuous advice to a client regarding the investment of client funds based
on the individual needs of the client. Through personal discussions in which goals and objectives
based on a client's particular circumstances are established, we develop a client's personal
investment policy and create and manage a portfolio based on that policy. During our data-
gathering process, we determine the client's individual objectives, time horizons, risk tolerance,
and liquidity needs. As appropriate, we also review and discuss a client's prior investment history,
as well as family composition and background.
5
We manage these advisory accounts on a discretionary and/or non-discretionary basis and offer
both proprietary and non-proprietary alternatives to the client. Account supervision is guided by
the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and
income), as well as tax considerations.
We offer Advisor as Portfolio Manager (APM) Accounts, an asset -based fee account with no
commissions or transaction fees to the client. The client, or the investment advisor
representative, depending on the agreement signed, may conduct transactions in a wide variety
of securities and periodically adjust portfolio holdings as circumstances dictate - for a single asset-
based fee.
Clients from time to time may impose reasonable restrictions on investing in certain securities,
types of securities, or industry sectors. The firm may not be able to accommodate all requests.
Our investment recommendations are limited to specific products or services offered by a broker-
dealer or insurance company and will generally include advice regarding the following securities:
Exchange-listed securities
Securities traded over-the-counter
Corporate debt securities (other than commercial paper)
Certificates of deposit
Interests in partnerships investing in real estate
Exchanged Traded Funds
Separately Managed Accounts
•
•
• Variable life insurance
• Variable annuities
• Mutual fund shares
•
•
• Municipal securities
• US Government securities
•
•
•
• Other
Because some types of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the client's stated investment objectives,
tolerance for risk, liquidity and suitability.
Proprietary Model Portfolio Management
Our firm provides portfolio management services to clients using model asset allocation
portfolios. Our clients have access to these models through our proprietary program branded as
"Buy/Hold Plus". Each model portfolio is comprised of mutual funds and/or Exchanged Traded
Funds and is designed to meet a specified range of risk tolerance and/or time horizon in
connection with a client's broad-based investment goals. Investments in our Traditional Buy/Hold
Plus program are based on one of five models and combine traditional asset allocation with our
proprietary manager selection process to determine the best performing fund within each asset
class. Investments in our Buffered Buy/Hold Plus program utilize buffered or defined outcome
ETFs to build portfolios that can prove upside potential to an index-based cap, while still
maintaining a degree of downside protection. Third Party Money Managers are screened
6
quarterly and portfolios are conditionally re-balanced according to predetermined allocations.
The models and their respective allocations are as follows:
• Traditional Models:
o Conservative – 30% stock funds, 68% bond funds, 2% cash
o Moderately Conservative – 45% stock funds, 53% bond funds, 2% cash
o Moderate – 65% stock funds, 33% bond funds, 2% cash
o Moderately Aggressive – 75% stock funds, 23% bond funds, 2% cash
o Aggressive - 86% stock funds, 12% bond funds, 2% cash
• Buffered Models:
o Buffered 100 - 98% buffered ETFs, 2% cash
o Buffered 60 - 40% equity ETFs, 58% buffered ETFs, 2% cash
These advisory accounts are managed on a discretionary basis. Through personal discussions with
the client and the use of an investment policy statement questionnaire in which the client's goals
and objectives are established, we determine if the model portfolio is suitable to the client's
circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based
on the portfolio's goal, rather than on each client's individual needs. Clients do not have the
opportunity to place reasonable restrictions on these types of investments held in their account.
Clients retain individual ownership of all securities.
Our investment recommendations are limited to the specific products or services offered by a
broker dealer or insurance company and will generally include advice regarding the following
securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Mutual Funds
• Exchanged Traded Funds
• Variable Annuities
Because some types of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the client's stated investment objectives,
tolerance for risk, liquidity and suitability.
To ensure that our initial determination of an appropriate portfolio remains suitable and that the
account continues to be managed in a manner consistent with the client's financial
circumstances, we will:
• Periodically contact each participating client to determine whether there have been any
changes in the client's financial situation or investment objectives;
• Be reasonably available to consult with the client;
• Encourage clients to contact us immediately should there be a change of their financial
situation; and
• Maintain client suitability information in each client's file.
7
In addition, each introducing investment advisor representative remains in close contact with
their respective clients to update various financial information and determine continued
suitability.
Non-Proprietary Model Portfolio Management
Our individual advisory representatives may provide portfolio management services to clients
using model asset allocation portfolios. These models may be managed to a specific portfolio
goal.
The individual advisory representatives manage these advisory accounts on a discretionary or
non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e.,
maximum capital appreciation, growth, income, or growth and income), as well as tax
considerations.
Through personal discussions with the client in which the client's goals and objectives are
established, the individual advisor representative determines if the model portfolio is suitable to
the client's circumstances. Once they determine the suitability of the portfolio, the portfolio is
managed based on the portfolio's goal, rather than on each client's individual needs. Clients,
nevertheless, typically have the opportunity to place reasonable restrictions on the types of
investments to be held in their account. Clients retain individual ownership of all securities.
These investment recommendations are limited to the specific product or service offered by a
broker dealer or insurance company and will generally include advice regarding the following
securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Mutual fund shares
• Exchanged Traded Funds
• Variable Annuities
Because some types of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the client's stated investment objectives,
tolerance for risk, liquidity and suitability.
In some cases, investment advisory representatives may incorporate alternative strategies
designed to limit risk but also capture upside potential in both up and down markets. There is no
assurance that these strategies will be successful or that any attempted performance goals will
be achieved.
These strategies may include the use of exchange traded funds that offer leverage or that are
designed to perform Inversely to the index or benchmark they track-or both. Our investment
advisory representatives are sure to ascertain a client's suitability prior to the use of such
instruments or trading strategies, based on a full understanding of the terms and features of the
product or strategy recommended.
Typically, such products are utilized in sophisticated trading strategies and are highly complex in
nature and are disclosed to the clients of WIA as such. In addition, due to the effects of
compounding, their performance over longer periods of time can differ significantly from their
8
stated daily objective. Therefore, inverse and/or leveraged ETFs that are reset daily may not be
suitable for retail investors who plan to hold them for longer than one trading session.
To ensure that initial determination of an appropriate portfolio remains suitable and that the
account continues to be managed in a manner consistent with the client's financial
circumstances, we will:
• Periodically send written reminders to each Model Portfolio Management Services client
requesting any updated information regarding changes in the client's financial situation
and investment objectives;
• Periodically contact each participating client to determine whether there have been any
changes in the client's financial situation or investment objectives, and whether the client
wishes to impose investment restrictions or modify existing restrictions;
• Be reasonably available to consult with the client
• Encourage clients to contact us immediately should there be a change of their financial
situation; and
• Maintain client suitability information in each client's file.
Third-Party Manager Programs
We also offer advisory management services to our clients through Third-Party Manager
Programs (hereinafter, "Programs").
Our firm may provide the client with an asset allocation strategy developed through personal
discussions in which goals and objectives based on the client's particular circumstances are
established. This asset allocation strategy is drafted into the client's Personal Investment Policy
Statement ("PIPS").
Based on the client's individual circumstances and needs (as exhibited in the client's PIPS) we will
then perform management searches of various Third Party Money Managers to identify which
registered investment advisor's portfolio management style is appropriate for that client. Factors
considered in making this determination include account size, risk tolerance, the opinion of each
client and the investment philosophy of the selected registered investment advisor. Clients
should refer to the selected registered investment advisor's Firm Brochure or other disclosure
document for a full description of the services offered. We are available to meet with clients on
a regular basis, or as determined by the client, to review the account.
Once we determine the most suitable investment advisor(s) for the client, we may re-affirm the
client's investment profile by completing the selected managers PIPS (if applicable). The Third-
Party adviser(s) then creates and manages the client's portfolio based on the client's individual
needs as exhibited in the PIPS.
investment advisor(s)
We monitor the performance of the selected registered investment advisor(s). If we determine
that a particular selected registered
is not providing sufficient
management services to the client, or is not managing the client's portfolio in a manner
consistent with the client's PIPS, we may suggest that the client contract with a different
registered investment advisor and/or program sponsor. Under this scenario, our firm selects a
new registered investment advisor and/or program for the client.
9
Third-Party Asset Management Programs ("TAMPS")
WIA may recommend or select other investment advisors for its clients generally through Third-
Party Asset Management Programs ("TAMPs"). Envestnet Asset Management, Inc. ("Envestnet")
makes available advisory services and programs of Third-Party investment advisors. Through
these TAMPs, WIA’s representatives provide ongoing investment advice to clients that is tailored
to the individual needs of the client. As part of these TAMP services, the representative typically
obtains the necessary financial data from the client, assists the client in determining the
suitability of the program, assists the client in setting an appropriate investment objective and
risk tolerance and assists the client in opening an account with the TAMP. In addition, depending
on the type of program, the representative may assist the client to select a model portfolio of
securities designed by the TAMP or select a portfolio management firm to provide discretionary
asset management services. It is the Third-Party Asset Management Program (and not WIA's
representative) that has client authority to purchase and sell securities on a discretionary or non-
discretionary basis pursuant to investment objective chosen by the client. This authorization will
be set out in the TAMP client agreement. The Brochure for the particular TAMP will explain
whether clients may impose restrictions on investing in certain securities or types of securities.
In particular, WIA currently offers advisory services through TAMPs sponsored by a variety of well
diversified asset managers. Clients should refer to the Brochure, client agreement and other
account paperwork for each TAMP for more detailed information about the services available
under the program.
Fees and Compensation
Investment Supervisory Services Individual Portfolio Management Fees
Our annual fees for Investment Supervisory Services are based upon a percentage of assets under
management and generally range from 0.3% to 3.00%.
The annualized fee for Investment Supervisory Services will be charged as a percentage of assets
under management based on the corresponding program selected by the client, according to the
following schedules: Fees shall be prorated and paid quarterly, in advance, based upon the total
market value of the assets on the last day of the previous calendar quarter. Initial inception billing
will include fees for the remainder of the current calendar quarter, calculated in advance, on a
prorated basis from the day the initial deposit was added to the account.
Advisor as Portfolio Manager Non-Discretionary Fee Schedule (SILVER)
Assets Under Management
Total Annual Fee
Advisor Fee
Program Fee
$10,000* - $24,999
2.30%
1.80%
0.50%
$25,000 - $49,999
2.30%
1.90%
0.40%
$50,000 - $99,999
2.20%
1.90%
0.30%
$100,000 - $249,999
2.25%
2.00%
0.25%
$250,000 - $499,999
2.25%
2.05%
0.20%
10
$500,000 - $999,999
2.25%
2.10%
0.15%
$1,000,0000 - $1,999,999
2.25%
2.15%
0.10%
$2,000,0000 - and above
2.25%
2.15%
0.10%
Advisor as Portfolio Manager Discretionary Fee Schedule (SILVER)
Assets Under Management
Annual Fee
Advisor Fee
Program Fee
$10,000* - $24,999
2.30%
1.80%
0.50%
$25,000 - $49,999
2.30%
1.90%
0.40%
$50,000 - $99,999
2.20%
1.90%
0.30%
$100,000 - $249,999
2.25%
2.00%
0.25%
$250,000 - $499,999
2.25%
2.05%
0.20%
$500,000 - $999,999
2.30%
2.10%
0.20%
$1,000,0000 - $1,999,999
2.30%
2.15%
0.15%
$2,000,0000 - and above
2.25%
2.15%
0.10%
*Minimum Individual Account $10,000 Minimum Combined Household $25,000
Advisor as Portfolio Manager Discretionary Fee Schedule (GOLD)
Assets Under Management
Annual Fee
Advisor Fee
Program Fee
$50,000* - $99,999
2.50%
2.05%
0.45%
$100,000 - $249,999
2.50%
2.10%
0.40%
$250,000 - $499,999
2.50%
2.15%
0.35%
$500,000 - $999,999
2.50%
2.20%
0.30%
$1,000,000 - $1,999,999
2.50%
2.25%
0.25%
$2,000,000 - $4,999,999
2.50%
2.30%
0.20%
$5,000,000 - $9,999,999
2.50%
2.30%
0.20%
$10,000,000 - above
2.50%
2.35%
0.15%
11
*A minimum of $50,000 of assets under management is required to participate in the Advisor as
Portfolio Manager, Discretionary Asset Management Program (GOLD). This account size may be
negotiable under certain circumstances. WIA may group certain related client accounts for the
purposes of achieving the minimum household size and determining the annualized fee.
Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee
schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis.
Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will
be considered in determining the fee schedule. These include the complexity of the client, assets
to be placed under management, anticipated future additional assets; related accounts; portfolio
style, account composition, reports, among other factors. The specific annual fee schedule will
be identified in the contract between the adviser and each client. Investment Advisory Fee
Schedule, as outlined below, is a tiered or layered fee schedule, which applies distinct fee rates
to different portions of the portfolio.
Discounts, not generally available to our advisory clients, may be offered to family members and
friends of associated persons of our firm.
Fund Strategist Account Models (FSM)
Assets Under Management
Annual Fee
Advisor Fee
Program Fee
$50,000* - $99,999
2.50%
1.80%
0.70%
$100,000 - $249,999
2.50%
1.85%
0.65%
$250,000 - $499,999
2.50%
1.85%
0.65%
$500,000 - $999,999
2.50%
1.90%
0.60%
$1,000,000 - $1,999,999
2.50%
2.00%
0.50%
$2,000,000 - $4,999,999
2.50%
2.05%
0.45%
$5,000,000 - $9,999,999
2.50%
2.10%
0.40%
$10,000,000 - above
2.50%
2.20%
0.30%
*A minimum of $50,000 of assets under management is required to participate in the World
Fund Strategist Account Models (FSM). This account size may be negotiable under certain
circumstances. WIA may group certain related client accounts for the purposes of achieving the
minimum household size and determining the annualized fee.
Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee
schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis.
Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will
be considered in determining the fee schedule. These include the complexity of the client, assets
12
to be placed under management, anticipated future additional assets; related accounts; portfolio
style, account composition, reports, among other factors. The specific annual fee schedule will
be identified in the contract between the adviser and each client. Investment Advisory Fee
Schedule, as outlined below, is a tiered or layered fee schedule, which applies distinct fee rates
to different portions of the portfolio.
Separately Managed Account Models (SMA)
Assets Under Management
Annual Fee
Advisor Fee
Program Fee
$100,000* - $249,999
2.65%
1.85%
0.80%
$250,000 - $499,999
2.65%
1.85%
0.80%
$500,000 - $999,999
2.65%
1.90%
0.75%
$1,000,000 - $1,999,999
2.60%
2.00%
0.60%
$2,000,000 - $4,999,999
2.60%
2.05%
0.55%
$5,000,000 - $9,999,999
2.60%
2.10%
0.40%
$10,000,000 - above
2.65%
2.20%
0.45%
*A minimum of $100,000 of assets under management is required to participate in the World
Separately Managed Account Models (SMA). This account size may be negotiable under certain
circumstances. WIA may group certain related client accounts for the purposes of achieving the
minimum household size and determining the annualized fee.
Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee
schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis.
Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will
be considered in determining the fee schedule. These include the complexity of the client, assets
to be placed under management, anticipated future additional assets; related accounts; portfolio
style, account composition, reports, among other factors. The specific annual fee schedule will
be identified in the contract between the adviser and each client. Investment Advisory Fee
Schedule, as outlined below, is a tiered or layered fee schedule, which applies distinct fee rates
to different portions of the portfolio.
Unified Managed Account Models (UMA)
Assets Under Management
Annual Fee
Advisor Fee
Program Fee
$100,000* - $249,999
2.65%
1.85%
0.80%
$250,000 - $499,999
2.65%
1.85%
0.80%
13
$500,000 - $999,999
2.65%
1.90%
0.75%
$1,000,000 - $1,999,999
2.60%
2.00%
0.60%
$2,000,000 - $4,999,999
2.60%
2.05%
0.55%
$5,000,000 - $9,999,999
2.60%
2.10%
0.50%
$10,000,000 - above
2.65%
2.20%
0.45%
*A minimum of $100,000 of assets under management is required to participate in the Unified
Managed Account Models (UMA). This account size may be negotiable under certain
circumstances. WIA may group certain related client accounts for the purposes of achieving the
minimum household size and determining the annualized fee.
Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee
schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis.
Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will
be considered in determining the fee schedule. These include the complexity of the client, assets
to be placed under management, anticipated future additional assets; related accounts; portfolio
style, account composition, reports, among other factors. The specific annual fee schedule will
be identified in the contract between the adviser and each client.
Insurance and Annuity Exchange
Variable Annuities
Assets Under Management
Annual Fee
Advisor Fee
Program Fee
$10,000* - $99,999
2.20%
1.85%
0.35%
$100,000 - $249,999
2.15%
1.85%
0.30%
$250,000 - $499,999
2.16%
1.85%
0.31%
$500,000 - $749,999
2.17%
1.90%
0.27%
$750,000 - $999,999
2.17%
1.90%
0.27%
$1,000,000 - $1,999,999
2.24%
2.00%
0.24%
$2,000,000 - $4,999,999
2.27%
2.05%
0.22%
$5,000,000 - $9,999,999
2.32%
2.10%
0.22%
$10,000,000 - +
2.50%
2.30%
0.20%
14
Fixed Annuities
Assets Under Management
Annual Fee
Advisor Fee
Program Fee
$10,000* - $99,999
2.18%
1.85%
0.33%
$100,000 - $249,999
2.13%
1.85%
0.28%
$250,000 - $499,999
2.14%
1.85%
0.29%
$500,000 - $749,999
2.15%
1.90%
0.25%
$750,000 - $999,999
2.15%
1.90%
0.25%
$1,000,000 - $1,999,999
2.22%
2.00%
0.22%
$2,000,000 - $4,999,999
2.25%
2.05%
0.20%
$5,000,000 - $9,999,999
2.30%
2.10%
0.20%
$10,000,000 - +
2.48%
2.30%
0.18%
*A minimum of $10,000 of assets under management is required to participate in the
Insurance and Annuity Exchange (FIDx). This account size may be negotiable under certain
circumstances. WIA may group certain related client accounts for the purposes of achieving the
minimum household size and determining the annualized fee.
Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee
schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis.
Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will
be considered in determining the fee schedule. These include the complexity of the client, assets
to be placed under management, anticipated future additional assets; related accounts; portfolio
style, account composition, reports, among other factors. The specific annual fee schedule will
be identified in the contract between the adviser and each client. Investment Advisory Fee
Schedule, as outlined below, is a tiered or layered fee schedule, which applies distinct fee rates
to different portions of the portfolio.
Investment Supervisory Services Proprietary Model Portfolio Management Fees
Our annual fees for Model Portfolio Management Services are based upon a percentage of assets
under management and generally range from 0.25% to 3.00% for the Traditional Models and
.37% to 3.00% for the Buffered Models.
The annualized fee for Investment Supervisory Services will be charged as a percentage of assets
under management based on the corresponding program selected by the client, according to the
following schedules: Fees shall be prorated and paid quarterly, in advance, based upon the total
market value of the assets on the last day of the previous calendar quarter. Initial inception billing
15
will include fees for the remainder of the current calendar quarter, calculated in advance, on a
prorated basis from the day the initial deposit was added to the account.
Our Investment Advisory Fee Schedule, as outlined below, is a tiered or layered fee schedule
which applies distinct fee rates to different portions of the portfolio. For the first break point
multiply the first range amount, in this case $50,000, by the applicable rate for that range. Next,
multiply the second range, in this case $50,000, by its applicable, lower rate, then multiply the
third range amount, in this case $150,000, by its applicable lower rate on the schedule, and so
on until the calculation is complete. All accounts within the same family (husband, wife, and
minor children) are linked and treated as one household for purposes of fee calculations.
Corporate accounts are considered separately and, thus, would not be included in the household
for the purpose of reducing fees. The discounted fees are calculated based upon the cumulative
account values at the end of the prior calendar quarter. Any advanced fees due to the account
owner will be prorated and refunded in the event of a liquidation or transfer.
Buy/Hold Plus Fee Schedule for Traditional Models
Assets Under Management
Annual Fee
Advisor Fee
Program Fee
$25,000* - $49,999
2.50%
1.80%
0.70%
$50,000 - $99,999
2.50%
1.90%
0.60%
$100,000- $249,999
2.50%
2.00%
0.50%
$250,000 - $499,999
2.50%
2.05%
0.45%
$500,000 - $999,999
2.45%
2.05%
0.40%
$1,000,000 - $1,999,999
2.45%
2.10%
0.35%
$2,000,000 - $4,999,999
2.45%
2.15%
0.30%
$5,000,000- $9,999,999
2.45%
2.20%
0.25%
$10,000,000 - and above
2.50%
2.25%
0.25%
16
Buy/Hold Plus Fee Schedule for Buffered Models
Assets Under Management
Annual Fee
Advisor Fee
Program Fee
$25,000* - $49,999
2.57%
1.80%
0.77%
$50,000 - $99,999
2.62%
1.90%
0.72%
$100,000- $249,999
2.67%
2.00%
0.67%
$250,000 - $499,999
2.70%
2.05%
0.65%
$500,000 - $999,999
2.67%
2.05%
0.62%
$1,000,000 - $1,999,999
2.68%
2.10%
0.58%
$2,000,000 - $4,999,999
2.72%
2.15%
0.57%
$5,000,000- $9,999,999
2.76%
2.20%
0.56%
$10,000,000 - and above
2.80%
2.25%
0.55%
Minimum Account Size $25,000 Minimum Household Size $50,000
*A minimum of $25,000 of assets under management is required for this service. This household
size may be negotiable under certain circumstances. WIA may group certain related client
accounts for the purposes of achieving the minimum account size and determining the
annualized fee.
Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee
schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis.
Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will
be considered in determining the fee schedule. These include the complexity of the client, assets
to be placed under management, anticipated future additional assets; related accounts; portfolio
style, account composition, reports, among other factors. The specific annual fee schedule will
be identified in the contract between the adviser and each client. Discounts, not generally
available to our advisory clients, may be offered to family members and friends of associated
persons of our firm.
General Information
Termination of the Advisory Relationship: Clients may cancel advisory agreements without
penalty for a period of five (5) days after the date signed. Agreement shall remain in full force
and effect until such time as either party to the agreement receives written notification from the
17
other party of his or her desire to cancel the agreement. Upon receipt by Advisor of written notice
of cancellation, the Advisor shall complete the outstanding commitments and obligations made
by it on behalf of the investor; however, the Advisor shall not make any new commitments or
undertake additional obligations on behalf of the investor. As disclosed above, certain fees are
paid in advance of services provided. Upon termination of any account, any prepaid, unearned
fees will be promptly refunded. In calculating a client's reimbursement of fees, we will pro rate
the reimbursement according to the number of days remaining in the billing period as applicable.
Mutual Fund Fees: All fees paid to WIA for investment advisory services are separate and distinct
from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These
fees and expenses are described in each fund's prospectus. These fees will generally include a
management fee, other fund expenses, and a possible distribution fee. If the fund also imposes
sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual
fund directly, without our services. In that case, the client would not receive the services provided
by our firm which are designed, among other things, to assist the client in determining which
mutual fund or funds are most appropriate to each client's financial condition and objectives.
Accordingly, the client should review both the fees charged by the funds and our fees to fully
understand the total amount of fees to be paid by the client and to thereby evaluate the advisory
services being provided.
Wrap Fee Programs and Separately Managed Account Fees: Clients participating in separately
managed account programs may be charged various program fees in addition to the advisory fee
charged by our firm. Such fees may include the investment advisory fees of the Third Party Money
Managers, which may be charged as part of a wrap fee arrangement. In a wrap fee arrangement,
clients pay a single fee for advisory, brokerage and custodial services.
Client's portfolio transactions may be executed without commission charge in a wrap fee
arrangement. In evaluating such an arrangement, the client should also consider that, depending
upon the level of the wrap fee charged by the broker-dealer, the amount of portfolio activity in
the client's account, and other factors, the wrap fee may or may not exceed the aggregate cost
of such services if they were to be provided separately. We will review with clients any separate
program fees that may be charged to clients.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to
WIA minimum account requirements and advisory fees in effect at the time the client entered
into the advisory relationship. Therefore, our firm's minimum account requirements will differ
among clients.
How are Advisory Fees Calculated and Earned:
In Advance as a percentage of assets under management
How Frequently Do We Collect Advisory Fees: Quarterly
How Do We Collect Advisory Fees:
• Direct Debit of Client Brokerage, Managed, Mutual Fund or Bank Account
• Bill Client Directly
• Credit Card
18
Advisory Fees in General: Unless otherwise specified, all asset management fees are typically
prorated and paid quarterly, in advance. Fees are billed approximately 15 days after the end of
each calendar quarter and where appropriate, deducted directly from the Investor's account.
Clients should note that similar advisory services may (or may not) be available from other
registered (or unregistered) investment advisers for similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees
in excess of $1,200 more than six months in advance of services rendered.
Item 5 Account Requirements and Types of Clients
WIA provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
•
• High net worth individuals
• Pension and profit-sharing plans(other than plan participants)
• Charitable organizations
• Corporations or other businesses not listed above.
As previously disclosed in Item 5, our firm has established certain initial minimum account
requirements, based on the nature of the service(s) being provided. For a more detailed
understanding of those requirements, please review the disclosures provided in each applicable
service.
Item 6 - Portfolio Manager Selection and Evaluation
WIA serves as the portfolio manager in the wrap fee program. WIA may outsource its
portfolio management by using outside portfolio managers for the referenced Program.
WIA uses industry standards to measure the performance of its portfolio managers;
however, the firm does not use a third-party auditor to review and verify the performance
of its portfolio managers.
Performance-Based Fees and Side-By-Side Management
WIA does not charge any performance-based fees (fees based on a share of capital gains on
or capital appreciation of the assets of a client).
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting. In this type of technical analysis, we review charts of market and security activity in an
attempt to identify when the market is moving up or down and to predict when how long the
trend may last and when that trend might reverse.
19
Technical Analysis. We analyze past market movements and apply that analysis to the present
in an attempt to recognize recurring patterns of investor behavior and potentially predict future
price movement.
Technical analysis does not consider the underlying financial condition of a company. This
presents a risk in that a poorly-managed or financially unsound company may under perform
regardless of market movement.
Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular
stock against the overall market in an attempt to predict the price movement of the security.
Quantitative Analysis. We use mathematical models in an attempt to obtain more accurate
measurements of a company's quantifiable data, such as the value of a share price or earnings
per share, and predict changes to that data. A risk in using quantitative analysis is that the models
used may be based on assumptions that prove to be incorrect.
Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify
an appropriate ratio of securities, fixed income, and cash suitable to the client's investment goals
and risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a particular
security, industry or market sector. Another risk is that the ratio of securities, fixed income, and
cash will change over time due to stock and market movements and, if not corrected, will no
longer be appropriate for the client's goals.
Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager
of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability
to invest over a period of time and in different economic conditions. We may look at the
underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap
in the underlying investments held in another fund(s) in the client's portfolio. We also monitor
the funds or ETFs in an attempt to determine if they are continuing to follow their stated
investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may not be
able to replicate that success in the future. In addition, as we do not control the underlying
investments in a fund or ETF, managers of different funds held by the client may purchase the
same security, increasing the risk to the client if that security were to fall in value. There is
also a risk that a manager may deviate from the stated investment mandate or strategy of the
fund or ETF, which could make the holding(s) less suitable for the client's portfolio.
Third-Party Money Manager Analysis. We examine the experience, expertise, investment
philosophies, and past performance of independent third-party investment managers in an
attempt to determine if that manager has demonstrated an ability to invest over a period of time
and in different economic conditions. We monitor the manager's underlying holdings, strategies,
concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part
of our due-diligence process, we survey the manager's compliance and business enterprise risks
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Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the
companies whose securities we purchase and sell, the rating agencies that review these
securities, and other publicly-available sources of information about these securities, are
providing accurate and unbiased data. While we are alert to indications that data may be
incorrect, there is always a risk that our analysis may be compromised by inaccurate or
misleading information.
Investment Strategies
We use the following strategy(ies) in managing client accounts, provided that such strategy(ies)
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. We purchase securities with the idea of holding them in the client's
account for a year or longer. Typically, we employ this strategy when:
• we believe the securities to be currently undervalued, and/or
• we want exposure to a particular asset class over time, regardless of the current
projection for this class.
• 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.
Short-term purchases. When utilizing this strategy, we 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.
A short-term purchase strategy poses risks should the anticipated price swing not materialize;
we are then left with the option of having a long-term investment in a security that was designed
to be a short-term purchase, or potentially taking a loss.
In addition, this strategy involves more frequent trading than does a longer-term strategy, and
will result in increased brokerage and other transaction-related costs, as well as less favorable
tax treatment of short-term capital gains.
Trading. We purchase securities with the idea of selling them very quickly (typically within 30
days or less). We do this in an attempt to take advantage of our predictions of brief price swings.
Utilizing a trading strategy creates the potential for sudden losses if the anticipated price swing
does not materialize. Moreover, under those circumstances, we are left with few options:
•
•
having a long-term investment in a security that was designed to be a short-term
purchase, or
the potential of having to taking a loss.
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In addition, because this strategy involves more frequent trading than does a longer-term
strategy, there will be a resultant increase in brokerage and other transaction-related costs, as
well as less favorable tax treatment of short-term capital gains.
Risk of Loss. Securities investments are not guaranteed and you may lose money on your
investments. We ask that you work with us to help us understand your tolerance for risk.
Clients should understand that investing in any securities, including mutual funds, involves a risk
of loss of both income and principal.
Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our
firm may provide investment advisory services relative to client investment assets, clients
maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers
of securities beneficially owned by the client shall be voted, and (2) making all elections relative
to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events
pertaining to the client's investment assets. Clients are responsible for instructing each custodian
of the assets, to forward to the client copies of all proxies and shareholder communications
relating to the client's investment assets.
We may provide clients with consulting assistance regarding proxy issues if they contact us with
questions at our principal place of business.
Item 7 - Client Information Provided to Portfolio Managers
WIA is usually both your registered investment adviser and your portfolio manager. WIA
may outsource its portfolio management by using outside portfolio managers for the
referenced Programs. In some cases, your portfolio manager has the same access to you r
information as WIA. This information may include, among other things, income, net worth,
risk tolerance, and investment objectives. Portfolio Managers use this information to
determine an appropriate asset allocation and manage investments. When a client updates
their information with WIA, portfolio managers will be provided with the same updated
information.
Item 8 - Client Contact with Portfolio Managers
Clients may communicate with portfolio managers directly during normal business hours.
Consultations beyond normal business practices may require additional negotiated fees.
Item 9 - Additional Information
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to an evaluation of WIA or the integrity of WIA’s
management. WIA has no information applicable to this Item.
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Other Financial Industry Activities and Affiliations
WIA is a wholly owned subsidiary of WIA Holdings, LLC. Under the common control of WIA
Holdings, LLC, WIA is affiliated with Goldman Sachs & Co., LLC, a FINRA broker-dealer (Member
SIPC) and SEC Registered Investment Adviser, and World Investments, LLC, a FINRA broker dealer
(Members SIPC), WIA is also affiliated with World Insurance Associates, LLC, Scotts American,
LLC, Keating, LLC, ESA Associates, LLC, FastComp, LLC, Hamond Safety Management, LLC, Pacific
Coast NCA Premium Finance, LLC, and World Insurance Programs, LLC, all insurance agencies
engaging in Life, Health, Long Term Care, Variable, and various other Insurance business.
Recommendations for Goldman Sachs investment products are limited to a small subset of
products approved by WIA. No incentives are provided to WIA or WIA Investment Advisor
Representatives to recommend Goldman Sachs products over other investment products.
WIA is also affiliated with other financial services companies, but does not have any shared
business dealings, operations, referral programs, clients, representatives, or premises with these
other companies, and has no reason to believe the firm’s relationship with them otherwise
creates a conflict of interest with WIA clients. A full list of WIA’s affiliates will be provided upon
request.
Investment Adviser Representatives (“IARs”) of WIA may effect securities transactions for Clients
as registered representatives of World Investments, LLC. (“WI”) or St. Bernard Securities, LLC (“St.
Bernard”), both FINRA broker-dealers. WIA is affiliated with WI through the common control and
ownership by WIA Holdings, LLC. WIA has no affiliation with St. Bernard. Advisors that are
registered representatives of these firms may recommend either of the two firms with whom
they are registered for broker-dealers services. Factors for such a recommendation may be when
transaction compensation is seen as a benefit to the client. For broker-dealer services, WI or St.
Bernard, or their associated persons, may receive compensation, which is separate and distinct
from compensation related to investment advisory services. Commissions paid to advisors for
broker-dealer services may be higher or lower than those paid by other brokers.
All FINRA, SEC, and other regulatory agencies disclosure requirements and policies are observed
for all transactions. If a trade error were to occur, it may result in profit or loss to the firm. The
firm has controls in place to limit such trade errors. Investment Advisers will not participate in
any profits resulting from such errors.
Some Investment Adviser Representatives (“IARs”) of WIA may also be registered as IARs of
Acrisure Investment Advisory Solutions, LLC (“Acrisure”). However, these IARs do not effect any
transactions through Acrisure. One WIA Advisor is also registered as an Advisor with Nexus338,
an advisory firm providing technology-based retirement plan managed account services to non-
WIA clients. WIA is not affiliated with IWP, Acrisure, or Nexus338.
Individuals may also write Insurance business through Pensionmark Partners Insurance Services,
LLC (“PPIS”) as independent insurance agents. PPIS is affiliated with WIA through common
control and ownership. PPIS is an insurance producer group engaging in Life, Health, Long Term
Care and Variable Insurance business. Variable insurance products will be offered exclusively
through WI, while non-variable products will be offered directly with an insurance carrier through
the producer group contracts. Compensation will be paid directly by these entities.
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Individuals licensed as Registered Representatives or Insurance Agents may spend as much as
50% of their time on these non-advisory activities. When a client’s Advisor is acting in their
capacity as registered representatives or independent insurance agents, clients will be charged
separately from their advisory services. Clients have the option to purchase investment products
that we recommend through other brokers or agents that are not affiliated with WIA.
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
WIA has adopted a Code of Ethics for all supervised persons of the firm describing its high
standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes
provisions relating to the confidentiality of client information, a prohibition on insider trading, a
prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the
reporting of certain gifts and business entertainment items, and personal securities trading
procedures, among other things. All supervised persons at WIA must acknowledge the terms of
the Code of Ethics annually, or as amended.
Advisors of WIA may buy or sell securities that are recommended to clients. WIA’s employees
and persons associated with WIA are required to follow the Code of Ethics. Subject to satisfying
this policy and applicable laws, officers, directors, and employees of WIA and its affiliates may
trade for their own accounts in securities which are recommended to and/or purchased for WIA’s
clients. The Code of Ethics is designed to assure that the personal securities transactions,
activities, and interests of the employees of WIA will not interfere with (i) making decisions in the
best interest of advisory clients and (ii) implementing such decisions while, at the same time,
allowing employees to invest for their own accounts. Under the Code certain classes of securities
have been designated as exempt transactions, based upon a determination that these would not
materially interfere with the best interest of WIA’s clients. In addition, the Code requires pre-
approval of many transactions, and restricts trading in close proximity to client trading activity.
Nonetheless, because the Code of Ethics in some circumstances would permit employees to
invest in the same securities as clients, there is a possibility that employees might benefit from
market activity by a client. Employee trading is continually monitored under the Code of Ethics
to reasonably prevent conflicts of interest between WIA and its clients.
Advisors may recommend and trade in the same securities with clients and/or related accounts
at or about the same time. Generally, this would pose a conflict if the Advisor or related account
were given a better price than the client. To mitigate this conflict, it is procedure to not trade an
Advisors account or related persons’ account on the same day as a client unless the client gets
the better price.
Trades may be done on an aggregated basis when consistent with WIA's obligation of best
execution. In such circumstances, the Advisor (or related account) and client accounts will share
commission costs equally and receive securities at a total average price. WIA will retain records
of the trade order (specifying each participating account) and its allocation, which will be
completed prior to the entry of the aggregated order. Completed orders will be allocated as
specified in the initial trade order. Partially filled orders will be allocated on a pro-rata basis. Any
exceptions will be explained on the order.
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WIA’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting
WIA at (800) 833-1862 or by sending an email to compliance@worldadvisors.com.
Brokerage Practices
Advisory clients of WIA are required to use Pershing, LLC, a non-affiliated clearing broker dealer
for custodial and transaction services for client accounts and in some cases for World Securities,
Inc. Pershing LLC provides the clearing, asset allocation, custodial and transactional services that
are required to operate WIA, as its affiliated broker dealer World Securities, Inc. may not provide
one or more of these services. In addition, the use of Pershing LLC enables WIA to pay from the
client's advisory fees, some of the transaction fees as described in the fee schedule.
Each client of WIA provides written authority for the use of Pershing as the "clearing entity" for
their transactions and the commission costs that will be charged for said transactions.
Clients must include any limitations on this discretionary authority in the afore mentioned
limitations as required. Such
authority statement. Clients may change/amend these
amendments must be provided to us in writing.
Advisory clients of WIA in need of brokerage or custodial services other than the asset allocation
services offered, WIA may recommend the use of World Securities, Inc. for those services where
the investment advisor representative of WIA is properly licensed to do so and provided WIA can
meet its fiduciary obligation of best execution. However, no client is under obligation to effect
transactions through any recommended broker.
WIA will block trades where possible and when advantageous to clients. This blocking of trades
permits the trading of aggregate blocks of securities composed of assets from multiple client
accounts, so long as transaction costs are shared equally and on a pro-rated basis between all
accounts included in any such block.
Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an
average share price. WIA will typically aggregate trades among clients whose accounts can be
traded at a given broker, and generally will rotate or vary the order of brokers through which it
places trades for clients on any particular day. WIA block trading policy and procedures are as
follows:
• Transactions for any client account may not be aggregated for execution if the practice is
prohibited by or inconsistent with the client's advisory agreement with WIA, or our firm's
order allocation policy.
• Trading personnel in concert with the portfolio manager determine that the purchase or
sale of the particular security involved is appropriate for the client and consistent with
the client's investment objectives and with any investment guidelines or restrictions
applicable to the client's account.
• The portfolio manager must reasonably believe that the order aggregation will benefit,
and will enable WIA to seek best execution for each client participating in the aggregated
order. This requires a good faith judgment at the time the order is placed for the
execution. It does not mean that the determination made in advance of the transaction
must always prove to have been correct in the light of a "20-20 hindsight" perspective.
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Best execution includes the duty to seek the best quality of execution, as well as the best
net price.
• Prior to entry of an aggregated order, an electronic order ticket is generated which
identifies each client account participating in the order and the proposed allocation of the
order, upon completion, to those clients. Trading personnel have the ability to print order
tickets or generate a print screen of the entire allocation for any particular aggregated
trading activity.
•
If the order cannot be executed in full at the same price or time, the securities actually
purchased or sold by the close of each business day must be allocated pro rata among the
participating client accounts in accordance with the initial order ticket or other written
statement of allocation. However, adjustments to this pro rata allocation may be made
to participating client accounts in accordance with the initial order ticket or other written
statement of allocation. Furthermore, adjustments to this pro rata allocation may be
made to avoid having odd amounts of shares held in any client account, or to avoid
excessive ticket charges in smaller accounts.
• Generally, each client that participates in the aggregated order must do so at the average
price for all separate transactions made to fill the order and must share in the
commissions on a pro-rata basis in proportion to the client's participation. Under the
client's agreement with the custodian/broker, transaction costs may be based on the
number of shares traded for each client.
•
If the order will be allocated in a manner other than that stated in the initial statement of
allocation, a written explanation of the change must be provided to and approved by the
Chief Compliance Officer no later than the morning following the execution of the
aggregate trade.
• WIA client account records separately reflect, for each account in which the aggregated
transaction occurred, the securities which are held by, and bought and sold for, that
account.
• Funds and securities for aggregated orders are clearly identified on WIA records and to
the broker-dealers or other intermediaries handling the transactions, by the appropriate
account numbers for each participating client.
• No client or account will be favored over another.
Review of Accounts
Investment Supervisory Services Individual Portfolio Management
REVIEWS: While the underlying securities within Individual Portfolio Management Services
accounts are continually monitored, these accounts are reviewed regularly as the investment
advisor representatives deem necessary. Accounts are reviewed in the context of each client's
stated investment objectives and guidelines. More frequent reviews may be triggered by
material changes in variables such as the client's individual circumstances, or the market, political
or economic environment.
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These accounts are typically reviewed by the corresponding investment advisor representative.
REPORTS: In addition to the monthly statements and confirmations of transactions that clients
receive from their custodian, Individual registered investment advisors may provide other
reports summarizing account performance, balances and holdings. These reports will also remind
the client to notify us if there have been changes in the client's financial situation or investment
objectives and whether the client wishes to impose investment restrictions or modify existing
restrictions.
Investment Supervisory Services Proprietary Model Portfolio Management
REVIEWS: While the underlying securities within Individual Portfolio Management Services
accounts are continually monitored, these accounts are reviewed regularly as the managers
deem necessary. Accounts are reviewed in the context of each client's stated investment
objectives and guidelines. More frequent reviews may be triggered by material changes in
variables such as the client's individual circumstances, or the market, political or economic
environment. In addition, the investment advisor representatives review their client accounts on
a regular basis.
These accounts are typically reviewed by the portfolio manager.
REPORTS: In addition to the monthly/quarterly statements and confirmations of transactions that
clients receive from the custodian, Individual registered investment advisors may provide other
reports summarizing account performance, balances and holdings. These reports will also remind
the client to notify us if there have been changes in the client's financial situation or investment
objectives and whether the client wishes to impose investment restrictions or modify existing
restrictions.
Platform Providers, FSP (Fund Strategist Portfolio), SMA (Separately Managed Account), UMA
(Unified Managed Account)
REVIEWS: While the underlying securities within Individual Portfolio Management Services
accounts are continually monitored, these accounts are reviewed regularly as the managers
deem necessary. Accounts are reviewed in the context of each client's stated investment
objectives and guidelines. More frequent reviews may be triggered by material changes in
variables such as the client's individual circumstances, or the market, political or economic
environment. In addition, the investment advisor representatives review their client accounts on
a regular basis.
These accounts are typically reviewed by the portfolio manager.
REPORTS: In addition to the monthly/quarterly statements and confirmations of transactions that
clients receive from the custodian, Individual registered investment advisors may provide other
reports summarizing account performance, balances and holdings. These reports will also remind
the client to notify us if there have been changes in the client's financial situation or investment
objectives and whether the client wishes to impose investment restrictions or modify existing
restrictions.
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Mutual Fund Portfolio Management
REVIEWS: WIA continually reviews and monitors the Mutual Fund's holdings in accordance with
the investment objectives as detailed in the Fund Prospectus.
REPORTS: Clients should refer to the Fund Prospectus for information regarding regular reports
to the fund by WIA.
Selection And Monitoring of Third-Party Money Managers
REVIEWS: These client accounts should refer to the independent registered investment adviser's
Firm Brochure (or other disclosure document used in lieu of the brochure) for information
regarding the nature and frequency of reviews provided by that independent registered
investment adviser.
WIA will provide reviews as contracted at the inception of the advisory relationship.
These accounts are typically reviewed by the corresponding investment advisor representative.
REPORTS: These clients should refer to the independent registered investment adviser's Firm
Brochure (or other disclosure document used in lieu of the brochure) for information regarding
the nature and frequency of reports provided by that independent registered investment adviser.
WIA will provide these client accounts with reports if and when as contracted for at the inception
of the advisory relationship.
Custody
WIA is deemed to have custody of client funds because investment advisory fees are directly debited
from some Client accounts. Debiting of fees is done pursuant to authorization provided by the Client.
Clients should receive statements at least quarterly from the selected qualified Custodian that holds
and maintains client’s investment assets. WIA urges clients to carefully review such statements and
compare the official custodial records to the account statements that WIA may provide. WIA’s
statements may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies of certain securities.
WIA is also deemed to have custody of client assets as a result of certain Clients’ authorization for
WIA and/or its IARs to distribute assets from their account(s) to a specific named recipient on demand
in accordance with a standing letter of instruction. WIA complies with the SEC No-Action Letter dated
2/21/2017 (Investment Adviser Association) allowing firms complying with the provisions of the No-
Action Letter to forego an annual surprise custody examination with respect to those assets.
Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we place
trades in a client's account without contacting the client prior to each trade to obtain the client's
permission.
Our discretionary authority includes the ability to do the following without contacting the client:
Determine the security to buy or sell; and/or Determine the amount of the security to buy or sell.
Clients give us discretionary authority when they sign a discretionary agreement with our firm
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and may limit this authority by giving us written instructions. Clients may also change/amend
such limitations by once again providing us with written instructions.
Financial Information
Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client
more than six months in advance of services rendered. Therefore, we are not required to include
a financial statement.
As an advisory firm, we are also required to disclose any financial condition that is reasonable
likely to impair our ability to meet our contractual obligations. WIA has no additional financial
circumstances to report.
WIA has not been the subject of a bankruptcy petition at any time during the past ten years.
Privacy Policy
World Investment Advisors, LLC (“WIA”) recognizes that its Clients have an expectation that WIA
and its affiliates will maintain the confidentiality of Clients’ nonpublic personal information.
Consequently, WIA has adopted this Privacy Policy concerning information obtained during the
servicing of Client’s account(s).
Nonpublic Information: Nonpublic information obtained by WIA for purposes of providing
services hereunder will not be furnished to third parties for any other purpose other than in
furtherance of the services to be provided hereunder. Notwithstanding the foregoing, WIA may
disclose nonpublic information (i) to the extent such disclosure is required by court order or by a
valid order of a governmental body governmental or quasi-governmental agency (such as FINRA)
(ii) after the time of disclosure such information becomes part of the public knowledge or
literature, not as a result of any inaction or action of WIA, (iii) reasonably necessary for WIA to
enforce its legal rights in any dispute with that Client; or (iv) is approved by Client, in writing, for
release. WIA does not disclose nonpublic personal information about its Clients to any party
except as permitted by law.
Sources of Personal Information: WIA collects Personal Information about its Clients from
meetings with Clients and on applications or other forms Clients have submitted to WIA, as well
as information about Clients’ investments or transactions with WIA or others (such as third-party
service providers or fund companies) from other sources.
How WIA Protects the Confidentiality of Clients’ Nonpublic Personal Information: WIA does
not sell or trade Clients’ information with nonaffiliated companies. When information is provided
to third party service providers, safeguards are in place to assure that information is used only
for the purpose it is provided. WIA maintains its records on secured computers. Prospective
employees are screened for criminal convictions. Once hired, employees are made aware of
WIA’s Privacy Policy and of the confidential nature of the information they handle. Employees
are limited to accessing only that customer information that is necessary to perform their job
functions.
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To Whom This Policy Applies: This Notice applies to all WIA Clients who enter into an Advisory
Services Agreement or Customer Agreement with WIA. For Former Clients: WIA’s Privacy Policy
continues to apply even to Clients that have terminated services with the firm.
Internet Cookies: An internet “cookie” is a small amount of data that is placed on to your
electronic device by a website and stored in your internet browser. Cookies allow websites to
store things like preferences, so that it can recognize users when returning to the site and
respond appropriately. When individuals access the Worldadvisors.com website, WIA makes use
of cookies to improve the load times and functionality of the website, and in some cases
registration pages. WIA may from time to time also utilize data tracking software to assist in
spotting trends and areas of improvement on the website. By accessing the Worldadvisors.com
site and embedded web pages, users are providing their express approval allowing WIA to utilize
these technologies to improve services provided. WIA may also use various third-party cookies
to report usage statistics of the service, or to authenticate users and prevent fraudulent access
of user accounts.
Access to and Correction of Information: Upon the written request of Clients, WIA will make
available for review any file that may be maintained for their personal Information; provided,
however, that any Information collected in connection with, or in anticipation of, any claim or
legal proceeding will not be made available. If Clients notify WIA that any Information is
incorrect, the information will be reviewed. If WIA agrees the information is incorrect, records
will be corrected. If WIA disagrees, Clients may submit a short statement of dispute, which will
be included in any future disclosure of the disputed Information.
Additional California Privacy Disclosures: Please consult the supplemental WIA Privacy Notice
for California Residents for additional disclosures pertinent to California residents.
Further Information: WIA reserves the right to change this Privacy Policy at any time. The
examples contained within this Privacy Policy are illustrations and are not intended to be
exclusive. This Policy attempts to comply with federal and state regulations regarding privacy.
Clients may have additional rights under other foreign or domestic laws that may apply to them.
If the financial advisor servicing a client account leaves WIA to join another firm, the advisor is
permitted to retain copies of client information so that he/she can assist with the transfer of the
client account and continue to serve the client at their new firm.
“Opting Out” of Third-Party Disclosures: If a client does not want a financial advisor to retain
copies of client sensitive information when he/she leaves WIA to join another firm, the client may
contact the WIA Compliance Department by calling (800) 833-1862 or by sending an email to
compliance@worldadvisors.com to request further information regarding this policy.
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