A. The Pillar Strategies (the “Registrant”) is a trade name for Prestige Wealth Services
Group, Inc., a corporation that was formed in November 2012 in the state of Delaware.
The Registrant became registered as an Investment Adviser Firm in January 2013. Roy
Williams is the sole owner and the Registrant’s Managing Member.
B. As discussed below, the Registrant offers to its clients (other investment advisory firms)
sub-investment advisory services. The Registrant does not provide financial planning
services.
INVESTMENT ADVISORY SERVICES
The Registrant provides discretionary investment advisory services on a fee basis. The
Registrant’s annual investment advisory fee is based upon a percentage (%) of the market
value of the assets placed under the Registrant’s management.
Unified Managed Accounts. In conjunction with the Registrant’s investment
management services, the Registrant sponsors a Unified Managed Accounts (“UMA”) (a
professionally managed private investment account that is rebalanced regularly and can
encompass various investment vehicles including, but not limited to mutual funds,
stocks, bonds, master limited partnerships (“MLPs”) and exchange traded funds
(“ETFs”), all in a single account). As the sponsor for the UMA, the Registrant is
responsible for portfolio trading, re-balancing, reporting and other administrative
responsibilities.
MISCELLANEOUS
No Financial Planning or Non-Investment Consulting/Implementation Services. The
Registrant does not provide financial planning and related consulting services regarding
non-investment related matters, such as estate planning, tax planning, insurance, etc.
Registrant does not serve as an attorney, accountant, or insurance agency, and no portion
of our services should be construed as legal, accounting, or insurance implementation
services. Accordingly, the Registrant does not prepare estate planning documents, tax
returns or sell insurance products.
To the extent requested by a client, we may recommend the services of other
professionals for certain non-investment implementation purposes (i.e. attorneys,
accountants, insurance, etc.), including representatives of Registrant in their separate
individual capacities as representatives Triad Advisors, a FINRA member broker-dealer
(“Triad”) and/or as licensed insurance agents. The Registrant may also recommend the
services of Prestige Accounting Services Group, LLC (“PASG”), an affiliated accounting
firm. 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 made by Registrant or its
representatives.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional (i.e.
attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible
for the quality and competency of the services provided.
Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded
funds are available directly to the public. Therefore, a prospective client can obtain many
of the funds that may be utilized by Registrant independent of engaging Registrant as an
investment advisor. However, if a prospective client determines to do so, he/she will not
receive the Registrant’s initial and ongoing investment advisory services.
In addition to Registrant’s investment advisory fee described below, and transaction
and/or custodial fees discussed below, clients will also incur, relative to all mutual fund
and exchange traded fund purchases, charges imposed at the fund level (e.g. management
fees and other fund expenses).
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant 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, fund
manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time
when Registrant determines that changes to a client’s portfolio are neither necessary nor
prudent. Clients nonetheless remain subject to the fees described in Item 5 below during
periods of account inactivity.
Cash Positions. Registrant continues to treat cash as an asset class. As such, unless
determined to the contrary by Registrant, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for purposes of calculating
Registrant’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market
conditions/events (there being no guarantee that such anticipated
market conditions/events will occur), Registrant may maintain cash positions for
defensive purposes. In addition, while assets are maintained in cash, such amounts could
miss market advances. Depending upon current yields, at any point in time, Registrant’s
advisory fee could exceed the interest paid by the client’s money market fund.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a
specific custodian designated sweep account. The yield on the sweep account will
generally be lower than those available for other money market accounts. When this
occurs, to help mitigate the corresponding yield dispersion Registrant shall (usually
within 30 days thereafter) generally (with exceptions) purchase a higher yielding money
market fund (or other type security) available on the custodian’s platform, unless
Registrant reasonably anticipates that it will utilize the cash proceeds during the
subsequent 30-day period to purchase additional investments for the client’s account.
Exceptions and/or modifications can and will occur with respect to all or a portion of the
cash balances for various reasons, including, but not limited to the amount of dispersion
between the sweep account and a money market fund, the size of the cash balance, an
indication from the client of an imminent need for such cash, or the client has a
demonstrated history of writing checks from the account.
The above does not apply to the cash component maintained within a Registrant actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for
access to such cash, assets allocated to an unaffiliated investment manager and cash
balances maintained for fee billing purposes.
The client shall remain exclusively responsible for yield dispersion/cash balance
decisions and corresponding transactions for cash balances maintained in any Registrant
unmanaged accounts.
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains
their responsibility to promptly notify the Registrant if there is ever any change in their
financial situation or investment objectives for the purpose of reviewing, evaluating or
revising Registrant’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Registrant
and its third-party service providers use to provide services to Registrant’s clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in
Registrant’s operations and result in the unauthorized acquisition or use of clients’
confidential or non-public personal information. Clients and Registrant are nonetheless
subject to the risk of cybersecurity incidents that could ultimately cause them to incur
losses, including for example: financial losses, cost and reputational damage to respond
to regulatory obligations, other costs associated with corrective measures, and loss from
damage or interruption to systems. Although Registrant has established procedures to
reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will
always be successful, especially considering that Registrant does not directly control the
cybersecurity measures and policies employed by third-party service providers. Clients
could incur similar adverse consequences resulting from cybersecurity incidents that
more directly affect issuers of securities in which those clients invest, broker-dealers,
qualified custodians, governmental and other regulatory authorities, exchange and other
financial market operators, or other financial institutions.
Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2
of Form ADV shall be provided to each client prior to, or contemporaneously with, the
execution of the Sub-Advisory Agreement.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time,
impose reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does sponsor or participate in a wrap fee program.
E. As of March 1, 2024, the Registrant had approximately $133,316,000 in assets under
management on a discretionary basis.