Wealthspire Advisors LLC (“Wealthspire Advisors” or “Wealthspire”) is an SEC-registered investment
adviser providing wealth management, investment advisory and financial consulting through its
state-registered Investment Advisor Representatives (“Advisor Representatives”) to individuals,
businesses, non-profit organizations and foundations. Our role is to listen, inform and advise. We take
a well-rounded, relationship-driven approach to helping our clients develop customized solutions
that address a full range of financial issues. Our investment strategy is focused on each client’s long-
term goals and risk tolerance.
Sontag Advisory LLC (“Sontag”) was founded in 1995 by Howard Sontag and has been wholly owned
by NFP Corp. (previously known as National Financial Partners, Corp.) (“NFP”) since 2015, NFP was
acquired by Aon plc on April 25, 2024.
On May 1, 2019, Sontag acquired Bronfman E.L. Rothschild, L.P., an SEC-registered investment advisor
(“Bronfman Rothschild”). Bronfman Rothschild was formed in May 2013 as the successor by
conversion from Baker Tilly Investment Advisors, LLC, an investment adviser providing services since
August 1997. Following the acquisition, Bronfman Rothschild became a subsidiary of Sontag.
Beginning in October 2019, Bronfman Rothschild was renamed Wealthspire Advisors, LP. Wealthspire
Advisors, L.P. and Sontag, both separate registered investment advisers and subsidiary companies of
NFP, began doing business under the common brand and trade name of Wealthspire Advisors.
Wealthspire Advisors, L.P. merged with and into Sontag as of December 31, 2020, and the surviving
entity was renamed Wealthspire Advisors LLC.
On November 13, 2020, Wealthspire acquired Strategic Wealth Management Group, LLC
(“StratWealth”), a SEC-registered investment advisor and Maryland limited liability company formed
on February 14, 2001. StratWealth became registered with the Securities and Exchange Commission
on May 17, 2002. Following the acquisition, StratWealth became a subsidiary of Wealthspire Advisors
LLC and began doing business as Wealthspire Advisors on January 11, 2021. StratWealth merged with
and into Wealthspire as of September 30, 2021.
On November 12, 2021, Wealthspire acquired Private Capital Group, LLC (“PCG”), a SEC-registered
investment advisor and Connecticut limited liability company that has been providing investment
advisory services as an SEC-registered investment adviser since 2003. Following the acquisition, PCG
became a subsidiary of Wealthspire Advisors LLC and began doing business as Wealthspire Advisors
on February 14, 2022. PCG merged with and into Wealthspire as of September 30, 2022.
On December 31, 2021, Wealthspire acquired Private Ocean, LLC (“Private Ocean”), a SEC-registered
investment advisor and California limited liability company that has been providing investment
advisory services as an SEC-registered investment adviser since 1983 (as Salient Financial Corp.).
Following the acquisition, Private Ocean became a subsidiary of Wealthspire Advisors LLC and began
doing business as Wealthspire Advisors on May 23, 2022. Private Ocean intends to maintain a separate
client brochure until such time as the operations of Wealthspire Advisors LLC and Private Ocean are
sufficiently integrated to merit a combined client brochure.
On January 24, 2022, Wealthspire announced that it will integrate Lenox Wealth Advisors, LLC
(“LWA”), a SEC-registered investment advisor, New York limited liability company, and subsidiary of
NFP that has been providing investment advisory services as an SEC-registered investment adviser
since 2011. Following the announcement, LWA began doing business as Wealthspire Advisors on
January 24, 2022. LWA merged with and into Wealthspire on June 30, 2022.
On December 30, 2022, Wealthspire acquired Sage Financial Advisors, LLC (“Sage”), a SEC-registered
investment advisor and Nevada limited liability company that commenced operations in January
1996. Following the acquisition, Sage became a subsidiary of Wealthspire Advisors LLC and began
doing business as Wealthspire Advisors on April 24, 2023. Sage merged with and into Wealthspire as
of August 31, 2023.
On April 3, 2023, Wealthspire acquired Heron Financial Group, LLC (“Heron”), a SEC-registered
investment advisor and New York limited liability company that has been providing investment
advisory services as an SEC-registered investment adviser since 2008. Following the acquisition,
Heron became a subsidiary of Wealthspire Advisors LLC and began doing business as Wealthspire
Advisors on July 31, 2023. Heron merged with and into Wealthspire as of November 1, 2023.
On July 17, 2023, Wealthspire acquired ACG Advisory Services, LLC dba ACG Wealth Management
(“ACG”), a SEC-registered investment advisor and Delaware limited liability company that has been
providing investment advisory services as an SEC-registered investment adviser since 1991. Following
the acquisition, ACG became a subsidiary of Wealthspire Advisors LLC and began doing business as
Wealthspire Advisors on October 30, 2023. ACG intends to maintain a separate client brochure until
such time as the operations of Wealthspire Advisors LLC and ACG are sufficiently integrated to merit
a combined client brochure.
On November 1, 2023, Wealthspire acquired GM Advisory Group, LLC (“GMAG”), a SEC-registered
investment advisor and Delaware limited liability company that has been providing investment
advisory services as an SEC-registered investment adviser since 2004. Following the acquisition,
GMAG became a subsidiary of Wealthspire Advisors LLC. GMAG intends to maintain a separate client
brochure until such time as the operations of Wealthspire Advisors LLC and GMAG are sufficiently
integrated to merit a combined client brochure.
NFP also owns other registered investment advisers, broker-dealers, insurance agencies and other
product and service providers. Wealthspire Advisors is under no obligation to sell any products or
recommend any services to our clients as a result of NFP’s ownership.
Mike LaMena is the firm’s Chief Executive Officer; Eric Sontag is the firm’s President and Chief
Operating Officer; Hoyt Stastney is the firm’s General Counsel; Michael Moriarty is the firm’s Chief
Investment Officer; Michael Del Priore is the firm’s Chief Compliance Officer; and Brian Powers is the
firm’s Chief Financial Officer.
Assets Under Management
As of December 31, 2023, Wealthspire Advisors has the following regulatory assets under
management:
Clients Assets
Discretionary 6799 $ 18,529,313,855
Non-discretionary 357 $ 343,065,458
Total 7156 $ 18,872,379,313
Services to Individual Clients
Wealthspire Advisors offers a suite of wealth management services, which may include one or more
of the following, depending on each client’s specific engagement:
Investment Advisory
Evaluation of current portfolio
Assessment of investment objectives and financial goals
Asset allocation planning
Separate Account Manager research and selection
Investment program implementation and rebalancing
Portfolio monitoring and risk management
Performance measurement
Financial Planning and Consulting
Portfolio monitoring and advice regarding assets not managed by Wealthspire Advisors
Insurance planning
Estate and wealth transfer planning
Retirement planning
Education planning
Philanthropic and charitable gift planning
Comprehensive Reporting
Unique reporting service complementing standard statements provided by the account
custodian
Customized periodic statements aggregating all invested (and sometimes fixed or illiquid)
assets - even those not managed by Wealthspire Advisors
Portfolio performance, asset class returns, annual income and investment flows are
consolidated on one easy-to-understand page
Tax Reporting
Tax reporting service to assist our clients’ tax professionals
Firm provides annual “tax packages” to clients and/or their accountants
Tax packages include reports and summaries detailing: cost basis, fees, gain/loss, interest,
dividends, distributions and charitable contributions, among other information
Asset Allocation and Account Customization
Advisory services begin with determining each client's financial circumstances and investment
objectives and are followed by continuous investment management services to the client's
investment account (“Account(s)”) based on the client's needs and objectives. Wealthspire Advisors
tailors its services to the individual investment needs of its clients by determining each client’s
investible assets, investment experience, specific goals, objectives, risk tolerance, time horizon,
investment restrictions and other considerations (collectively, “Investment Information”) that might
impact the client’s investment needs. Investment Information is generally gathered using a
questionnaire followed by an interview process. To comply with applicable laws and internal
procedures when opening new Accounts, Wealthspire Advisors may request proof of identification
from a prospective client and may utilize third party agencies to verify the client's identity.
Based on this determination of a client’s Investment Information, Wealthspire Advisors develops an
investment policy for the Account and generally implements an investment program grounded on
one of its various portfolio guidelines. As agreed with each client individually, this program may take
into account the allocation of the client’s assets not placed under Wealthspire Advisors’ management
(e.g. cash holdings, 401k balances, assets placed with other investment advisors/managers, limited
partnerships, business interests, individual securities holdings, employee stock options, real estate,
etc.). Generally, Wealthspire Advisors’ intention is to manage investments to provide the client with
an overall asset allocation (including assets outside Wealthspire Advisors’ investment purview, if
agreed) matching as closely as possible the client’s investment profile.
Wealthspire Advisors has a fiduciary duty to provide services consistent with the client’s best interest.
As part of its investment advisory services, Wealthspire Advisors will review client portfolios on an
ongoing basis to determine if any changes are necessary based upon various factors, including, but
not limited to, investment performance, mutual fund manager tenure, style drift, and/or a change in
the client’s Investment Information. Based upon these factors, there may be extended periods of time
when Wealthspire Advisors determines that changes to a client’s portfolio are neither necessary nor
prudent. Of course, as indicated below, there can be no assurance that investment decisions made
by Wealthspire Advisors will be profitable or equal any specific performance level(s).
Investment Selection - Separate Account Managers
Wealthspire Advisors may recommend the allocation of a portion of a client’s investment assets
among one or more unaffiliated independent investment managers (“Separate Account Manager”)
in accordance with the client’s designated investment objectives. In such situations, the Separate
Account Manager shall have day-to-day responsibility for the active discretionary management of the
allocated assets. Wealthspire Advisors shall continue to render Investment Advisory services to the
client relative to the ongoing monitoring and review of account performance, asset allocation and
client investment objectives. Factors which Wealthspire Advisors shall consider in recommending
Separate Account Managers include the client’s designated investment objectives, management
style, performance, reputation, financial strength, reporting, pricing, and research. Wealthspire
Advisors maintains a disciplined research and due diligence process to identify Separate Account
Managers suitable for client investment and also maintains ongoing annual due diligence and review
over the recommended firms. Before a client establishes an account with a Separate Account
Manager, the client shall also receive the Separate Account Manager’s written disclosure statement
specifying its fees and services.
Wealthspire Advisors maintains sub-advisory arrangements with most of the Separate Account
Managers it recommends for client portfolios. This means that Wealthspire Advisors has authority to
hire and/or fire the Separate Account Manager on behalf of its discretionary Clients and also results
in some operational efficiencies regarding the opening and closing of accounts as well as
communicating transaction details. Separate Account Managers charge their own advisory fees,
which are typically deducted directly from the Client’s custodial account at customary billing
intervals, separate from Wealthspire Advisor’s fee, and do not separately pay a referral fee to
Wealthspire Advisors. The assets invested with a recommended Separate Account Manager are
included with the client’s other assets managed directly by Wealthspire Advisors for the purpose of
calculating and billing in accordance with the client’s fee schedule.
Individual Managed Accounts include the following service and fee categories:
Wealthspire Advisors Wealth Management, recommended for accounts with assets under
management over $2,000,000, includes semi-annual or quarterly meetings with a service team which
may consist of two or three Wealthspire Advisors employees. Wealthspire Advisors utilizes an
"institutional" asset allocation model based on investing principals used by the largest endowments
and foundations in the world. By utilizing the methodology used by institutional money managers,
Wealthspire Advisors aims to achieve consistent returns with less volatility than traditional portfolios.
Once a client's allocation is in place, Wealthspire Advisors employs a rigorous due diligence process
to select the appropriate mutual funds, exchange-traded funds (“ETFs”), private investment funds,
and/or investment managers.
Wealthspire Advisors Wealth Solutions, recommended for accounts with assets under management
between $500,000 and $2,000,000, includes annual or semi-annual meetings with an Advisor
Representative. Investments consist of mainly mutual funds and ETFs.
Wealthspire Pathways, which utilizes Charles Schwab and Co., Inc.’s Institutional Intelligent Portfolios®
Platform, recommended for accounts with assets under management between $100,000 and
$500,000, includes annual meetings with an Advisor Representative. Investments consist of ETFs and
a cash allocation.
Wealthspire Advisors Institutional, recommended for institutions with assets under management
exceeding $5,000,000, includes quarterly or semi-annual meetings with a service team which
consists of three Wealthspire Advisors employees. It is managed in line with the Wealthspire Advisors
Wealth Management program discussed above.
Wealthspire Advisors has established account services relationships with, and typically recommends
the custodial services of, Charles Schwab & Co., Fidelity Brokerage Services (“Fidelity”), and Pershing
Advisor Solutions (“Pershing”). These firms maintain custody of Account assets and process
transactions ordered by Advisor Representatives and Separate Account Managers. Reports of
Account transactions and positions are prepared and sent to each client no less than quarterly by
each custodian.
Wealthspire Advisors is responsible for the management of investments within client Accounts and
adjusts client portfolios by buying and selling investments from time-to-time based on current
investment objectives and client needs. The firm may also manage Accounts on a non-discretionary
basis from time-to-time, and, when it does so, Advisor Representatives obtain permission for Account
transactions from the client prior to placing the trades. Accounts are continuously monitored, and
investments are made based on changes to economic and market conditions or to realign the
portfolio to be consistent with the client's current allocation plan, investment objectives, time horizon,
and risk tolerance.
Clients may place reasonable restrictions or constraints on the way their Accounts are managed,
where practicable, and retain the right to modify Account restrictions at any time by providing
written notice of such changes to Wealthspire Advisors.
Advisor Representatives will periodically request updates to a client's Investment Information to
assist in managing and supervising the client's Account and to make any necessary changes to the
investment decisions and recommendations being made for the client's Account. However, clients
remain ultimately responsible for informing Wealthspire Advisors of material changes to Investment
Information as it occurs. Wealthspire Advisors generally does not accept Accounts maintained at a
custodian with which the firm does not have an established services relationship.
Clients may contact their Advisor Representative any time they wish to confer about any aspect of
the Account or services being, or to be, provided.
Wealthspire has entered into an agreement with Flourish Digital Assets LLC (“Flourish Digital Assets”)
to offer certain eligible clients the opportunity to invest in cryptocurrency basis through Flourish
Crypto accounts offered on the Flourish platform. A Flourish Crypto account is a cryptocurrency
investment account custodied by Paxos Trust Company, LLC (“Paxos”) through which investors can
trade cryptocurrencies and maintain custody of cryptocurrencies and U.S. dollars. Clients that invest
through a Flourish Crypto account will manage their own accounts and execute agreements with
Flourish Digital Assets and Paxos.
Investment Consulting Services
Wealthspire Advisors assists other organizations with asset allocation strategies, investment
manager research and selection, performance reporting, marketing support and other services in
exchange for a flat fee. The representatives of the organization retain the authority to approve or
reject all asset allocation strategies, investment manager recommendations or other materials that
result from Wealthspire’s services. In addition, each representative of the organization retains sole
responsibility for determining their needs, and in choosing which strategies or managers may be
appropriate for them.
Unaffiliated Private Investment Funds
In certain cases, Wealthspire Advisors may recommend investment in certain unaffiliated private
investment funds. Wealthspire Advisors’ role relative to the private investment funds shall be limited
to its initial and ongoing due diligence and investment monitoring services. If a client decides to
become a private fund investor, the amount of assets invested in the fund(s) shall be included as part
of “assets under management” for purposes of Wealthspire Advisors calculating its investment
advisory fee. Wealthspire Advisors’ clients are under absolutely no obligation to consider or make an
investment in a private investment fund(s).
All clients that determine to become investors in a fund, will generally receive an Offering
Memorandum prepared by the fund sponsor (discussing the fund's investment objectives, risk
factors, conflicts, etc.) and shall generally be required to enter into a Subscription Agreement
acknowledging the terms and conditions of the fund and/or venture and the corresponding risk
factors, including loss of principal and liquidity constraints. Wealthspire Advisors will only
recommend private funds to those clients for whom it reasonably believes such an investment to be
suitable, given the client’s total portfolio, risk parameters and liquidity needs. Wealthspire Advisors
shall not exercise any discretion as to whether or not a client shall invest in any private fund. Rather,
the ultimate investment decision shall remain with the client.
Private investment funds generally involve various risk factors, including, but not limited to, potential
for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of
which is set forth in each fund’s offering documents, which will be provided to each client for review
and consideration. Unlike liquid investments that a client may maintain, private investment funds do
not provide daily liquidity or pricing.
Because of the above factors associated with a private fund investment, the Firm must make a
determination as to whether a specific private fund is appropriate for the client. In so doing, the Firm
shall consider the following factors:
• The type of offering-including risks, time horizon, and liquidity issues;
• The client's investment objective(s)-realizing that for certain clients, a private fund of any kind
may not be suitable;
• The client's current portfolio allocation;
• The client’s available cash to commit to the private fund;
• The private fund's investment minimum per investor; and
• The client's current allocation to private investment funds.
Please Note: Valuation. In the event that Wealthspire Advisors references private investment funds
owned by the client on any supplemental account reports prepared by Wealthspire Advisors, the
value(s) for all private investment funds owned by the client shall reflect the most recent valuation
provided by the fund sponsor. However, if subsequent to purchase, the fund has not provided an
updated valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the
fund provides an updated valuation, then the statement will reflect that updated value. The most
recently available value will continue to be reflected on this report until the fund provides a further
updated value. Please Also Note: As a result of the valuation process, the report may reflect an initial
purchase price or an updated value subsequent to purchase, and the current value(s) of an investor’s
fund holding could be significantly more or less than the value reflected on the report. The client’s
advisory fee shall be based upon the value reflected on the report.
Wealthspire Pathways
Wealthspire Pathways, which utilizes Schwab Institutional Intelligent Portfolios®, is an automated
investment program through which clients are invested in a range of investment strategies we have
constructed and manage, each consisting of a portfolio of ETFs and a cash allocation. The client may
instruct us to exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage
account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional
Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a
software provider to independent investment advisors and an affiliate of CS&Co., to operate
Wealthspire Pathways. We are independent of and not owned by, affiliated with, or sponsored or
supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s
investment advisor and primary point of contact with respect to Wealthspire Pathways. We are solely
responsible, and Schwab is not responsible, for determining the appropriateness of Wealthspire
Pathways for the client, choosing a suitable investment strategy and portfolio for the client’s
investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted
with SPT to provide us with the Platform, which consists of technology and related trading and
account management services for Wealthspire Pathways. The Platform enables us to make
Wealthspire Pathways available to clients online and includes a system that automates certain key
parts of our investment process (the “System”). The System includes an online questionnaire that
helps determine the client’s investment objectives and risk tolerance and select an appropriate
investment strategy and portfolio. Clients should note that we will recommend a portfolio via the
System in response to the client’s answers to the online questionnaire. The client may then indicate
an interest in a portfolio that is one level less or more conservative or aggressive than the
recommended portfolio, but we then make the final decision and select a portfolio based on all the
information we have about the client. The System also includes an automated investment engine
through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing
and tax-loss harvesting (if the client is eligible and elects).
We charge clients a fee for our services as described below under Item 5 Fees and Compensation.
Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other
fees to CS&Co. as part of Wealthspire Pathways. Schwab does receive other revenues in connection
with Wealthspire Pathways.
We do not pay SPT fees for the Platform so long as we maintain $100 million in client assets in
accounts at CS&Co. that are not enrolled in Wealthspire Pathways. If we do not meet this condition,
then we pay SPT an annual licensing fee of 0.10% (10 basis points) on the value of our clients’ assets in
Wealthspire Pathways. This fee arrangement gives us an incentive to recommend or require that our
clients with accounts not enrolled in Wealthspire Pathways be maintained with CS&Co.
Trustee Services
Certain of Wealthspire Advisors’ employees (or employees of affiliates) may, upon client request, serve
as
trustee for various types of trusts set up by clients. The employees offer these services at their sole
discretion on a limited, case-by-case basis.
The firm’s trustee services include the execution of trust duties, as well as the administrative functions
necessary to support the fiduciary responsibilities of the trustee. This service is separate and apart
from the investment advisory services and is subject to a separate fee. Trustee services include (as
applicable):
Maintaining calendar for trust distributions and payments, including: mandatory distributions
of income and/or principal to beneficiaries, tax payments, tax estimates, trustee and
administrative fee payments
Ensuring timely distribution of assets or monies required under the terms of the trust
Communication with beneficiaries to ensure a smooth administrative process
Making tax payments and estimated payments as required
Distributing K-1s to beneficiaries
Coordinating with other trusted advisors to create comprehensive tax and financial planning
Maintaining debt schedules for promissory notes as required
Monitoring the Trust’s investment portfolio to ensure proper implementation given the time
horizon and risk profile of the trust
Reviewing tax returns prepared by trust’s accountant
Acting as Agent for Trust or General Partner
Power of Attorney (“POA”) Services
Check writing authority on accounts
Trust Administration and Reporting Services
Through its relationship with its custodians, the firm is able to provide trust administration and
reporting services to the trusts where one of its employees serves as trustee or those trusts it
manages for trustees not affiliated with the firm. Trust administration and reporting services are an
important tool to eliminate manual processes for trust accounting, and include:
Detailed trust accounting, including automated separation of principal and income
Calculation and facilitation of distributions to beneficiaries and third parties
Recordkeeping of illiquid assets owned by the trust
Review and facilitate filing of trust tax returns prepared by the trust’s accountant, tax
payments, and delivery of K-1s to trust beneficiaries, as directed by the trustee
Furnish trust reports, accountings, and information to beneficiaries as directed by trustee or
if otherwise required
Client Retirement Plan Assets
Wealthspire Advisors also provides investment advisory services relative to the client’s 401(k) plan
assets upon request. In such event, Wealthspire Advisors shall allocate (or recommend that the client
allocate) the retirement account assets among the investment options available on the 401(k)
platform. Please Note: Wealthspire Advisors’ services shall be limited to the allocation of the client’s
assets among the investment alternatives available through the plan. Wealthspire Advisors will not
receive any communications from the plan sponsor or custodian, and it shall remain the client’s
exclusive obligation to notify Wealthspire Advisors of any changes in investment alternatives,
restrictions or other relevant or material information pertaining to the retirement account.
IRA Rollovers
In appropriate circumstances, Wealthspire Advisors may recommend that a client roll over an
account held in a former employer's retirement plan to Individual Retirement Account ("IRA") for
Wealthspire Advisors to manage. When providing investment advice to clients regarding retirement
plan accounts or IRAs, Wealthspire Advisors is 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 Wealthspire Advisors makes money creates some conflicts
with the client’s interests, so Wealthspire Advisors operates under a special rule that requires it to act
in the client’s best interest and not put the firm’s interests ahead of the clients. If the client elects to
rollover assets into an IRA account subject to Wealthspire Advisors’ management, the account will
be subject to Wealthspire Advisors’ advisory fee per the client’s Investment Advisory Agreement.
Conflict of Interest: A financial advisor’s recommendation to roll over retirement plan assets
into an IRA creates some conflict of interest because such a recommendation can create an
incentive to recommend the rollover for the purpose of generating additional compensation
rather than solely based on the client’s needs. When Wealthspire Advisors recommends a
rollover IRA, the recommendation is given in the client’s best interest and with the client’s
interests ahead of the firm’s, and the client is never under any obligation, contractually or
otherwise, to complete a rollover to have the rollover IRA assets managed by Wealthspire
Advisors.
Many employers permit former employees to keep their retirement assets in the company plan. Also,
some retirement plans may permit current employees to move assets out of the company plan
before retiring or leaving the company. In determining whether to complete an IRA rollover, and to
the extent the following options are available, Wealthspire Advisors clients should consider their costs
and benefits.
An employee will typically have four options:
Leave the assets in the employer/former employer's plan;
Transfer the funds to a new employer’s retirement plan;
Cash out and take a taxable distribution from the plan; or
Roll the funds into an IRA account.
Each of these options has advantages and disadvantages, and Wealthspire Advisors recommends
that a client communicate with their CPA/tax attorney to consider them before making a change.
Each client should consider the following relevant issues together with their Wealthspire Advisors
advisor, as well as their tax and/or legal professional, before initiating a retirement plan rollover:
Determine whether the investment options in the employer's retirement plan address client’s
needs or whether other types of investments are needed.
Employer retirement plans generally have a more limited investment menu than IRAs.
Employer retirement plans may have unique investment options not available to the public
such as employer securities, or previously closed funds.
The employer plan may have lower fees than Wealthspire Advisors’ fees.
If interested in investing only in mutual funds, client should understand the cost structure of
the share classes available in employer's retirement plan compared to those available in an
IRA.
Client should understand the various products and services that may be available through a
Rollover IRA and the potential costs of those products and services.
Wealthspire Advisors’ recommended strategy may entail higher risk than the option(s)
provided in client’s plan.
Client’s current plan may also offer financial advice.
Keeping assets titled in a 401k or retirement account may potentially delay a required
minimum distribution.
For clients concerned about protecting assets from creditors, an existing 401k plan may offer
more liability protection than a rollover IRA. Such legal protection varies by state.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets
have been generally protected from creditors in bankruptcies. However, there may be some
exceptions to these general rules so an attorney should be consulted if concerned about
protecting retirement plan assets from creditors.
Loans may be available from the employer plan (although generally not to ex-employees); no
loan available from an IRA.
IRA assets can be accessed any time; however, distributions are subject to ordinary income
tax and may also be subject to a 10% early distribution penalty unless qualifying for an
exception such as disability, higher education expenses or the purchase of a home.
If you own company stock in your 401k plan, you may be able to liquidate those shares at a
lower capital gains tax rate.
Client’s existing retirement plan may allow Wealthspire Advisors to be hired as the investment
manager and to keep the assets titled in the plan name. It is important that clients understand the
differences between these types of accounts and to evaluate whether a rollover is best under the
circumstances.
Insurance
While Wealthspire Advisors routinely provides insurance planning as part of a client’s financial plan,
Wealthspire Advisors does not sell insurance. Wealthspire Advisors may provide Client with
recommendations of licensed insurance agents (some of whom may be affiliated with parent
company NFP) for the purchase of various types of insurance. Wealthspire Advisors does not accept
or receive referral compensation from any of the firms to whom it refers clients.
Although Wealthspire is affiliated with Lenox Advisors, a licensed insurance agency, Wealthspire is
not an insurance agency and does not sell fixed or general account life insurance products or
annuities.
Wrap Fee Program
Wealthspire Advisors does not offer a wrap fee program. A "wrap fee program" is a program under
which Investment Advisory and brokerage execution services are provided for an annualized
"wrapped" fee that is not based on the number of transactions in a client's account. From time to
time, Wealthspire Advisors may recommend investment with a Separate Account Manager which
has its own wrap fee program.
No Legal Services
Certain of Wealthspire Advisors’ employees may be licensed to practice law. However, no such
persons provide legal services to any of Wealthspire Advisors’ clients, and no corresponding attorney-
client relationship is established. This foregoing is provided for purposes of full disclosure and to
emphasize that the fact that certain of Wealthspire Advisors’ employees may be licensed to practice
law is not material to Wealthspire Advisors’ investment advisory business or services.
Services Offered to ERISA Plans
Wealthspire Advisors provides advisory services to retirement plans subject to the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”), including participant-directed
defined contribution plans, such as 401(k) plans, defined contribution plans that are not participant-
directed and defined benefit plans (“ERISA Plan Clients”). Each ERISA Plan Client is required to enter
into an investment advisory or investment management agreement with Wealthspire Advisors
describing the services that Wealthspire Advisors will perform for the ERISA plan and its participants
(the “ERISA Plan Services Agreement”). Wealthspire Advisors provides both ERISA fiduciary services
and non-fiduciary services to ERISA Plan Clients.
Please Note: As of March 2019, Wealthspire Advisors intends to introduce future ERISA plan clients to
NFP Retirement, Inc. (“NFP-R”), an affiliated company specializing in working with plan sponsors.
Wealthspire Advisors believes that, in most cases, NFP-R will be better equipped to service our
current and future 401k plan sponsor clients.
Conflict of Interest: NFP-R and Wealthspire Advisors are affiliated firms, as both are owned by NFP
Corp. Therefore, Wealthspire Advisors has a conflict of interest where it recommends the services of
an affiliated firm. Wealthspire Advisors has addressed this conflict of interest as outlined more fully
below in “Item 14--Client Referrals and Other Compensation.”
Fiduciary Services for ERISA Plan Clients
Wealthspire Advisors provides fiduciary services either as a discretionary investment manager or a
non- discretionary investment adviser.
Discretionary Investment Management Services
Wealthspire Advisors provides investment management services to ERISA Plan Clients on a
discretionary basis as an investment manager under ERISA Section 3(38) and in that capacity,
Wealthspire Advisors’ investment decisions are made in its sole discretion without the ERISA Plan
Client’s prior approval. Each ERISA Plan Client who engages Wealthspire Advisors to perform
investment management services is required to enter into an investment management agreement.
Wealthspire Advisors’ investment management services include developing and implementing an
investment policy statement, selecting a broad range of investment options consistent with ERISA
Section 404(c), making decisions about the selection, retention, removal and addition of investment
options and if the ERISA Client has determined that the Plan should have a qualified default
investment alternative (a “QDIA”) for participants who fail to make an investment election, selecting
the investment that will serve as a QDIA.
Non-Discretionary Investment Advisory Service
Wealthspire Advisors also provides investment advisory services on a nondiscretionary basis and in
that capacity, the ERISA Plan Client retains, and exercises, final decision-making authority and
responsibility for the implementation (or rejection) of Wealthspire Advisors’ recommendations or
advice. Each ERISA Plan Client who engages Wealthspire Advisors to perform nondiscretionary
investment advisory services is required to enter into an investment advisory agreement. Wealthspire
Advisors’ nondiscretionary investment advisory services include assisting the ERISA Plan Client in
developing and implementing an investment policy statement and assisting the ERISA Plan Client in
making decisions about the selection, retention, removal and addition of investments.
Non-Fiduciary Services for ERISA Plan Clients
Wealthspire Advisors’ non-fiduciary services provided to ERISA Plan Clients include assisting in group
enrollment meetings, educating plan participants about general investment principles and the
investment alternatives under the plan and educating the ERISA Plan Client as to its fiduciary
responsibilities. Wealthspire Advisors’ non-fiduciary services also include assisting the ERISA Plan
Client in monitoring, selecting and supervising service vendors and performing benchmarking
studies and fee analysis.
For a more detailed description of Wealthspire Advisors’ fiduciary and non-fiduciary services, the
ERISA Plan Client should refer to the ERISA Plan Services Agreement.
ERISA / IRC Fiduciary Acknowledgment. If the client is: (i) a retirement plan (“Plan”) organized under
ERISA; (ii) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section
4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets in his or
her Plan account or to take a distribution; (iii) the beneficial owner of an IRA acting on behalf of the
IRA; or (iv) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section
4975(e)(1)(A) of the Internal Revenue Code: then Wealthspire Advisors represents that it and its
representatives are fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any
investment advice provided by the Registrant or its representatives or with respect to any investment
recommendations regarding an ERISA Plan or participant or beneficiary account.
Financial Planning
Wealthspire Advisors also offers comprehensive and limited financial planning and consulting
services depending on each client's needs.
Our comprehensive evaluation of a client's current and anticipated future financial state is
accomplished by using currently known variables to assess future cash flows, asset values, and
withdrawal plans. Through the financial planning process, all questions, information, and analysis are
considered as they impact and are impacted by the entire financial and life situation of the client.
Clients purchasing this service receive a written summary which provides the client with a detailed
financial outline designed to assist the client in achieving his or her financial goals and objectives.
Our limited financial planning services are based on specific recommendations outlined by our
clients. Our clients will receive an appropriate evaluation based on the parameters agreed to in the
services agreement.
We seek to develop comprehensive or limited financial plans that include any or all of the subject
areas as defined by the Certified Financial Planning Board:
Financial Statement Preparation and Analysis: We review family records, budgets, assets,
liabilities, and cash flow to create a clear picture of the current financial status of our clients
in order to determine opportunities and priorities. Specific topics that may be addressed
include, but are not limited to: (i) personal financial planning; (ii) asset liability ownership; (iii)
debt management/structuring; (iv) home purchase analysis; (v) analysis/comparison of debt
pay-off options; (vi) cash flow; (vii) calculation of liquidity and cash reserve needs; (viii) budget
monitoring; and (ix) inflation projection of living expenses.
Investment Planning: We analyze investment alternatives and their effect on the client's
portfolio. We communicate our economic and investment outlook via a quarterly Investment
Philosophy that is available to all advisory clients. Specific topics that may be addressed
include: (i) asset allocation; (ii) retirement income strategies; (iii) education goal analysis; (iv)
potential tax ramifications of various investment strategies; (v) computation of the length of
time, money, or other asset will last given a specified rate of withdrawal and expected rate of
return; (vi) calculation of a lump sum amount of money needed to be invested to receive a
specified level of income per year for a certain number of years; and (vii) portfolio
optimization/rebalancing.
Insurance Planning, Risk Management, and Employee Benefits: We analyze the impact
of the client's death, disability, or incapacity on his or her financial strategy. We evaluate
existing policies and determine ways to cost-effectively meet family needs that can be
addressed through life, disability, and long-term care insurance. Specific topics that may be
addressed include: (i) survivor income needs; (ii) capital needs; (iii) estate liquidity needs; and
(iv) buy-sell analysis.
Income Tax Planning: We analyze the client's income tax history and spending patterns to
plan for the current and future years then model the potential impact of various investment
and financial strategies on the client's net worth and liquidity. Specific topics that may be
addressed include: (i) income tax projections including general and specific techniques for
reducing tax liability; (ii) tax deduction and tax credit maximization opportunities; (iii)
alternative minimum tax considerations; (iv) business structure alternatives including
compensation methodology; (v) intergenerational asset transfers; (vi) capital gain/loss
harvesting; (vii) Roth conversion analysis; and (viii) net investment income considerations.
Retirement Planning: We analyze current strategies and investment plans to help the client
achieve his or her retirement goals. For individuals who are already retired, we analyze the
impact of changing income and expense amounts and timing, gifting, and risk tolerance with
the objective of maintaining financial independence. Specific topics that may be addressed
include: (i) analysis of retirement needs; (ii) early retirement analysis; (iii) pension
maximization; (iv) social security optimization; and (v) rollovers/transfers.
Estate Planning: We assist the client in assessing and developing long-term strategies,
including (as appropriate), trusts, wills, powers of attorney, asset protection plans, and estate
tax exposure. We carefully evaluate the impact of various gifting and wealth transfer
strategies. Specific topics that may be addressed include: (i) estate/death tax estimate
including general and specific techniques for reducing taxes, probate, and transfer costs; (ii)
estate liquidity and survivor income analysis; (iii) gifting strategies; (iv) estate planning for
minor children or special needs dependents; and (v) charitable planning strategies.
We gather required information through in-depth personal interviews. Information gathered
includes the client's current financial status, tax circumstances, future goals, investment objectives,
and attitudes towards risk. We carefully review documents supplied by the client and prepare a
written report.
The financial plan is presented to the client within six months of the contract date, provided that all
information needed to prepare the financial plan has been promptly provided.
Additionally, Wealthspire Advisors provides advice on non-security matters. Generally, this is in
connection with the rendering of estate planning, fixed insurance, and/or fixed annuity.
Should a client choose to implement the recommendations contained in the financial plan,
Wealthspire Advisors suggests the client work closely with his/her attorney, accountant, insurance
agent, and/or stockbroker. Implementation of the recommendations contained in the financial plan
is entirely at the client's discretion. To the extent that Wealthspire Advisors or an affiliate offers legal,
accounting, insurance, or brokerage services recommendations, a client is not obligated to use a
Wealthspire Advisors affiliate to obtain any such services. If a client chooses to use a Wealthspire
Advisors affiliate for any such services, Wealthspire has a conflict of interest when evaluating product
recommendations involving advisory services or products offered by the firm or its affiliate.
While certain individuals associated with Wealthspire Advisors are registered representatives of a
broker-dealer and licensed as insurance agents/brokers of various insurance companies, financial
plan recommendations are generally of a generic nature and do not typically involve the
recommendation of specific investment products. Recommendations are not limited to any specific
product or service offered by a particular broker-dealer or insurance company.
Cash Positions. All cash positions (money markets, etc.) may be included as part of assets under
management for purposes of calculating Wealthspire‘s advisory fee. Please Further Note: When the
account is holding cash positions, those cash positions may be subject to the same fee schedule as
set forth below unless otherwise agreed upon.
Please Note: Our services are not intended to replace any tax, legal or accounting advice from a
tax/legal/accounting professional.
As an accommodation when asked, Wealthspire Advisors may recommend the services of qualified
professionals for certain non-investment implementation purposes (e.g. attorneys, accountants,
insurance agents, etc.). Clients are encouraged to make their own decisions and are under no
obligation to engage the services of any such recommended professional. Although we have
experience with these service providers, Wealthspire has not performed due diligence on these
service providers and is not responsible for the services provided by these services providers. The
client is under no obligation to engage the services of any such recommended professional. The client
retains absolute discretion over all such implementation decisions and is free to accept or reject any
recommendation from Wealthspire and/or its representatives. Please Also Note: If the client engages
any professional (i.e. attorney, accountant, insurance agent, etc.), recommended or otherwise, and a
dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively
from the engaged professional. At all times, the engaged licensed professional(s), and not
Wealthspire, shall be responsible for the quality and competency of the services provided. Please
Further Note: Wealthspire believes that it is important for the client to address financial planning
issues on an ongoing basis. Wealthspire’s advisory fee, as set forth at Item 5 below, will remain the
same regardless of whether or not the client determines to address financial planning issues with
Wealthspire. Please Also Note: It remains the client’s responsibility to promptly notify Wealthspire
Advisors of any change in his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/revising Wealthspire Advisors’ previous recommendations and/or services.
Held Away Assets
We use a third-party platform, Pontera Order Management System (“Pontera”), to facilitate
management of held away assets, such as 401(k) or defined contribution plan participant accounts,
over which we have discretion. Pontera allows us to avoid being considered to have custody of Client
funds since we do not have direct access to Client log-in credentials to affect trades. We are not
affiliated with Pontera in any way and receive no compensation from them for using their platform.
A link will be provided to the Client allowing them to connect an account(s) to the platform. Once
Client account(s) is connected to Pontera, Wealthspire will review the current account allocations.
When deemed necessary, we will rebalance the account considering client investment goals and risk
tolerance, and any change in allocations will consider current economic and market trends. The goal
is to improve account performance over time, minimize loss during difficult markets, and manage
internal fees that harm account performance. Client account(s) will be reviewed periodically, and
allocation changes will be made as deemed necessary.