Firm Description
Summit Wealth Group, LLC hereinafter (Summit, Adviser, Firm) was founded in February 2010 by
Theodore J. Spinardi II (Senior Managing Director). In January 2013, Summit became a registered
investment advisor. Summit is an SEC registered investment adviser as of October 2021. In January
2023, the Firm assets were assigned to SPINARDI REVOCABLE TR DTD 08/02/01.
Summit offers investment advisory services to individuals, high net worth individuals, trusts, estates,
and businesses. The Advisor does not act as a custodian of client assets and the client always
maintains asset control.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the
client on an as-needed basis. Any conflicts of interest arising out of the Adviser activity, or its
associated persons are disclosed in this brochure.
Principal Owner(s):
Theodore J. Spinardi II 100% owner as assigned to the “Spinardi Revocable Trust” Dated 8/2/2023
Types of Advisory Services
The Adviser provides investment supervisory services, also known as asset management services;
manages investment advisory accounts not involving investment supervisory services; furnishes
investment advice through consultations; issues periodicals about securities by subscription; issues
special reports about securities; and issues charts, graphs, formulas, or other devices which clients
may use to evaluate securities. On more than an occasional basis, the Adviser furnishes advice to
clients on matters not involving securities, such as financial planning matters, taxation issues, and trust
services that often include estate planning.
As of January 10, 2023, the Adviser manages approximately $120,798,694 in discretionary assets and
approximately $2,489,972 in non-discretionary assets for approximately 222 clients.
Tailored Relationships
The goals and objectives for each client are documented in our client relationship management
system. Investment policy statements are created that reflect the stated goals and objectives. Clients
may impose restrictions on investing in certain securities or types of securities.
Assignment of Investment Management Agreements
Agreements may be assigned in accordance with the Summit Wealth Group, LLC Investment Advisory
Agreement signed by the client.
Types of Agreements
The following agreements define the typical client relationships.
Investment Management Agreement
As part of the investment management service, all aspects of the client’s financial affairs are reviewed
and realistic and measurable goals are set and objectives to reach those goals are defined. As goals
and objectives change over time, suggestions are made and implemented on an ongoing basis. The
Adviser periodically reviews a client’s financial situation and portfolio through regular contact with the
client which often includes an annual meeting with the client. The Adviser makes use of portfolio
rebalancing software to maintain client allocations according to the Investment Policy Statement in
effect.
The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior
to the start of the relationship. The agreement sets forth the services to be provided, the fees for the
service and the agreement may be terminated by either party in writing at any time.
Summit provides customized investment advisory solutions for its clients. This is achieved through
continuous personal client contact and interaction while providing discretionary investment
management and consulting services. The Adviser works closely with each client to identify their
investment goals and objectives as well as risk tolerance and financial situation in order to create an
investment strategy. Summit will then construct a portfolio, consisting of mutual funds and exchange-
traded funds (ETFs). The Advisor may also utilize individual stocks and bonds to meet the needs of its
clients. For certain clients, the Advisor may also recommend interests in limited partnerships or other
types of securities. Summit will select, recommend and/or retain mutual funds on a fund by fund basis.
Due to specific custodial and/or mutual fund company constraints, material tax consideration, and/or
systematic investment plans, Summit will select, recommend and/or retain a mutual fund share class
that does not have trading costs, but do have higher internal expense ratios than institutional share
classes. Summit will seek to select the lowest cost share class available that is in the best interest of
each client and will ensure the selection aligns with the client’s financial objectives and stated
investment guidelines.
Summit’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-
allocate positions that have been held less than one year to meet the objectives of the client or due to
market conditions. The Adviser 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 the acceptance by the Adviser.
Summit evaluates and selects securities for inclusion in client portfolios only after applying their
internal due diligence process. Summit may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. The Adviser 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. Summit 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 client, generating cash to meet client needs, or any risk deemed unacceptable for the
client’s risk tolerance.
At no time will Summit accept or maintain custody of a client’s funds or securities, except for
authorized deduction of the Advisor’s fees as outline in Item 15 – Custody. All client assets will be
managed within their designated account[s] at the Custodian, pursuant to the client investment
advisory agreement.
Financial Planning Agreement
The financial plan may include, but is not limited to: a net worth statement; a cash flow statement; a
review of investment accounts, including reviewing asset allocation and providing repositioning
recommendations; strategic tax planning; a review of retirement accounts and plans including
recommendations; a review of insurance policies and recommendations for changes, if necessary; one
or more retirement scenarios; estate planning review and recommendations; and education planning
with funding recommendations.
Financial planning may be the only service provided to the client and does not require that the client
use or purchase the investment advisory services offered by the Adviser. There is an inherent conflict
of interest for the Adviser whenever a financial plan recommends the use of professional investment
management services or other financial products or services. The Adviser or its associated persons
may receive compensation for financial planning and the provision of investment management
services and other products and services. However, the client is under no obligation to accept any of
the recommendations of the Adviser or use the services of the Adviser in particular.
Summit will typically provide a variety of financial planning services to individuals and families,
pursuant to a written financial planning agreement. Services are offered in several areas of a client’s
financial situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan based on the client’s
financial goals
and objectives. This planning may encompass one or more areas of need, including,
but not limited to investment planning, retirement planning, personal savings, education savings,
insurance needs and other areas of a client’s financial situation.
A financial plan developed for the client will usually include general recommendations for a course of
activity or specific actions 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. Summit may also refer clients to an accountant,
attorney or another specialist, as appropriate for their unique situation. For certain financial planning
engagements, the Adviser will provide a written summary of client’s financial situation, observations,
and recommendations. For consulting or ad-hoc engagements, the Adviser may not provide a written
summary. Financial plans are typically completed within six months of contract date, assuming all
information and documents requested are provided promptly.
Financial planning recommendations pose a conflict between the interests of the Adviser and the
interests of the client. For example, the Adviser has an incentive to recommend that clients engage the
Adviser for investment management services or to increase the level of investment assets with the
Adviser, as it would increase the amount of Advisory fees paid to the Adviser. Clients are not obligated
to implement any recommendations made by the Adviser or maintain an ongoing relationship with the
Adviser. If the client elects to act on any of the recommendations made by the Adviser, the client is
under no obligation to implement the transaction through the Adviser.
Hourly Engagements
The Adviser provides hourly services for clients who need advice on a limited scope of work. The
hourly rate for limited scope engagements shall not exceed $300 per hour. The number of hours
required to complete he agreed upon work will vary depending upon the complexity of the client's
financial situation (including the time required for preparation and research) and the specific areas of
concern specified by the client. The areas of concern for which the client engages Summit’s Financial
Planning Services shall be specified in writing.
Asset Management
Investments may also include equities (stocks), warrants, corporate debt securities, commercial paper,
certificates of deposit, municipal securities, investment company securities (variable life insurance,
variable annuities, and mutual funds shares), U. S. government securities, options contracts, futures
contracts, and interests in partnerships.
Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds, usually
through brokers or fund companies. Fund companies charge each fund shareholder an investment
management fee that is disclosed in the fund prospectus. Brokerages may charge a transaction fee for
the purchase of some funds. Stocks and bonds are purchased or sold through a brokerage account
when appropriate. The brokerage firm sometimes charges a fee for stock and bond trades. The
Adviser does not receive any compensation, in any form, from brokerage firms or fund companies.
Initial public offerings (IPOs) are not available through the Adviser.
Prior to engaging Summit to provide investment advisory services, each client is required to enter into
one or more agreements with the Adviser that define the terms, conditions, authority and
responsibilities of the Adviser and the client. These services may include:
• Establishing an Investment Strategy – Summit, will develop a strategy that seeks to achieve the
Client’s goals and objectives.
• Asset Allocation – Summit will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Summit will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
• Investment Management and Supervision – Summit will provide investment management an
ongoing oversight of the Client’s investment portfolio.
IRA Rollover Considerations and Recommendations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account (IRA)
that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset-based fee as set forth in the agreement you executed with
our firm. This practice presents a conflict of interest because persons providing investment advice on
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based
compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm.
We comply with the Department of Labor (DOL) Prohibited Transaction Exemption 2020-02 (PTE
2020-02) where applicable. Our firm is providing the following additional acknowledgment:
When the Adviser provides investment advice to individuals regarding a retirement plan account or
individual retirement account, the firm is deemed a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are
laws governing retirement accounts. The way the Adviser makes money creates potential conflicts with
a client’s interest. Therefore, the Adviser, operates under a special rule which requires the firm to act in
a client’s best interest and not put the Adviser’s interest ahead of the client. Under this special rule’s
provisions, the Adviser must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put the Adviser’s financial interests ahead of a client when making recommendations
(give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure advice given is in the client’s best interest.
• Charge no more than is reasonable for services; and
• Provide basic information about conflicts of interest.
The Adviser benefits financially from the rollover of a client’s assets from a retirement account to an
account managed by the firm. This is a primary conflict of interest because when the Adviser provides
investment advice, the assets increase the firm assets under management and, in turn, advisory fees.
To meet the fiduciary responsibility the Adviser only recommends a rollover when it is deemed in the
client’s best interest.
Wrap Fee Programs
The Adviser does not provide investment management services to a wrap program.
Termination of Agreements
A Client may terminate any of the aforementioned agreements at any time by notifying the Adviser in
writing. Clients shall be charged pro-rata for services provided through to the date of termination. If the
client made an advance payment, the Adviser will refund any unearned portion of the advance
payment.
The Adviser may terminate any of the aforementioned agreements at any time by notifying the client in
writing. If the client made an advance payment, the Adviser will refund any unearned portion of the
advance payment.
The Adviser reserves the right to terminate any financial planning engagement where a client has
willfully concealed or has refused to provide pertinent information about financial situations when
necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Any unused
portion of fees collected in advance will be refunded.