General
Belvedere Wealth Advisors, LLC (“Belvedere”) is organized in the state of Florida. This Firm
has been established in 2018, and is wholly owned by Belvedere Capital Holding, LLC.
Belvedere offers the following services to advisory clients:
Investment Supervisory Services
Belvedere will offer non-discretionary investment advisory services to its clients. These
services will involve a comprehensive periodic review of assets held by a client at one or
more third party custodians, which may be broker-dealers, banks, or other appropriate
financial institutions, and provide advice to the client regarding potential investment
transactions in the client’s accounts. By reviewing a client’s aggregate investments across
multiple accounts, Belvedere will be able to advise a client on a more comprehensive basis
than may be possible for an institution providing advice only with respect to a single
account maintained at that institution. Belvedere will not offer custody services to its
clients. As described more fully below, Belvedere will be compensated in the form of
annual advisory fees for its advice, and will not be compensated in respect of transactions
executed in its client’s accounts. As a result, Belvedere’s advice will not be driven in any
sense by a financial stake in the transactions it may recommend.
Belvedere also will offer discretionary investment management services to its clients.
These services will involve detailed consultations with the client for the purpose of
formulating customized investment objectives and criteria, following which Belvedere will
manage the client’s portfolio in a manner consistent with such objectives. On a periodic
basis, not less often than annually, Belvedere will conduct follow-up consultations with
each discretionary client and review investment objectives and account performance, and
agree with the client on any adjustments to the client’s investment objectives that may be
determined with the client to be appropriate. As in the case of its non-discretionary
services, Belvedere will be compensated for its discretionary services in the form of annual
management fees, and will not be compensated in respect of transactions executed in its
client’s accounts. As a result, Belvedere’s management of a client’s account will not be
driven in any sense by a financial stake in the transactions it may initiate for the client.
Additional General Information
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended
to clients or engaged directly by the client on an as-needed basis. Conflicts of interest related
to recommendations of other professionals will be disclosed to the clients in the event they
should occur.
Belvedere’s Agreements may not be assigned without client consent.
As of October 17, 2018, Belvedere has $0 in assets under management (“AUM”).
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All fees are negotiable, and the precise manner in which each client’s fees are determined
will be specified in the client’s account agreement with Belvedere.
Belvedere’s advisory and management fees generally are charged on the basis of the
aggregate market value of the assets in a client’s account (including cash and equivalent
items). Belvedere’s standard fee schedule, which may be subject to exception if agreed by
Belvedere in writing on a case-by-case basis, is as follows:
• 1.5% per annum on accounts of $500,000 or less
• 1.3% per annum on accounts over $500,000 but not over $2,000,000
• 1.2% per annum on accounts over $2,000,000 but not over $5,000,000
• 1.0% per annum on accounts over $5,000,000
Belvedere’s fees are payable quarterly in arrears, and shall be due and payable to
Belevedere within ten (10) days after the end of each calendar quarter. Belvedere will send
invoices to clients at the end of each quarter for purposes of collecting any advisory and
management fees that are due and owing to Belvedere.
For purposes of calculating Belvedere’s annual advisory or management fee, the aggregate
market value of the assets in the client’s account is determined as of the end of each
calendar quarter (before deducting applicable fees and charges) unless there have been
additions to or withdrawals from the Account during the quarter, in which case the client's
fee will be based on the average aggregate market value during such quarter. Belvedere’s
annual advisory and management fees are prorated for any period of less than a full
calendar quarter.
Belvedere’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, third party investment and other third parties
such as fees charged by managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes
on brokerage accounts and securities transactions. Mutual funds and exchange traded
funds also charge internal management fees, which are disclosed in a fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to Belvedere’s fee, and
Belvedere shall not receive any portion of these commissions, fees, and costs.
Item 12 further describes the factors that Belvedere considers in selecting or
recommending broker-dealers for client transactions and determining the reasonableness
of their compensation (
e.g., commissions).
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Belvedere intends to provide investment advisory and management services to individuals,
high net worth individuals, trusts and U.S. and international business organizations.
Belvedere does not have an absolute minimum for investment portfolios or a minimum
account size. Belvedere typically provides investment advisory services to clients with
investment portfolios of $500,000 or more. This limit maybe met by a single account or by
aggregating the assets within multiple related accounts. This minimum account size serves
as a guideline, only. Belvedere, in its sole discretion, may waive this minimum account
requirement.
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Belvedere begins each new client relationship with one or more detailed interviews of the
client for the purpose of developing a comprehensive understanding of the client’s financial
goals, investment horizon and objectives, attitudes toward risk, and level of financial
sophistication. Based on one of these interviews, Belvedere, in collaboration with the
client, develops an investor profile for the client, which is generally the basis for all
portfolio decisions.
In addition, Belvedere has a regular process of identifying quality instruments representing
the full range of asset types that may be included in a client’s portfolio.
Based on the client’s investor profile developed by Belvedere in collaboration with the
client, Belvedere selects instruments that are consistent with the profile and in furtherance
of the client’s goals.
Belvedere believes that diversification is the most important tool for risk
control.
Belvedere may use one or more of the following methods of analysis or investment
strategies when providing its recommendations:
• Fundamental Analysis - involves analyzing individual companies and their
industry groups, including a company's financial statements, details regarding
the company's product line, the experience and expertise of the company's
management, and the outlook for the company's industry. The resulting data is
used to measure the true value of the company's stock compared to the current
market value.
• Technical Analysis - involves studying past price patterns and trends in the
financial markets to predict the direction of both the overall market and specific
stocks.
• Long Term Purchases - securities purchased with the expectation that the
value of those securities will grow over a relatively long period of time, generally
greater than one year.
• Short Term Purchases - securities purchased with the expectation that they
will be sold within a relatively short period of time, generally less than one year,
to take advantage of the securities' short-term price fluctuations.
Belvedere may also formulate its recommendations based on its own analyses and
opinions or those provided by independent broker-dealers or financial institutions.
Belvedere’s investment advice may vary depending upon each end client's specific financial
situation, if information concerning an end client’s financial situation is provided to
Belvedere by its investment advisor client. If this information is provided, Belvedere will
determine investments and allocations based upon the end client’s predefined objectives,
risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and
other various suitability factors. Belvedere’s investment advisor clients and/or any end
clients restrictions and guidelines may affect the nature of the recommendations provided
by Belvedere.
Investing in securities involves risk of loss that clients should be prepared to bear.
Certain risks associated with the methods of analysis or investment strategies utilized by
Belvedere include the following:
• Fundamental Analysis – A risk associated with fundamental analysis is that
information obtained by Belvedere may be incorrect and the analysis may not
provide an accurate estimate of earnings, which may be the basis for a stock's
value. Further, if securities prices adjust rapidly to new information, utilizing
fundamental analysis may not result in favorable performance.
• Technical Analysis – A risk associated with technical analysis is that charts
utilized by Belvedere may not accurately predict future price movements.
Current prices of securities may reflect all information known about the security.
Day-to-day changes in market prices of securities may follow random patterns
and may not be predictable with any reliable degree of accuracy.
• Long Term Purchases – A risk of making an investment with a long term
horizon (i.e., greater than one year) is that drastic changes in the macro
environment may render the initial assumptions upon which the investment
decision was based obsolete. Such changes could include rapid and unexpected
increases in inflation, interest rates, currency exchange movements, rises in the
prices of key commodities that have a detrimental effect on the performance of
other securities, political and regulatory changes and wars and other such
turmoil.
• Short Term Purchases – Short term trading strategies tend to be opportunistic
and capitalize on an expected short term rise in the volatility of a certain
security. Increased volatility can generate outsized gains and losses.
Furthermore, frequent trading can negatively affect investment performance,
particularly through increased brokerage and other transactional costs and taxes.
Therefore, Belvedere will make short term trade recommendations sparingly
and only when it has a strong reason to believe in the success of the strategy.
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As a registered investment adviser, Belvedere is required to disclose all material facts
regarding any legal or disciplinary events that would be material to your evaluation of
Belvedere or the integrity of Belvedere’s management. Belvedere has no information to
report that is applicable to this Item.
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As a registered investment adviser, Belvedere is required to disclose all relationships it has
with affiliates and related persons that may be material to your evaluation of Belvedere
and the services it may provide you. Belvedere is affiliated with BLV Securities, LLC, a
FINRA registered broker-dealer, due to common ownership. Additional information on BLV
Securities, LLC can be found at brokercheck.finra.org.
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Belvedere has adopted a Code of Ethics for all supervised persons of the firm describing its
high standard of business conduct and its fiduciary duty to clients. The Code of Ethics
includes provisions relating to the confidentiality of client information, a prohibition on
insider trading, a prohibition on 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
Belvedere must acknowledge the terms of the Code of Ethics annually, or as amended.
Belvedere anticipates that, in appropriate circumstances, consistent with clients’
investment objectives, it will cause accounts over which Belvedere has management
authority to effect, and will recommend to investment advisory clients or prospective
clients, the purchase or sale of securities in which Belvedere, its affiliates and/or clients,
directly or indirectly, have a position of interest. Belvedere’s employees and persons
associated with Belvedere are required to follow Belvedere’s Code of Ethics. Subject to
satisfying this policy and applicable laws, officers, directors and employees of Belvedere
and its affiliates may trade for their own accounts in securities which are recommended to
and/or purchased for Belvedere’s clients.
The Code of Ethics is designed to assure that the personal securities transactions, activities
and interests of the employees of Belvedere 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, based upon a determination that
transactions in these would not materially interfere with the best interests of Belvedere’s
clients. In addition, the Code requires pre-clearance 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
in a security held by an employee. Employee trading is continually monitored under the
Code of Ethics, and to reasonably prevent conflicts of interest between Belvedere and its
clients.
Certain affiliated accounts may trade in the same securities with client accounts on an
aggregated basis when consistent with Belvedere's obligation of best execution. In such
circumstances, the affiliated and client accounts will share commission costs equally and
receive securities at a total average price. Belvedere 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.
Belvedere’s clients or prospective clients may request a copy of the firm's Code of Ethics by
contacting Mr. Julio Cesar F. Lage, CEO, at (786) 212-1032 and/or by email at
[email protected]. It is Belvedere’s policy that the firm will not affect any principal or agency cross securities
transactions for client accounts. Belvedere also will not cross trades between client
accounts. Principal transactions are generally defined as transactions where an adviser,
acting as principal for its own account or the account of an affiliated broker-dealer, buys
from or sells any security to any advisory client. A principal transaction may also be
deemed to have occurred if a security is crossed between an affiliated hedge fund and
another client account. An agency cross transaction is defined as a transaction where a
person acts as an investment adviser in relation to a transaction in which the investment
adviser, or any person controlled by or under common control with the investment adviser,
acts as broker for both the advisory client and for another person on the other side of the
transaction. Agency cross transactions may arise where an adviser is dually registered as a
broker-dealer or has an affiliated broker-dealer.
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In recommending broker-dealers, Belvedere will generally select brokers on the
basis of a competitive pricing structure, quality of execution, extended product
availability, and ease of use and access. Belvedere may utilize an affiliated broker-
dealer, BLV Securities, LLC to execute transactions. BLV Securities and/or
associated persons receive compensation for brokerage transactions effected in
these advisory accounts and for the purchase of investment and insurance
products recommended, which poses a conflict of interest. Clients may pay
commission higher than those obtainable from other brokers for the same
services rendered by BLV Securities or any other broker-dealer recommended to
the client by Belvedere. Clients can also elect to have their account opened and
trades executed at a broker-dealer of their choice, which may or may not cost
more to the client.
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Belvedere periodically reviews both discretionary and non-discretionary accounts. In this
regard, Belvedere reviews discretionary accounts not less often than quarterly, and
reviews non-discretionary accounts not less often than quarterly. In addition to its
periodic reviews, Belvedere may review accounts on an exceptional basis in response to
unusual market disruptions or other events, in connection with material additions to or
withdrawals from accounts, or in the case of other unusual developments that, in
Belvedere’s discretion, warrant additional review.
All reviews of client accounts are performed by Mr. Julio Cesar F. Lage, CEO of Belvedere.
Belvedere provides clients quarterly statements of account summarizing the assets in a
client’s account at the beginning and end of the period, the value of those assets, and
transactions occurring in the account during the period.
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As a registered investment adviser, Belvedere is required to inform you of certain paid
referral arrangements or other compensation arrangements it has in place. Belvedere has
no such arrangements in place, and thus it has no information to report relating to this
item.
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Clients should receive at least quarterly statements from the broker-dealer, bank or other
qualified custodian that holds and maintains the clients’ investment assets. Belvedere
urges you to carefully review such statements and compare such official custodial records
to the account statements that we may provide to you. Our statements may vary from
custodial statements based on accounting procedures, reporting dates, or valuation
methodologies of certain securities.
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Belvedere may be granted discretionary authority by the client at the outset of an
investment management relationship to select the identity and amount of securities to be
bought or sold. In all cases, however, 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, Belvedere observes the investment policies,
limitations and restrictions imposed by the clients to which it provides discretionary
investment management services.
Investment guidelines and restrictions must be provided to Belvedere in writing.
Accordingly, Belvedere requires that each discretionary client provide it written
investment objectives and criteria at the outset of any discretionary investment
management relationship, and that such investment objectives and criteria be reviewed not
less often than annually.
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As a matter of firm policy and practice, Belvedere does not have any authority to and does
not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving
and voting proxies for any and all securities maintained in client portfolios. Upon request,
Belvedere may provide advice to clients regarding the clients’ voting of proxies.
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As a registered investment adviser that offers discretionary investment management
services, Belvedere is required in this Item to disclose any financial condition that is
reasonably likely to impair Belvedere’s ability to meet its contractual commitment to
clients. In this regard, Belvedere is subject to no financial condition that impairs its ability
to meet contractual and fiduciary commitments to clients.
Belvedere has never been the subject of a bankruptcy proceeding.
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