Financial Advocates Wealth Management, LLC (“FAWM,” “us,” “we,” “our”) is registered with the Securities and Exchange Commission (SEC) as a n investment adviser. FAWM is a limited liability company formed in the State of Washington in April 2019. While FAWM is a new adviser, it is related through common control to other investment advisers, Financial Advocates Investment Management, LLC (“FAIM”) and Financial Advocates Advisory Services, LLC (“FAAS”). FAIM has been in business since 2010 and FAAS since 2008. FAWM is 100% owned by FA Holdings, Inc. The group of affiliated companies is referred to collectively as “Financial Advocates.” The Financial Advocates business model is based on a decentralized network of Investment Adviser Representatives (“IARs” or “Consultants”) with offices located in numerous states and cities. Although all of FAWM’s IARs are registered with, and subject to oversight and supervision by, FAWM, they operate their businesses independently and some offices work under a separate business name or “DBA”. IARs associated with FAWM may provide IAR services to clients under a DBA name that is owned and registered by the IAR or the group of IARs which the DBA name represents. As such, marketing materials provided to clients and potential clients may include the DBA name and may include a logo associated with the DBA name. FAWM continues to review and approve marketing materials related to the IAR or IA firm services offered and provided to clients. FAWM supervises IARs in the performance of their IAR duties whether the services are performed under the IAR’s name, the DBA name, or the FAWM name. If properly disclosed as an outside business activity of the IAR, FAWM allows IARs to provide other products and services through their DBA so long as they are unrelated to FAWM’s IA business. These outside business activities are not associated with or supervised by FAWM. Because all of our IARs operate their businesses independently from one another, they have significant flexibility in providing tailored individualized investment advice to clients. FAWM’s home office in Olympia, WA, assists the IARs with marketing, back-office functions and compliance responsibilities. A list of all of the FAWM approved DBA names can be found on our Schedule D, Section 1.B. Other Business Names of our Form ADV Part 1 which is available on the SEC’s Investment Advisor Public Disclosure website at www.adviserinfo.sec.gov. FAWM as a whole offers the following types of services: investment management, hourly consulting, financial planning and consultations, and pension consulting services. Individual IARs offer investment advice to clients utilizing some or all of these services. The following paragraphs describe our services and fees. Asset Management As part of our asset management services, we create a portfolio for each client, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and/or other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we have ongoing discretionary authority. We review the overall portfolio at least quarterly and, if necessary, rebalance based upon the client’s individual needs, stated goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. In designing an investment portfolio for a client, we may work with a third party money manager, also an investment adviser, who is independent of FAWM. When we work with third party money managers, we’re utilizing that money manager’s experience and strategies, helping to develop a suitable portfolio for each client. We conduct initial and ongoing due diligence on any money manager utilized. We also have discretionary authority to add and remove money managers within your investment portfolio. We make sure other advisers are properly registered before we begin working with them. Wrap Fee Programs: “Wrap fee programs” are advisory programs under which a specified fee or fees, not based directly upon transactions in a client’s account, is charged for both investment advisory services and the execution of client transactions. We make wrap programs available to our clients. Depending on, among other things, the size of the account, changes in its value over time, the ability to negotiate fees or commissions, and the number of transactions, the amount of the compensation we receive through wrap programs may be more or less than what we would receive if the client participated in different fee programs or paid separately for investment advice, brokerage and other services. Similarly, services may cost clients more or less than if they paid for the services separately. Where we earn additional compensation due to the client’s participation in a wrap fee program, we have a financial incentive to recommend these programs over other programs where our compensation is lower. This creates a conflict of interest, which we mitigate by fully disclosing our compensation and the choices available to clients, and by making recommendations consistent with our fiduciary duties to clients. There is not a material difference in how we manage wrap fee accounts and how we manage other accounts. Double Leaf Portfolio Solutions Double Leaf Portfolio Solutions is a wrap fee program sponsored by our affiliate, Financial Advocates Investment Management (“FAIM”). Clients interested in this program will receive a separate disclosure Brochure Appendix describing the program in more detail. Double Leaf Portfolio Solutions are financial models created for use by our IARs for their clients. FAIM has partnered with Horizon Investments, LLC, an unaffiliated investment adviser, to create models that are designed with the client’s investment lifecycle in mind. Horizon Investments is responsible for the portfolio construction and selection of the underlying investments with input and approval from FAIM. Horizon does not have knowledge of, or interaction, with the end-clients utilizing these models. Double Leaf Growth portfolios are designed for clients who are the wealth accumulation stage of their investment lifecycle. There are five globally diverse options, each are balanced with active and passive management to achieve growth in a cost effective manner. These options seek to achieve flexibility while also being focused on the client’s long term objectives. The five models include Double Leaf Aggressive Growth, Double Leaf Growth, Double Leaf Moderate, Double Leaf Conservative and Double Leaf Ultra Conservative.
Double Leaf Prepare portfolios are designed to help clients with the preservation of wealth stage of their investment lifecycle. The Double Leaf Prepare portfolios singularly prioritize risk management above market returns. The models are Double Leaf Aggressive with Risk Management, Double Leaf Growth with Risk Management, Double Leaf Moderate Growth with Risk Management, Double Leaf Conservative with Risk Management and Double Leaf Ultra Conservative with Risk Management.
Double Leaf Retire portfolios are designed for clients who are at the distribution of wealth stage of their investment lifecycle. The Double Leaf Retire portfolios seek to increase the likelihood that the client doesn’t outlive their assets and are designed specifically with longevity in mind. The models are Double Leaf 6% Spend, Double Leaf 5% Spend and Double Leaf 4% Spend.
Other Wrap Programs We expect to make other wrap fee programs available through unaffiliated sponsors. If we recommend one of these programs, clients will receive the sponsor’s disclosure documents prior to our investing client assets in the program. Third Party Asset Management Programs FAWM makes available advisory services and programs of third party asset managers. Under these programs, FAWM’s IARs provide ongoing investment advice to clients that is tailored to the individual needs of the client, assisting the client in determining suitability of the program, setting investment objectives and processing the paperwork with the third party asset manager. The IAR may also assist the client in selecting the model portfolio designed by the asset manager. When selecting third-party managers, FAWM retains discretionary authority to hire new managers or to terminate existing managers, but does not have discretionary authority

to select individual investments. Consulting Services, Targeted Financial Planning Some FAWM IARs may offer consulting services, including financial planning in specific areas. These targeted financial planning services are based on an analysis of the client’s current financial circumstances, goals and objectives with respect to a limited focus area. Typically, targeted financial planning and consulting services involve a process of information gathering by the IAR, analysis of the client’s needs or goals, typically followed by a meeting to discuss FAWM’s recommendations and to establish next steps for the client. Targeted financial planning does not usually result in a written plan or report. Financial planning services or hourly consulting services may include analysis or discussion in one or more of the following areas: Charitable Planning Education Planning Cost Segregation Study Mortgage/Debt Analysis Insurance Analysis Lines of Credit Evaluation Business and Personal Financial Planning Clients enter into a Consulting Agreement for financial planning and other consulting services. These services vary depending on each client’s needs, but may include any of the above-listed services. FAWM is not qualified to offer legal or accounting advice and we refer clients to an accountant, attorney or other specialist as necessary for non-advisory related services. Comprehensive Financial Planning Generally, comprehensive financial planning services are based on an analysis of the client’s current financial circumstances, goals and objectives. This involves a process of information gathering by the IAR, then preparation of a financial plan or other written report. Specifically, comprehensive financial planning will address one or more of the six key areas of financial planning: Financial Position Protection Planning Investment Planning Corporate and Personal Income Tax Planning Retirement Planning Estate Planning.
Our written financial plans provided to clients or financial planning consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. For comprehensive financial planning engagements, we provide our clients with a written summary of their financial situation, observations and recommendations. Financial plans or consultations are typically completed within six (6) months of a client’s signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. Clients are free to implement investment recommendations through brokers unaffiliated with FAWM or its IARs. Hourly Consulting Services General hourly consulting services are provided for a variety of purposes including, but not limited to: Annual Update to Financial Plan Asset Allocation Recommendations Portfolio Management Recommendations Individual Issue Consulting Third party review (2nd opinion) For hourly consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our financial planning services. Implementation of any recommendations or next steps to be taken will be at the discretion of the client. Investment Fiduciary & Retirement Plan Consulting We provide consulting and advisory services for employer-sponsored retirement plans that are designed to assist plan sponsors of employee benefit plans (“Sponsor”). These services are offered to the Sponsors on a one-time or ongoing basis. Generally, such pension consulting services consist of assisting the Sponsor in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the Sponsor dictate, areas of advising could include, but are not limited to, investment options, plan structure and participant education. Where we offer plan participants the option of using our Participant Advisory Services for discretionary investment management services, we’ll enter into a separate agreement with that participant, describing our services and fees for that service. We also ask that the participant provide information that will help us understand their investment objectives. In providing this service, we are deemed to be a fiduciary and investment manager as defined in ERISA Section 3(38). All pension consulting services shall be in compliance with the applicable state law(s) regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge our fiduciary role within the meaning of Section 3(21) of ERISA, but only with respect to the provision of services described in the Services section of the Investment Fiduciary & Retirement Plan Consulting Agreement (“RPAC”). When providing any ERISA fiduciary services, we will solely be making recommendations to the Sponsor and the Sponsor retains full discretionary authority and/or control over the assets. When entering into an RPAC agreement, the Plan Sponsor may select from a number of different services described below. With the exception of Participant Advisory Services, FAWM will be acting in a non-discretionary capacity and will solely be making recommendations to the Plan Sponsor. FAWM will not perform recordkeeping or brokerage services to the Plan. Neither FAWM nor the IAR will assume the duties of a trustee or a Plan Administrator, as defined in ERISA Sec. 3(16). Services offered under an RPAC agreement are described below. Investment Fiduciary Services: Plan-Level Recommendations to establish or revise the Plan’s Investment Policy Statement (“IPS”), Recommendations to select and monitor the Designated Investment Alternatives (“DIAs”), Recommendations to select and monitor Qualified Default Investment Alternatives (“QDIAs) Recommendation to select and monitor other investment managers Investment Fiduciary Services: Participant Level IAR will meet with Plan Participants periodically, or upon reasonable request, to collect information necessary to provide individual participants with investment advice and related services regarding the investment options available under the Plan.
IAR will manage the Participant’s account on a discretionary basis.
Administrative Support Retirement Plan Consulting Services oAssist Plan Sponsor in reviewing objectives and options through the Plan oReview of Plan committee structure and administrative policies & procedures oRecommend participant education and communications policies under ERISA 404(c) oAssist with development/maintenance of fiduciary audit file and document retention policies oDeliver fiduciary training and/or education periodically or upon reasonable request.
oCoordinate and reconcile participant disclosures under 404(a)(5) oDevelop requirements for responding to participant requests Oversight of Relationship with Service Provider oAssist with process to select, monitor and replace service providers oAssist with review of Covered Service Providers (CSP) disclosures under ERISA 408(b)(2) and fee benchmarking oProvide reports and/or information designed to assist with monitoring CSPs oReview ERISA Spending Accounts or Plan Expense Recapture Accounts oAssist with preparation and review of Request for Proposals (RFPs) and/or Request for Information (RFIs) oCoordinate and assist with CSP replacement and conversion Investments oPeriodic review of investment policy in context of Plan objectives oAssist Plan committee with monitoring investment performance oProvide analysis of investment managers and model portfolios oReview and recommend Designated Investment Managers and/or third-party advice providers as necessary oEducate Plan committee members, as needed, regarding replacement of DIA(s) and/or QDIA(s) Participant Services oFacilitate group enrollment meetings oCoordinate employee education regarding Plan investments and fees oAssist Plan participants in understanding Plan benefits, retirement readiness and impact of increasing deferrals.
Assets Under Management As of December 31, 2022, we had no assets under management.