A. Firm Information
Integrated Wealth Concepts LLC (also d/b/a Integrated Financial Partners, Integrated Partners and herein
“Integrated” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange
Commission (“SEC”). Integrated is organized as a Limited Liability Company (“LLC”) under the laws of the
Commonwealth of Massachusetts. Integrated was founded in July 2016 and is owned and operated by Paul
Saganey (equity holder).
Our firm offers services through our network of investment advisor representatives (“Advisory Persons”,
“Financial Advisors”). Financial Advisors may have their own legal business entities whose trade names and
logos are used for marketing purposes and may appear on marketing materials or client statements. These
business names have been adopted by Integrated as d/b/a names under which we provide advisory services.
The Client should understand that the businesses are legal entities of the Financial Advisor and not of Integrated.
The Financial Advisors are under the supervision of our firm, and the advisory services of the Financial Advisor
are provided through Integrated. Integrated provides notice of all of its d/b/a names online at the SEC’s
Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with our firm name or our
CRD# 284656. When using d/b/a names, Integrated may not always provide reference to the legal name of the
company, Integrated Wealth Concepts. Regardless, when used to refer to the company, the use of a d/b/a name
is intended as a pseudonym for our legal company name of Integrated Wealth Concepts. This Disclosure
Brochure provides information regarding the qualifications, business practices, and the advisory services
provided by Integrated.
The Advisor serves as a fiduciary to Clients, as defined under 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. Our fiduciary commitment is further described in our Code of Ethics. For more information
regarding our Code of Ethics, please see “Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.”
B. Advisory Services Offered
Integrated offers investment advisory services to individuals, high net worth individuals, families, trusts, estates,
businesses and retirement plans (each referred to as a “Client”). These services generally fall into four categories
– Investment Management Services, Financial Planning and Consulting Services, Family Office Services and
Retirement Plan Advisory Services.
Investment Management Services
Integrated provides customized wealth management solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related
advisory services. Integrated works 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. Integrated will implement the
investment strategy with its internal management and/or the use of unaffiliated money managers or investment
platforms (as described below).
Integrated’s services are provided through independent financial advisors. This is distinguished from some other
registered investment advisors that mandate that clients invest only in company-sponsored investment programs.
Integrated believes strongly in the flexibility it provides to its independent financial advisors. To the extent that
independent financial advisors employ Integrated-sponsored investment programs in client accounts, it is
because the independent financial advisor deems the investment program to be suitable for the client and not
because of any requirement to do so from Integrated.
Integrated provides investment advisory services and portfolio management services. It does not provide
securities custodial services. At no time will Integrated accept or maintain custody of a Client’s funds or
securities, except for authorized deduction of the Advisor’s fees or as a result of a client’s implementation of a
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standing letter of authorization. All Client assets will be managed within their designated account[s] at the
Custodian, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices.
Below is a description of the various investment management services provided by the Advisor.
Internal Investment Management
Integrated customizes its investment management services for its Clients. Portfolios are primarily constructed
using mutual funds, exchange-traded funds (“ETFs”), individual stocks and fixed income securities. The Advisor
may also utilize other types of investments, as appropriate, to meet the needs of each particular Client.
Integrated generally employs a long-term investment approach for Clients, but 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.
Integrated 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.
The specific advisory program selected by the Client will cost the client more or less than purchasing program
services separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the
same services purchased separately include, but may not be limited to, the type and size of the account, the
historical or expected size or number of trades for the account, the types of securities and strategies involved,
and the number and range of supplementary advisory and client-related services provided to the account.
Integrated may recommend, on occasion, redistributing investment allocations to diversify the portfolio.
Integrated 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. Integrated 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.
The following paragraphs contain important conflicts of interest to consider. With respect to certain types of
accounts, Clients do not pay any transaction charges (i.e. a SWM II account on LPL’s custodial platform). Clients
should be aware that Integrated is responsible for transaction charges to its custodians for those accounts. The
transaction charges paid by Integrated vary based on the type of transaction (e.g., mutual fund, equity or ETF)
and for mutual funds based potentially on whether or not the mutual fund pays 12b-1fees (fees paid by the
mutual fund to distributors of the funds to cover the cost of distribution and/or shareholder services) and/or
recordkeeping fees to the custodian. While Integrated does not participate in these fees, clients should
understand that the transaction charges to be incurred by Integrated may be a factor that Integrated considers
when deciding which securities to select and how frequently to place transactions in these accounts.
Solicitor Based Third Party Asset Manager Programs
For approriate clients, Integrated recommends that all or a portion of a Client’s portfolio be implemented by
utilizing one or more unaffiliated money managers or investment platforms (herein the “Third Party Asset
Managers” or “TPAMs”). The Client will be required to enter into one or more separate agreements with the
TPAM[s] that provide for discretionary management by the TPAM of the investment platform.
Integrated serves as both a solicitor of accounts to the TPAM and as the Client’s primary advisor and relationship
manager and will oversee the account to ensure the TPAM is managing consistent with the selected investment
strategy or strategies. However, the TPAM will assume discretionary authority for the day-to-day investment
management of those assets placed in their control. Integrated will assist and advise the Client in establishing
investment objectives for their account, the selection of the TPAM, and defining any restrictions on the account.
TPAM services generally begin with the financial advisor obtaining the necessary financial data from the Client to
assist with setting an appropriate investment objective, determining the suitability of the program and in opening
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an account with the TPAM. Depending on the program, the financial advisor may also assist the client with
selecting a model portfolio of securities designed and managed by either the TPAM or a selected portfolio
management firm available through the TPAM responsible for providing discretionary asset management
services. The TPAM or other third-party investment advisor is granted authority in its client agreement to
purchase and sell securities on a discretionary basis pursuant to investment objective chosen by the Client. In
doing so, the TPAM or other third-party investment advisor typically constructs various model investment
portfolios that are managed according to specific investment strategies associated with the respective models,
and that are not generally customized for individual Clients (subject to the client’s ability to request reasonable
investment restrictions on investing in securities or other special accommodations that may be made). In addition
to portfolio management services, the TPAM sponsor will also generally arrange for custody of client assets,
trade execution, cashiering services, and such other services as outlined in their separate client agreement and
Brochure.
Prior to entering into an agreement with a TPAM, the Client will be provided with each TPAM’s Form ADV
Part 2 - Disclosure Brochure, Form CRS as well as a disclosure statement that defines the relationship between
Integrated and the TPAM. Integrated does not receive any compensation from these TPAMs or Investment
Platforms, other than Integrated’s investment advisory fee (described in “Item 5 – Fees and Compensation”)
which is set forth in the Client’s investment monitoring agreement with Integrated.
Sub-Adviser Based Third Party Asset Management Programs
Integrated can enter into sub-advisory relationships in which it contracts with a TPAM to provide investment
management services to a client account. In these cases, Integrated and the Sub-Adviser are jointly responsible
for the ongoing management of the account. Your Advisor is responsible for assisting you with completing the
investor profile questionnaire or any account opening documentation. While each TPAM may have a different
name for their questionnaire, your responses will assist your Advisor with understanding your investment
objectives, financial situation, risk tolerance, investment time horizon and other personal information. Based on
the answers that you provide to your Advisor, he or she will assist you in determining which TPAM model or
portfolio strategy is appropriate for you. As part of establishing a new account, you will receive both our
disclosure brochure as well as the TPAM’s disclosure brochure.
Since each TPAM is uniquely structured with different investment products, please ensure that you carefully
review all documents provided to you on behalf of the TPAM. These include, but are not limited to:
• The TPAM’s Form ADV Part 2 or Disclosure Brochure for specific program descriptions.
• The TPAM’s Client Agreement as well as any other agreement entered into regarding a TPMM Program,
for specific contractual terms (including fees, billing methods, administrative and other fees, etc.).
• Any additional disclosure or offering documents provided by the TPAM in connection with investment
products.
Financial Planning and Consulting Services
Integrated provides a variety of financial planning and consulting services to individuals and families, pursuant to
a written financial planning and consulting agreement. Services are offered in several areas of a Client’s financial
situation, depending on their goals, objectives and financial situation. Financial planning is a separate service
from the Advisor’s investment management services. Clients have full discretion as to how they choose to
implement the recommendations discussed in the financial plan.
Financial planning and consulting services 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. Integrated may also refer Clients to an accountant, attorney or other specialist as
appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a
written summary of 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 months of contract date, assuming all information and documents requested are provided promptly.
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Family Office Services
Integrated offers family office services to high-net worth and business owner clients. The services are tailored to
the needs and complexities of the client pursuant to a written agreement. These services may include:
• Financial Planning Services;
• Business Planning;
• Wealth Management and Reporting;
• Legacy Planning;
• Lifestyle Management;
• Philanthropy; and
• Governance.
Retirement Plan Advisory Services
Integrated provides plan advisory services to company retirement plans (each a “Plan”) and the sponsor of the
Plan (herein the “Plan Sponsor”). Services are tailored to the size and complexity of the Plan and the needs of
the Plan Sponsor and/or the participants in the Plan (each a “Plan Participant”), pursuant to the terms of the
retirement plan advisory agreement. These services may include:
• Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Management Services (Discretionary or Non-discretionary)
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Vendor Analysis and Benchmarking
Integrated may provide retirement plan advisory services on behalf of the Plan and Plan Sponsor on
either a
non-discretionary (under ERISA Section 3(21)) or a discretionary basis (under ERISA Section 3(38)). Further, the
Advisor may also be engaged to provide investment management for the accounts of the Plan Participants.
Client Role and Obligations Relative to Integrated’s Advisory Services
Integrated relies on forthright communication from its clients in order to provide them with investment services.
It is imperative that clients be direct, honest and fulsome with their investment criteria, investment knowledge,
holdings, goals, time horizon and other important factors. Clients are obliged to report changes in their financial
situation, including the factors enumerated above, as soon as possible.
Important Disclosures Relating to Our Services
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent
requested by a client, Integrated may provide financial planning and related consulting services regarding non-
investment related matters, such as estate planning, tax planning, insurance, etc. Integrated does not serve as
a law firm, accounting firm, or insurance agency, and no portion of Integrated’s services should be construed as
legal, accounting, or insurance implementation services. Accordingly, Integrated does not prepare estate
planning documents, tax returns or sell insurance products.
To the extent requested by a client, Integrated may recommend the services of other professionals for certain
non-investment implementation purposes (i.e. attorneys, accountants, insurance agents, etc.). Clients are
reminded that they are 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 Integrated or its representatives.
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If the client engages any unaffiliated recommended 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[s] (i.e. attorney, accountant, insurance agent, etc.), and not
Integrated, shall be responsible for the quality and competency of the services provided.
Retirement Rollovers-Potential for Conflict of Interest. A client or prospective client leaving an employer typically
has four options regarding an existing retirement plan (and may engage in a combination of these options): (i)
leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan,
if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv)
cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences).
Integrated does not provide rollover recommendations, however, upon client request, Integrated may provide
education materials intended to assist a client determine whether they should engage in a rollover or not. No
client is under any obligation to roll over retirement plan assets to an account managed by Integrated.
Unaffiliated Private Investment Funds. Integrated also provides investment advice regarding private investment
funds. Integrated, on a non-discretionary basis, may recommend that certain qualified clients consider an
investment in private investment funds, the description of which (the terms, conditions, risks, conflicts and fees,
including incentive compensation) is set forth in the fund’s offering documents. Integrated’s role relative to
unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment
monitoring services. If a client determines to become an unaffiliated private fund investor, the amount of assets
invested in the fund(s) shall be included as part of “assets under management” for purposes of Integrated
calculating its investment advisory fee. Integrated’s fee shall be in addition to the fund’s fees. Integrated’s
clients are under absolutely no obligation to consider or make an investment in any private investment fund(s).
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 own, private investment funds do not provide daily liquidity or pricing.
Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the
client shall establish that the client is qualified for investment in the fund, and acknowledges and accepts the
various risk factors that are associated with such an investment.
In the event that Integrated references private investment funds owned by the client on any supplemental
account reports prepared by Integrated, 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
updated value will continue to be reflected on the report until the fund provides a further updated value.
As result of the valuation process, if the valuation reflects initial purchase price or an updated value subsequent
to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more or less than
the value reflected on the report. Unless otherwise indicated, Integrated shall calculate its fee based upon the
latest value provided by the fund sponsor.
Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of
Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG
investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e.,
considers how a company safeguards the environment); Social (i.e., the manner in which a company manages
relationships with its employees, customers, and the communities in which it operates); and Governance (i.e.,
company management considerations). The number of companies that meet an acceptable ESG mandate can
be limited when compared to those that do not, and could underperform broad market indices. Investors must
accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual
funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As
with any type of investment (including any investment and/or investment strategies recommended and/or
undertaken by Integrated), there can be no assurance that investment in ESG securities or funds will be
profitable, or prove successful. Integrated generally relies on the assessments undertaken by the unaffiliated
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mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or
portfolio’s underlying company securities meet a socially responsible mandate.
Cash Positions. Integrated continues to treat cash as an asset class. As such, unless determined to the
contrary by Integrated, all cash positions (money markets, etc.) shall continue to be included as part of assets
under management for purposes of calculating Integrated’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), Integrated 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, Integrated’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 Integrated 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 Integrated 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 an Integrated 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 Integrated unmanaged accounts.
Portfolio Activity. Integrated has a fiduciary duty to provide services consistent with the client’s best interest. As
part of its investment advisory services, Integrated 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 Integrated 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.
Client Obligations. In performing its services, Integrated shall not be required to verify any information received
from the client or from the client’s other designated professionals, and is expressly authorized to rely thereon.
Moreover, each client is advised that it remains their responsibility to promptly notify Integrated if there is ever
any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or
revising Integrated’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Integrated and its third-party service
providers use to provide services to Integrated’s clients employ various controls, which are designed to prevent
cybersecurity incidents stemming from intentional or unintentional actions that could cause significant
interruptions in Integrated’s operations and result in the unauthorized acquisition or use of clients’ confidential or
non-public personal information. Clients and Integrated 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 Integrated has established procedures to reduce the risk
of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially
considering that Integrated does not directly control the cybersecurity measures and policies employed by third-
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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 copies of Integrated’s written Brochure and Client Relationship Summary as set forth
on Part 2 of Form ADV and Form CRS, respectively, shall be provided to each client prior to, or
contemporaneously with, the execution of the client service agreement.
C. Tailored Relationships
Integrated makes available, through its financial advisors, advisory services to meet most individual Client needs
and objectives. It is the role of the financial advisor to meet with Clients and determine which option(s) are most
suitable in assisting the Clients with meeting their investment needs. Certain programs available through
Integrated may be utilized by multiple Clients that have similar time horizons, needs and objectives. Integrated
offers Clients the ability to place restrictions on their advisory account(s). In general, the restrictions may include
security type, specific securities, and cash balance requirement. Under certain situations a restriction may
prevent Integrated from providing investment choices to meet a client’s needs. In the event a restriction does
impair Integrated’s ability to manage a portfolio effectively the client engagement may be terminated under the
terms of the contract.
D. Wrap Fee Programs
For some Clients, Integrated may include the securities transaction fees together with investment advisory fees
to provide the Client with a single, bundled fee structure. This combination of fees is typically referred to as a
“Wrap Fee Program.” Integrated sponsors and is the investment manager of a wrap fee program called the
Integrated Models. Additionally, Integrated is a sponsor of wrap fee programs developed and sponsored by its
Custodians. Integrated’s Wrap Fee Program Brochure is included as Appendix 1 to this Disclosure Brochure
solely to discuss the fees and potential conflicts associated with a bundled fee, the Integrated Models and the
custodial wrap fee programs.
Participation in a wrap program can cost the client more or less than purchasing such services separately. The
terms and conditions of a wrap program engagement are more fully discussed in the Wrap Fee Program
Brochure. Because wrap program transaction fees and/or commissions are paid by Integrated to the account
custodian, Integrated has an economic incentive to maximize its compensation by seeking to minimize the
number of transaction fee trades in a client's wrap fee account.
E. Assets Under Management
As of December 31, 2023, Integrated managed approximately $12,394,481,000 in assets, all of which are
advised on a discretionary basis. Clients may request more current information at any time by contacting the
Advisor.