A. Description of the Advisory Firm This firm has been in business since 2008, and the principal owner is Douglas Dean
Vander Weide.
B. Types of Advisory Services
Valiant Wealth, LLC (hereinafter “Valiant Wealth”) offers the following services to
advisory clients:
Investment Supervisory Services
Valiant Wealth offers ongoing portfolio management services based on the individual
goals, objectives, time horizon, and risk tolerance of each client. Valiant Wealth creates
an Investment Advisory Contract for each client, which outlines the client’s current
situation (income, tax levels, and risk tolerance levels) and then constructs a plan (the
Investment Advisory Contract) to aid in the selection of a portfolio that matches each
client’s specific situation. Investment Supervisory Services include, but are not limited
to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
Valiant Wealth evaluates the current investments of each client with respect to their risk
tolerance and time horizon. Valiant Wealth requests discretionary authority from clients
in order to select securities and execute transactions without permission from the client
prior to each transaction. Risk tolerance levels are documented in the Investment
Advisory Contract, which is signed by each client.
Financial Planning Financial planning may include, but is not limited to: investment planning, insurance
planning, tax concerns, retirement planning, education planning, and debt/credit
planning. The fees associated with these services are variable depending upon the
complexity of the services needed. Each client’s financial planning fee is documented in
Exhibit II of the Investment Advisory Contract.
Services Limited to Specific Types of Investments
Valiant Wealth offers investment advice and/or money management to mutual funds,
equities, bonds, fixed income, debt securities, ETFs, REITs, private placements, options
and government securities. Valiant Wealth may use other securities as well to help
diversify a portfolio when applicable. Upon request, Valiant Wealth may offer advice on
securities that clients hold outside of their accounts at Valiant Wealth.
C. Client Tailored Services and Client Imposed Restrictions Valiant Wealth offers the same suite of services to all of its clients. However, specific
client financial plans and their implementation are dependent upon the client
Investment Advisory Contract that outlines each client’s current situation (income, tax
levels, and risk tolerance) and is used to construct a client specific plan to aid in the
selection of a portfolio that matches restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs. However, if the restrictions prevent Valiant
Wealth from properly servicing the client account, or if the restrictions would require
Valiant Wealth to deviate from its standard suite of services, Valiant Wealth reserves the
right to end the relationship.
D. Wrap Fee Programs
Valiant Wealth does not participate in any wrap fee programs.
E. Amounts Under Management
Valiant Wealth has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $165,877,635 $24,382,856 February 20, 2020
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A. Fee Schedule Investment Supervisory Services Fees Assets Under Management Annual Fee First $1,000,000 1.50%
Next $1,000,000 1.20%
Next $3,000,000 0.90%
Above $5,000,000 Negotiable
These fees are negotiable, and the final fee schedule is attached as Exhibit II of the
Investment Advisory Contract. Fees are paid quarterly in arrears. Clients may terminate
their contracts with thirty (30) days’ written notice. If client terminates prior to the end
of a quarter, Valiant Wealth is entitled to a pro rata fee for the days of service provided
during the final quarter. Client will be sent an invoice detailing the charges, and
payment will be required within thirty (30) days.
We may also charge a percentage of the annual gross profits for the account in
performance fees. These fees are payable annually in arrears, unless otherwise
negotiated. The performance fee allocation may be subject to a “high water mark”
provision. No performance fee will be charged, except to the extent that the amount of
the capital increase exceeds the sum of any cumulative loss in the account on a yearly
basis. Annual gross profits are defined as the difference in the value of the account
between January 1 and December 31, adjusted for deposits and withdrawals made
during the year. Clients should note that a fee in excess of 3.00% of assets under
management is in excess of industry norm and similar advisory services can be obtained
for less.
Because fees are charged in arrears, no refund policy is necessary. Clients may terminate
their accounts without penalty within five (5) business days of signing the advisory
contract. Advisory fees are withdrawn directly from the client’s accounts with client
written authorization.
In cases where Advisor fees are directly deducted, Advisor is required to a.) Obtain
client authorization, b.) Send a copy of the invoice to the client at the same time that the
Valiant Wealth directs invoice to the custodian for payment, c.) Disclose that the
Advisor will send quarterly invoices to the client wherein Advisor fees are itemized.
Financial Planning Fees Depending upon the complexity of the situation and the needs of the client, the rate for
financial planning is usually between $1,000 and $15,000. Fees are paid in advance, but
never more than three months in advance. Fees that are charged in advance can be
refunded based on the prorated amount of work completed at the point of termination.
The fees are negotiable, and the final fee schedule will be attached as Exhibit II of the
Investment Advisory Contract. Clients may terminate their contracts without penalty
within five (5) business days of signing the advisory contract. After such time, clients
may terminate their account with thirty (30) days written notice.
B. Payment of Fees Payment of Investment Supervisory Fees
Advisory Fees are withdrawn directly from the client’s account(s) with client written
authorization. Fees for assets under management are paid quarterly in arrears.
Payment of Financial Planning Fees
Fixed Financial Planning Fees are paid via check or journal request, but never more than
three months in advance. Fees that are charged in advance can be refunded based on the
prorated amount of work completed at the point of termination.
C. Clients Are Responsible For Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees, mutual
fund fees, transaction fee etc.). Those fees are separate and distinct from the fees charged
by Valiant Wealth. Please see Item 12 of this brochure regarding broker/custodian.
D. Prepayment of Fees
Valiant Wealth only collects financial planning fees in advance. Fees that are collected in
advance will be refunded based on the prorated amount of work completed at the point
of termination. Fees will be returned within fourteen days to the client via check or to be
deposited back into client’s account.
E. Outside Compensation For the Sale of Securities to Clients
Neither Valiant Wealth nor its supervised persons accept any compensation for the sale
of securities or other investment products, including asset-based sales charges or
services fees from the sale of mutual funds.
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We charge performance-based fees to “Qualified clients” who have a net worth greater than
$2,100,000, or those for whom we manage a minimum of $1,000,000, from the beginning of our
agreement for services. Performance-based fees are fees based on a share of capital gains or
capital appreciation of a client’s account. The amount of the performance-based fee we charge is
described in the “Fees and Compensation - Item 5” section in this Brochure.
Performance based fee arrangements may create an incentive for Valiant Wealth to recommend
investments, which may be riskier or more speculative than those investments that would be
recommended under a different fee arrangement.
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Valiant Wealth generally provides investment advice and/or management supervisory services
to the following Types of Clients:
Individuals
High-Net-Worth Individuals
Trusts, Estates, or Charitable Organizations
Corporations or Business Entities
Valiant Wealth may also provide investment advice and/or supervisory services about
certain privately-issued securities for those clients who represent they are accredited
investors within the meaning of Regulation D of the Securities Act and who otherwise
meet certain investor standards.
Minimum Account Size There is an account minimum, $100,000, which may be waived by the investment
advisor, based on the needs of the client and the complexity of the situation.
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Investment Loss A. Methods of Analysis
Valiant Wealth’s primary method of analysis includes the use of proprietary data and
tools of Dimensional Fund Advisors.
Investing in securities involves risk of loss. Clients should be able to bear the loss of their entire investment. B. Investment Strategies
Valiant Wealth employs a “buy and hold” approach to asset management. The practice
of this style of asset management is based on the belief that no one can time the market.
Valiant Wealth adheres to the following principles:
• Markets are efficient and assets are fairly priced.
• Diversification reduces the risk of uncertainty. Asset allocation and expenses
determine results in the portfolio.
Valiant Wealth offers clients a range of Model Portfolios from which to choose. Each
Model Portfolio is designed to offer an optimized asset allocation based on varying
levels of risk. In setting their investment objectives, Valiant Wealth recommends clients
consider which of the risk profiles is best suited to them.
Investing in securities involves a risk of loss of principal. C. Risks of Specific Securities Utilized Valiant Wealth generally seeks investment strategies that do not involve significant or
unusual risk beyond that of the general domestic and/or international equity markets.
Mutual Funds: Investing in mutual funds carries the risk of capital loss. Mutual funds
are not guaranteed or insured by the FDIC or any other government agency. You can
lose money investing in mutual funds. All mutual funds have costs that lower
investment returns. They can be of bond “fixed income” nature (lower risk) or stock
“equity” nature (mentioned above).
Equity: Investing in equities generally refers to buying shares of stocks by an individual
or firms in return for receiving a future payment of dividends and capital gains if the
value of the stock increases. There is an innate risk involved when purchasing a stock
that it may decrease in value and the investment may incur a loss.
Treasury Inflation Protected / Inflation Linked Bonds: The Risk of default on these
bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however,
they carry a potential risk of losing share price value, albeit rather minimal.
Fixed Income: Investing in Fixed Income guarantees fixed periodic payments in the
future that may involve economic risks such as inflationary risk, interest rate risk,
default risk, repayment of principal risk, etc.
Debt: Investing in Debt carries risks such as the possibility of default on the principal,
fluctuation in interest rates, and counterparties being unable to meet obligations.
Stocks & Exchange Traded Funds (ETF): Investing in stocks & ETF's carries the risk of
capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy).
Investments in these securities are not guaranteed or insured by the FDIC or any other
government agency.
Real Estate Funds: Investing in Real Estate Funds carries risks that are inherent in this
sector of the market. Liquidity risk, market risk, and interest rate risk are just some of
the factors that can influence the gain or loss that is passed on to the investor. Liquidity
and market risk tend to have a greater effect on funds that are more growth-oriented, as
the sale of appreciated properties depends upon market demand. Conversely, interest
rate risk impacts the amount of dividend income that is paid by income-oriented funds.
Hedge Funds: Hedge Funds are not suitable for all investors and involve a high degree
of risk due to several factors that may contribute to above average gains or significant
losses. Such factors include leveraging or other speculative investment practices,
commodity trading, complex tax structures, a lack of transparency in the underlying
investments, and generally the absence of a secondary market.
REITs: Real Estate Investment Trusts have specific risks including valuation due to cash
flows, dividends paid in stock rather than cash, and the payment of debt resulting in
dilution of shares.
Private Placements: Investing in Private Placements carries a substantial risk, as they
are largely unregulated offerings not subject to securities laws.
Option Risk: The risk with option buying are the risk of losing your entire investment in
a relatively short period time and losing your entire investment as the option goes out of
the money and as expiration nears. The risk with option selling are options sold may be
exercised at any time before expiration and forgoing the right to profit when the
underlying stock rises above the strike price of the call option sold.
D. Risks of Trading Long term trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various other types of
risk that will typically surface at various intervals during the time the client owns the
investments. These risks include but are not limited to inflation (purchasing power) risk,
interest rate risk, economic risk, market risk, and political/regulatory risk.
Short-term trading risks include liquidity, economic stability, and inflation.
Short sales risks include the upward trend of the market and the infinite possibility of
loss.
Margin transactions use leverage that is borrowed from a brokerage firm as collateral.
Options writing involve a contract to purchase a security at a given price, not
necessarily at market value, depending on the market.
Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss of principal.
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A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report.
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A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither Valiant Wealth nor its representatives are registered as a broker/dealer or as
representatives of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Valiant Wealth nor its representatives are registered as a FCM, CPO, or CTA.
C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests
Douglas Vander Weide, Managing Member, is a Manager of Valiant College Hill, LLC,
an Iowa based LLC, and Private Placement Offering with the sole purpose of buying a
limited partnership interest in College Hill Associates, L.P., a partnership engaged in
property development. Investments in Valiant College Hill, LLC are offered and sold
only to “accredited investors” as that term is defined in Rule 501(a) of the Securities Act.
Mr. Vander Weide is compensated for acting as a Manager of this entity.
Douglas Vander Weide, Managing Member is also a Manager of VWA ACS, LLC, an
Iowa based LLC and Private Placement Offering with the sole purpose of buying an
ownership interest in Associated Computer Systems, LLC. Investments in VWA ACS,
LLC are offered and sold only to “accredited investors” as that term is defined in Rule
501(a) of the Securities Act. Mr. Vander Weide is compensated for acting as a Manager
of this entity.
Douglas Vander Weide, Managing Member is a Manager of Valiant Twin Bridges, LLC,
an Iowa based LLC and Private Placement Offering with the purpose of buying a limited
partnership interest in Twin Bridges Associates, L.P., a company engaged in property
development. Investments in Valiant Twin Bridges, LLC are offered and sold only to
“accredited investors” as that term is defined in Rule 501(a) of the Securities Act. Mr.
Vander Weide is compensated for acting as a Manager of this entity.
Douglas Vander Weide, Managing Member, is a Manager of Valiant Regenexx LLC, an
Iowa based LLC formed for the purpose of investing in Regenexx, LLC, a privately held
biotechnology company. Investments in Valiant Regenexx LLC are offered and sold only
to “accredited investors” as that term is defined in Rule 501(a) of the Securities Act. Mr.
Vander Weide is compensated for acting as a Manager of this entity.
Valiant Wealth’s advisory clients are currently invested in or may be solicited to invest
in Valiant College Hill, LLC, VWA ACS, LLC, Valiant Twin Bridges, LLC, and Valiant
Regenexx LLC along with Mr. Vander Weide. No advisory fees are assessed for assets
held in Valiant College Hill, LLC, VWA ACS, LLC, Valiant Twin Bridges, LLC, and
Valiant Regenexx LLC. Investors to whom such private offerings are made will receive a
private placement memorandum or other relevant offering documents. Please refer to
the offering documents for a complete description of the fees, conflicts of interest,
investment objectives, risks, and other important information associated with investing
in such companies.
Douglas Vander Weide is also on the Board of Directors for The Abod Shelters
Foundation, a charitable organization. Clients may make donations to The Abod Shelters
Foundation; however, Valiant Wealth does not recommend or advise them on that
matter.
D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections Valiant Wealth does not utilize nor select other advisors or third party managers. All
assets are managed by Valiant Wealth management.
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Trading A. Code of Ethics The employees of Valiant Wealth have committed to a Code of Ethics. The purpose of
our Code of Ethics is to ensure that when employees buy or sell securities for their
personal account, they do not create actual or potential conflict with our clients. We do
not allow any employees to use non-public material information for their personal profit
or to use internal research for their personal benefit in conflict with the benefit to our
clients.
Valiant Wealth’s policy prohibits any person from acting upon or otherwise
misusing non-public or inside information. No advisory representative or other
employee, officer or director of Valiant Wealth may recommend any transaction
in a security or its derivative to advisory clients or engage in personal securities
transactions for a security or its derivatives if the advisory representative
possesses material, non-public information regarding the security.
Valiant Wealth’s Code of Ethics is based on the guiding principle that the
interests of the client are our top priority. Valiant Wealth’s officers, directors,
advisors, and other employees have a fiduciary duty to our clients and must
diligently perform that duty to maintain the complete trust and confidence of
our clients. When the potential for conflict arises, it is our obligation to put the
client’s interests over the interests of either employees or the company.
The Code of Ethics applies to “access” persons. “Access” persons are employees
who have access to non-public information regarding any clients' purchase or
sale of securities, or non-public information regarding the portfolio holdings of
any reportable fund, who are involved in making securities recommendations to
clients, or who have access to such recommendations that are non-public.
The firm will provide a copy of the Code of Ethics to any client or prospective client
upon request.
B. Recommendations Involving Material Financial Interests Refer to Item 10 C and 11 C. of this brochure.
C. Investing Personal Money in the Same Securities as Clients Principals of Valiant Wealth may invest in private placements that we also recommend
to clients. As such, this creates a conflict of interest, as the number of investors in certain
private placements could be small providing a financial interest for us. Valiant Wealth
addresses potential conflicts of interest by making full disclosure of such relationships to
its Clients and adhering to written investment policies and strategies in recommending
investments.
D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of Valiant Wealth may buy or sell securities for
themselves at or around the same time as clients. The Chief Compliance Officer of
Valiant Wealth is Scott Stegg. He reviews all employee trades each quarter. The personal
trading reviews help us ensure that the personal trading of employees does not affect
the markets and that clients of the firm receive preferential treatment. Doug Vander
Weide, Managing member, reviews Scott Stegg’s trades.
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A. Factors Used to Select Custodians and/or Broker/Dealers
The Custodian, Schwab Institutional, a division of Charles Schwab & Co., Inc., CRD #
5393, was chosen as the custodian based on their relatively low transaction fees and
access to mutual funds and ETFs. Valiant Wealth does not charge a premium or
commission on transactions, beyond the actual cost imposed by Schwab Institutional.
1. Research and Other Soft-Dollar Benefits Valiant Wealth utilizes the services of custodial broker-dealers. Economic benefits are
received by Valiant Wealth, which would not be received if Valiant Wealth did not give
investment advice to clients. These benefits include: A dedicated trading desk, a
dedicated service group and an account services manager dedicated to Valiant Wealth’s
accounts, ability to conduct "block" client trades, electronic download of trades, balances
and positions, duplicate and batched client statements, and the ability to have advisory
fees directly deducted from client accounts.
2. Brokerage for Client Referrals
Valiant Wealth receives no referrals from a broker-dealer or third party in exchange for
using that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
Valiant Wealth will not allow clients to direct Valiant Wealth to use a specific broker-
dealer to execute transactions. Clients must use Valiant Wealth recommended custodian
(broker-dealer). By requiring clients to use a specific custodian, Valiant Wealth may be
unable to achieve most favorable execution of client transaction and that this may cost
clients money over using a lower-cost custodian.
B. Aggregating (Block) Trading for Multiple Client Accounts Valiant Wealth maintains the ability to block trade purchases across accounts. Block
trading may benefit a large group of clients by providing Valiant Wealth the ability to
purchase larger blocks resulting in smaller transaction costs to the client. Declining to
block trade can cause more expensive trades for clients.
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A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
Valiant Wealth monitors client accounts on a continuous basis and conducts formal
account reviews at least annually. Accounts are reviewed by Douglas Vander Weide and
Scott Stegg.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Additional reviews may be offered in certain circumstances. Triggering factors that may
warrant additional reviews include, but are not limited to, changes in economic
conditions, changes in the client’s financial situation or investment objectives, or a
client’s request.
C. Content and Frequency of Regular Reports Provided to Clients Each client will receive quarterly written reports detailing account performance, which
will come from Valiant Wealth. Clients may be provided with financial planning
deliverables. Such deliverables could include any of the following: cash flow analysis,
net worth statement, retirement projections, education analysis, and/or Valiant
Wealth’s proprietary wealth management system. Verbal advice may also be given
which may or may not include tangible deliverables.
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A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Refer to Item 10 C. of this brochure.
B. Compensation to Non – Advisory Personnel for Client Referrals Non-employee (outside) consultants, individuals, and/or entities, who are directly responsible
for bringing a Client to Valiant Wealth, may receive compensation from the firm. Such
arrangements will comply with the requirements set forth in Rule 206(4)-3 of the Investment
Advisers Act of 1940, including the requirement that the relationship between the solicitor and
the investment adviser be disclosed to the Client at the time of the solicitation or referral. In
addition, all applicable state laws will be observed. Under these arrangements, the Client does
not pay higher fees than Valiant Wealth’s normal/typical advisory fees.
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All assets are held at qualified custodians, which means the custodian provides statements
directly to the clients at their address of record. Clients will receive all required account
statements and billing invoices that are required in each jurisdiction, and they should carefully
review those statements for accuracy.
At the request of some clients, Valiant Wealth has obtained login information to client
brokerage accounts. In doing so, we are deemed to have custody over client funds and
securities.
Associated Persons of Valiant Wealth serve as trustees to certain accounts for which we provide
investment advisory services. Our capacity as trustees gives us custody over these client
relationships. These accounts will be held with a bank, broker-dealer, or other independent,
qualified custodian. If any Associated Person acts as trustee for any of your advisory accounts,
you will receive account statements from the independent, qualified custodian(s) holding your
funds and securities at least quarterly. You should carefully review account statements for
accuracy.
We are also deemed to have custody of client funds and securities because of the fee deduction
authority granted by the client in the investment advisory agreement and in certain situations
where we accept standing letters of authorization from clients to transfer assets to third parties.
We maintain safeguards in accordance with regulatory requirements regarding custody of
client assets.
We are also deemed to have custody of client funds and securities due to Mr. Vander Weide’s
association with Valiant College Hill, LLC and VWA ACS, LLC (described in further detail
under Item 10 above). We have retained an independent certified public accountant to conduct
an annual surprise examination of client funds and securities.
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For those client accounts where Valiant Wealth provides ongoing supervision, the client has
given Valiant Wealth written discretionary authority over the client’s accounts with respect to
securities to be bought or sold and the amount of securities to be bought or sold. Details of this
relationship are fully disclosed to the client before any advisory relationship has commenced.
The client provides Valiant Wealth discretionary authority via the Investment Advisory
Contract.
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Valiant Wealth will not ask for, nor accept voting authority for client securities. Clients will
receive proxies directly from the issuer of the security or the custodian. Clients should direct all
proxy questions to the issuer of the security.
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A. Balance Sheet
Valiant Wealth does not require nor solicit prepayment of more than $500 in fees per
client, six months or more in advance and therefore does not need to include a balance
sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients
Neither Valiant Wealth nor its management has any financial conditions that are likely
to reasonably impair its ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years Valiant Wealth has not been the subject of a bankruptcy petition.
Item 19: Requirements For State Registered Advisers Education and business background, including any outside business activities and
disclosable events for all management and supervised persons can be found in the
Supplement to this Brochure (Part 2B of Form ADV Part 2.)
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