A. Description of the Advisory Firm Aletheian Wealth Advisors LLC (hereinafter AWA) is a Limited Liability Company
organized in the State of Washington. The firm was formed in May 2019 and approved
July 2019, and the principal owners are Joshua Ray Betts and Randy T Siegel.
B. Types of Advisory Services
Investment Management – Multi-Family Office Services Client families’ best interests will be fully aligned with Aletheian Wealth Advisors as we
serve them under a single entity that provides wealth management and advisory services.
Working with Aletheian Wealth Advisors will enable clients to establish a governance
and management structure that addresses the complex issues surrounding a family's
wealth, resulting in more effective decision making and the potential for better outcomes.
Key Elements of Multi Family Office Services
·Centralize asset management activities with the potential to achieve higher returns or
lower risk for investment decisions via a formalized investment process
o Conduct an evaluation of the overall financial situation
o Determine investment objectives and family philosophy
o Establish risk profiles and time horizons
o Determine asset allocation strategies for public markets and private holdings
that balance risk/return goals with tax efficiency and wealth preservation
o Manage liquidity
o Coordinate other professional services such as philanthropy, tax and estate
planning.
o Facilitate the inter-generational transfer of wealth
AWA offers ongoing portfolio management services based on the Investment Policy
Statement that is created for each client's specific situation.
AWA will request 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 Policy Statement, which is given to
each client.
AWA seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of AWA’s economic,
investment or other financial interests. To meet its fiduciary obligations, AWA attempts
to avoid, among other things, investment or trading practices that systematically
advantage or disadvantage certain client portfolios, and accordingly, AWA’s policy is to
seek fair and equitable allocation of investment opportunities/transactions among its
clients to avoid favoring one client over another over time. It is AWA’s policy to allocate
investment opportunities and transactions it identifies as being appropriate and prudent
among its clients on a fair and equitable basis over time.
Family Advisory Services Financial Planning is an ongoing process that examines issues related to Family
Succession; Estate and Wealth Transfer; Cash Flow and Sustainability Analysis;
Philanthropic Intent; Minimization of Income and Estate Taxation; Life Management and
Budgeting; Insurance Sufficiency and Efficiency Reviews.
AWA offers Family Advisory Services to clients with illiquid and complex balance sheets
not under AWA management who require ongoing financial planning to address issues
related to Family Succession; Estate and Wealth Transfer; Cash Flow and Sustainability
Analysis; Philanthropic Intent; Minimization of Income and Estate Taxation; Life
Management and Budgeting; Insurance Sufficiency and Efficiency Reviews, as well as
ongoing coordination with attorneys and CPA’s.
Each client situation is distinct, with complicated balance sheets that may include real
estate, operating entities, liabilities and other unique assets. Complexity, asset structure,
and the scope of future goals and current deficiencies determines the time commitment.
Clients may terminate the agreement without penalty within five business days of
signing the Investment Advisory Contract. The ADV 2A and client contract has been
updated.
Fiduciary Services
Aletheian Fiduciary Services LLC provides previously engaged Investment Management
or Family Advisory clients of AWA a formalized Trust administration program aligned
with fiduciary standards, guidelines, and laws.
Personal trust accounts are typically established to accomplish certain goals such as:
o Family Succession and Wealth Transfer
o Income and Estate Tax Reduction
o Philanthropic Legacies
o Asset management in the event of incapacity
o Asset protection
Trust acceptance for existing RIA clients will be based upon a comprehensive review of
the purpose and objectives of the account. Trust investment policies are based on sound
fiduciary principles, including prudence, the preservation of capital, diversification, and
rate of return commensurate with the level of risk assumed.
Fees: Separate relationship fees will apply for administrative trustee services and
discretionary investment advisory services.
Services Limited to Specific Types of Investments AWA generally limits its investment advice to ETFs (including ETFs in the gold and
precious metal sectors), equities, fixed income securities, real estate funds (including
REITs), hedge funds, private equity funds, treasury inflation protected/inflation linked
bonds, venture capital funds and private placements, and mutual funds, although AWA
primarily recommends ETFs. AWA may use other securities as well to help diversify a
portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
AWA will tailor a program for each individual client specific to their individual needs
and requirements. AWA may use model allocations together with a specific set of
recommendations for each client based on their personal 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 AWA from
properly servicing the client account, or if the restrictions would require AWA to deviate
from its standard suite of services, AWA reserves the right to end the relationship.
D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees. AWA
does not participate in wrap fee programs.
E. Assets Under Management
AWA has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $17,286,876 $1,494,582 December 2019
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A. Fee Schedule
Investment Management – Multi-Family Office Services Fees
Total Assets Under Management Annual Fees $1,000,000 - $3,000,000 1.00%
$3,000,001 - $5,000,000 0.80%
$5,000,001 - $10,000,000 0.60%
$10,000,001 - $25,000,000 0.40%
$25,000,001 - $50,000,000 0.25%
$50,000,001 - and up 0.15%
The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period. This is a blended tier schedule.
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of AWA's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract
immediately upon written notice.
For capital markets portfolio assets under management, Fees are collected quarterly in
advance based upon the value of the account on the last day of the prior month. Fees are
calculated based upon the blended, tiered fee schedule.
For advisory services only clients, the agreed upon/negotiated annual fee is prorated into
quarterly installments.
Family Advisory Services Fees
Total Assets Annual Fees $1,000,000 - $3,000,000 0.46%
$3,000,001 - $5,000,000 0.46%
$5,000,001 - $10,000,000 0.30%
$10,000,001 - $25,000,000 0.20%
$25,000,001 - $50,000,000 0.125%
$50,000,001 - and up 0.075%
The advisory fee is calculated based on the client’s net worth.
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of AWA's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract
immediately upon written notice.
Fiduciary Services
Total Assets Under Management Annual Fees $1,000,000 - $3,000,000 .50%
$3,000,001 - $5,000,000 0.50%
$5,000,001 - $10,000,000 0.25%
$10,000,001 - $25,000,000 0.10%
$25,000,001 - $50,000,000 0.05%
$50,000,001 - and up 0.05%
The advisory fee is calculated using the value of the assets in Trust on the last business
day of the prior billing period.
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of AWA's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract
immediately upon written notice.
B. Payment of Fees Payment of Investment Management – Multi-Family Office Services Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly basis, or may be invoiced and billed
directly to the client on a quarterly basis. Clients may select the method in which they are
billed. Fees are paid in advance.
Payment of Family Advisory Services Fees Fiduciary Services fees are invoiced and billed directly to the client on a quarterly basis.
Fees are paid in advance. Fees are paid by check or bank transfer.
Payment of Fiduciary Services Fees Fiduciary Services fees are withdrawn directly from the trust's accounts with client's
written authorization on a quarterly basis, or may be invoiced and billed directly to the
grantor on a quarterly basis. Clients may select the method in which they are billed. Fees
are paid in advance.
C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by AWA. Please see Item 12 of this brochure
regarding broker-dealer/custodian.
D. Prepayment of Fees AWA collects fees in advance. Refunds for fees paid in advance but not yet earned will be
refunded on a prorated basis and returned within fourteen days to the client via check, or
return deposit back into the client’s account.
For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
the fees collected in advance minus the daily rate* times the number of days elapsed in
the billing period up to and including the day of termination. (*The daily rate is calculated
by dividing the annual asset-based fee rate by 365.)
Fixed fees that are collected in advance will be refunded based on the prorated amount of
work completed at the point of termination.
E. Outside Compensation For the Sale of Securities to Clients Neither AWA nor its supervised persons accept any compensation for the sale of
investment products, including asset-based sales charges or service fees from the sale of
mutual funds.
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AWA does not accept performance-based fees or other fees based on a share of capital gains on
or capital appreciation of the assets of a client.
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Loss A. Methods of Analysis and Investment Strategies
Methods of Analysis AWA’s methods of analysis include Fundamental analysis, Modern portfolio theory and
Quantitative analysis.
Fundamental analysis involves the analysis of financial statements, the general financial
health of companies, and/or the analysis of management or competitive advantages.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio
expected return for a given amount of portfolio risk, or equivalently minimize risk for a
given level of expected return, each by carefully choosing the proportions of various asset.
Quantitative analysis deals with measurable factors as distinguished from qualitative
considerations such as the character of management or the state of employee morale, such
as the value of assets, the cost of capital, historical projections of sales, and so on.
Investment Strategies
AWA uses long term trading, short term trading, margin transactions and options trading
(including covered options, uncovered options, or spreading strategies).
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
B. Material Risks Involved
Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is
that the market will fail to reach expectations of perceived value.
Modern portfolio theory assumes that investors are risk averse, meaning that given two
portfolios that offer the same expected return, investors will prefer the less risky one.
Thus, an investor will take on increased risk only if compensated by higher expected
returns. Conversely, an investor who wants higher expected returns must accept more
risk. The exact trade-off will be the same for all investors, but different investors will
evaluate the trade-off differently based on individual risk aversion characteristics. The
implication is that a rational investor will not invest in a portfolio if a second portfolio
exists with a more favorable risk-expected return profile – i.e., if for that level of risk an
alternative portfolio exists which has better expected returns.
Quantitative analysis Investment strategies using quantitative models may perform
differently than expected as a result of, among other things, the factors used in the models,
the weight placed on each factor, changes from the factors’ historical trends, and technical
issues in the construction and implementation of the models.
Investment Strategies AWA's use of margin transactions and options trading generally holds greater risk, and
clients should be aware that there is a material risk of loss using any of those strategies.
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 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.
Margin transactions use leverage that is borrowed from a brokerage firm as collateral.
When losses occur, the value of the margin account may fall below the brokerage firm’s
threshold thereby triggering a margin call. This may force the account holder to either
allocate more funds to the account or sell assets on a shorter time frame than desired.
Options transactions involve a contract to purchase a security at a given price, not
necessarily at market value, depending on the market. This strategy includes the risk that
an option may expire out of the money resulting in minimal or no value, as well as the
possibility of leveraged loss of trading capital due to the leveraged nature of stock options.
Selection of Other Advisers: Although AWA will seek to select only money managers
who will invest clients' assets with the highest level of integrity, AWA's selection process
cannot ensure that money managers will perform as desired and AWA will have no
control over the day-to-day operations of any of its selected money managers. AWA
would not necessarily be aware of certain activities at the underlying money manager
level, including without limitation a money manager's engaging in unreported risks,
investment “style drift” or even regulatory breaches or fraud.
Short term trading risks include liquidity, economic stability, and inflation, in addition to
the long term trading risks listed above. Frequent trading can affect investment
performance, particularly through increased brokerage and other transaction costs and
taxes.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
C. Risks of Specific Securities Utilized
AWA's use of margin transactions and options trading generally holds greater risk of
capital loss. Clients should be aware that there is a material risk of loss using any
investment strategy. The investment types listed below (leaving aside Treasury Inflation
Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other
government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may
lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity”
nature.
Equity investment generally refers to buying shares of stocks in return for receiving a
future payment of dividends and/or capital gains if the value of the stock increases. The
value of equity securities may fluctuate in response to specific situations for each
company, industry conditions and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount
of the payments can vary. This type of investment can include corporate and government
debt securities, leveraged loans, high yield, and investment grade debt and structured
products, such as mortgage and other asset-backed securities, although individual bonds
may be the best known type of fixed income security. In general, the fixed income market
is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond
prices usually fall, and vice versa. This effect is usually more pronounced for longer-term
securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury
inflation protected/inflation linked 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. Risks of investing in foreign fixed income securities also include the
general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100%
loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the
possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver,
or Palladium Bullion backed “electronic shares” not physical metal) specifically may be
negatively impacted by several unique factors, among them (1) large sales by the official
sector which own a significant portion of aggregate world holdings in gold and other
precious metals, (2) a significant increase in hedging activities by producers of gold or
other precious metals, (3) a significant change in the attitude of speculators and investors.
Real estate funds (including REITs) face several kinds of risk that are inherent in the real
estate sector, which historically has experienced significant fluctuations and cycles in
performance. Revenues and cash flows may be adversely affected by: changes in local real
estate market conditions due to changes in national or local economic conditions or
changes in local property market characteristics; competition from other properties
offering the same or similar services; changes in interest rates and in the state of the debt
and equity credit markets; the ongoing need for capital improvements; changes in real
estate tax rates and other operating expenses; adverse changes in governmental rules and
fiscal policies; adverse changes in zoning laws; the impact of present or future
environmental legislation and compliance with environmental laws.
Hedge funds often engage in leveraging and other speculative investment practices that
may increase the risk of loss; can be highly illiquid; are not required to provide periodic
pricing or valuation information to investors; May involve complex tax structures and
delays in distributing important tax information; are not subject to the same regulatory
requirements as mutual funds; and often charge high fees. In addition, hedge funds may
invest in risky securities and engage in risky strategies.
Private equity funds carry certain risks. Capital calls will be made on short notice, and
the failure to meet capital calls can result in significant adverse consequences, including
but not limited to a total loss of investment.
Private placements carry a substantial risk as they are subject to less regulation than are
publicly offered securities, the market to resell these assets under applicable securities
laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial
discount to the underlying value or result in the entire loss of the value of such assets.
Venture capital funds invest in start-up companies at an early stage of development in
the interest of generating a return through an eventual realization event; the risk is high
as a result of the uncertainty involved at that stage of development.
Options are contracts to purchase a security at a given price, risking that an option may
expire out of the money resulting in minimal or no value. An uncovered option is a type
of options contract that is not backed by an offsetting position that would help mitigate
risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss
for an uncovered call option is limitless. Spread option positions entail buying and selling
multiple options on the same underlying security, but with different strike prices or
expiration dates, which helps limit the risk of other option trading strategies. Option
transactions also involve risks including but not limited to economic risk, market risk,
sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk
and interest rate risk.
Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
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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 AWA nor its representatives are registered as, or have pending applications to
become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither AWA nor its representatives are registered as or have pending applications to
become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests
Neither AWA nor its representatives have any material relationships to this advisory
business that would present a possible conflict of interest.
D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections
AWA may direct clients to the third-party investment advisers. There is no revenue
shared between AWA and third-party investment managers. AWA will always act in the
best interests of the client, including when determining which third-party investment
adviser to recommend to clients. AWA will verify that all recommended advisers are
properly licensed, notice filed, or exempt in the states where AWA is recommending the
adviser to clients.
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Transactions and Personal Trading A. Code of Ethics
AWA has a written Code of Ethics that covers the following areas: Prohibited Purchases
and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions,
Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality,
Service on a Board of Directors, Compliance Procedures, Compliance with Laws and
Regulations, Procedures and Reporting, Certification of Compliance, Reporting
Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual
Review, and Sanctions. AWA's Code of Ethics is available free upon request to any client
or prospective client.
B. Recommendations Involving Material Financial Interests AWA does not recommend that clients buy or sell any security in which AWA or a related
person has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of AWA may buy or sell securities for themselves that
they also recommend to clients. This may provide an opportunity for representatives of
AWA to buy or sell the same securities before or after recommending the same securities
to clients resulting in representatives profiting off the recommendations they provide to
clients. Such transactions may create a conflict of interest. AWA will always document
any transactions that could be construed as conflicts of interest and will never engage in
trading that operates to the client’s disadvantage when similar securities are being bought
or sold.
D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of AWA may buy or sell securities for themselves at or
around the same time as clients. This may provide an opportunity for representatives of
AWA to buy or sell securities before or after recommending securities to clients resulting
in representatives profiting off the recommendations they provide to clients. Such
transactions may create a conflict of interest; however, AWA will never engage in trading
that operates to the client’s disadvantage if representatives of AWA buy or sell securities
at or around the same time as clients.
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A. Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be recommended based on AWA’s duty to seek “best
execution,” which is the obligation to seek execution of securities transactions for a client
on the most favorable terms for the client under the circumstances. Clients will not
necessarily pay the lowest commission or commission equivalent, and AWA may also
consider the market expertise and research access provided by the broker-
dealer/custodian, including but not limited to access to written research, oral
communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in AWA's research efforts. AWA will never charge
a premium or commission on transactions, beyond the actual cost imposed by the broker-
dealer/custodian.
AWA will require clients to use Fidelity Brokerage Services LLC.
1. Research and Other Soft-Dollar Benefits
While AWA has no formal soft dollars program in which soft dollars are used to pay
for third party services, AWA may receive research, products, or other services from
custodians and broker-dealers in connection with client securities transactions (“soft
dollar benefits”). AWA may enter into soft-dollar arrangements consistent with (and
not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange
Act of 1934, as amended. There can be no assurance that any particular client will
benefit from soft dollar research, whether or not the client’s transactions paid for it,
and AWA does not seek to allocate benefits to client accounts proportionate to any
soft dollar credits generated by the accounts. AWA benefits by not having to produce
or pay for the research, products or services, and AWA will have an incentive to
recommend a broker-dealer based on receiving research or services. Clients should be
aware that AWA’s acceptance of soft dollar benefits may result in higher commissions
charged to the client.
2. Brokerage for Client Referrals AWA 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 AWA will require clients to use a specific broker-dealer to execute transactions. Not
all advisers require clients to use a particular broker-dealer.
B. Aggregating (Block) Trading for Multiple Client Accounts
If AWA buys or sells the same securities on behalf of more than one client, then it may
(but would be under no obligation to) aggregate or bunch such securities in a single
transaction for multiple clients in order to seek more favorable prices, lower brokerage
commissions, or more efficient execution. In such case, AWA would place an aggregate
order with the broker on behalf of all such clients in order to ensure fairness for all clients;
provided, however, that trades would be reviewed periodically to ensure that accounts
are not systematically disadvantaged by this policy. AWA would determine the
appropriate number of shares and select the appropriate brokers consistent with its duty
to seek best execution, except for those accounts with specific brokerage direction (if any).
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A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for AWA's advisory services provided on an ongoing basis are
reviewed at least Annually by Randy T Siegel, Chief Operating Officer & Chief
Compliance Officer, with regard to clients’ respective investment policies and risk
tolerance levels. All accounts at AWA are assigned to this reviewer.
All financial planning accounts are reviewed upon financial plan creation and plan
delivery by Randy T Siegel, Chief Operating Officer & Chief Compliance Officer.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical
move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
Each client of AWA's advisory services provided on an ongoing basis will receive a
quarterly report detailing the client’s account, including assets held, asset value, and
calculation of fees. This written report will come from the custodian. AWA will also
provide at least quarterly a separate written statement to the client.
Each financial planning client will receive the financial plan upon completion.
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A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes)
Other than soft dollar benefits as described in Item 12 above, AWA does not receive any
economic benefit, directly or indirectly from any third party for advice rendered to AWA
clients.
B. Compensation to Non – Advisory Personnel for Client Referrals
AWA does not directly or indirectly compensate any person who is not advisory
personnel for client referrals.
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When advisory fees are deducted directly from client accounts at client's custodian, AWA will be
deemed to have limited custody of client's assets and must have written authorization from the
client to do so. Clients will receive all account statements and billing invoices that are required in
each jurisdiction, and they should carefully review those statements for accuracy.
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AWA provides discretionary investment advisory services to clients. The advisory contract
established with each client sets forth the discretionary authority for trading. Where investment
discretion has been granted, AWA generally manages the client’s account and makes investment
decisions without consultation with the client as to when the securities are to be bought or sold
for the account, the total amount of the securities to be bought/sold, what securities to buy or
sell, or the price per share. In some instances, AWA’s discretionary authority in making these
determinations may be limited by conditions imposed by a client (in investment guidelines or
objectives, or client instructions otherwise provided to AWA.
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AWA 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
AWA neither requires nor solicits prepayment of more than $500 in fees per client, six
months or more in advance, and therefore is not required to include a balance sheet with
this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients
Neither AWA nor its management has any financial condition that is likely to reasonably
impair AWA’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years AWA has not been the subject of a bankruptcy petition in the last ten years.
Item 19: Requirements For State Registered Advisers A. Principal Executive Officers and Management Persons; Their Formal Education and Business Background The education and business background of AWA’s current management
persons/executive officers, Joshua Ray Betts and Randy T Siegel, can be found on the
individual’s Form ADV Part 2B brochure supplement.
B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any)
Other business activities for each relevant individual can be found on the individual’s
Form ADV Part 2B brochure supplement.
C. How Performance-based Fees are Calculated and Degree of Risk to Clients AWA does not accept performance-based fees or other fees based on a share of capital
gains on or capital appreciation of the assets of a client.
D. Material Disciplinary Disclosures for Management Persons of this Firm
No management person at AWA or AWA has been found liable in an arbitration claim or
been found liable in a civil, self-regulatory organization, or administrative proceeding that
is material to the client’s evaluation of the firm or its management.
E. Material Relationships That Management Persons Have With Issuers of Securities (If Any) Neither AWA, nor its management persons, has any relationship or arrangement with
issuers of securities.
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