A. Firm Information
Consilio Wealth Advisors, LLC (“CWA” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the
State of Delaware. CWA was founded in March 2021 and is owned by Union 6, LLC and operated by Nathaniel M.
Donohue (Partner and Chief Compliance Officer) and Christopher M. Kaminski (Partner). This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided by CWA.
B. Advisory Services Offered
CWA offers investment advisory services to individuals and high net worth individuals (each referred to as a
“Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. CWA's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Wealth Management Services
CWA provides wealth management services for its Clients. These services generally include a broad range of
comprehensive financial planning in connection with discretionary investment management of Client portfolios.
These services are described below.
Investment Management Services CWA provides customized investment management solutions for its Clients. This
is achieved through continuous personal Client contact and interaction while providing discretionary investment
management services. CWA works closely with each Client to identify their investment goals and objectives as well
as risk tolerance and financial situation in order to create a portfolio strategy. CWA will then construct an
investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”),
individual stocks, bonds, alternative investments, or options contracts to achieve the Client’s investment goals. The
Advisor may retain a Client’s legacy investments based on portfolio fit and/or tax considerations.
CWA’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. CWA
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
CWA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. CWA may recommend, on occasion, redistributing investment allocations to diversify the portfolio. CWA
may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend
employing cash positions as a possible hedge against market movement. CWA may recommend selling positions
for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure
to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change
in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the
Client’s risk tolerance.
At no time will CWA accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Use of Independent Managers – CWA may recommend to Clients that all or a portion of their investment
portfolio be implemented by utilizing one or more unaffiliated money managers or investment platforms
(collectively “Independent Managers”). Independent Managers may be sourced directly or accessed through an
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investment management platform. The Client will be required to enter into a separate agreement with the
Independent Manager[s].
CWA serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s]
will assume discretionary authority for the day-to-day investment management of those assets placed in their
control. CWA will assist and advise the Client in establishing investment objectives for their account[s], the
selection of the Independent Manager[s], and defining any restrictions on the account[s]. CWA will continue to
provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties.
The Independent Manager[s] will implement the selected investment strategies based on their investment
mandates.
The Client may be able to impose reasonable investment restrictions on these accounts, subject to the
acceptance of these third parties. CWA does not receive any compensation from these Independent Managers
or Investment Platforms, other than its investment advisory fee. Please see Item 5 – Fees and Compensation.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
Financial Planning Services- CWA will provide financial planning and consulting services to Clients, pursuant to a
written financial planning agreement. CWA will identify the Client’s current financial situation by reviewing income,
spending, savings, assets, and liabilities, including investment portfolio, tax exposure, insurance coverage, and
estate plan. CWA will work with the Client to establish financial goals and strategy to achieve these goals.
Generally, financial planning services involve preparing a formal financial plan or rendering a specific financial
consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one
or more areas of need, including but not limited to, retirement analysis, employee stock-based compensation, tax
planning, investment planning, asset allocation, employee benefits, risk management planning, real estate
planning, debt strategies, education planning, and estate planning.
A financial plan developed for, or financial consultation rendered to the Client will usually include recommendations
for a course of activity to be taken by the Client. For example, recommendations may be made that the Client start
or revise their investment programs, commence or alter retirement savings, establish education savings and/or
charitable giving programs.
CWA may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial
situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide
a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming
all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
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C. Client Account Management
Prior to engaging CWA to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – CWA, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
• Portfolio Construction – CWA will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
• Investment Management and Supervision – CWA will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
CWA does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by CWA.
E. Assets Under Management
As of December 31, 2022, CWA manages $265,348,988 in Client Assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.