Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of California in 2015 and has been in business as an investment adviser since that time. Our firm
is owned by Mike Sheets (50%) and Avi Pai (50%).
Our firm provides asset management and investment consulting services for many different types of
clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons.
As a fiduciary it is our duty to always act in the client’s best interest. This is accomplished in part by
knowing the client. Our firm has established a service-oriented advisory practice with open lines of
communication. Working with clients to understand their investment objectives while educating
them about our process facilitates the kind of working relationship we value.
Types of Advisory Services Offered
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis.
Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising could include: investment options, plan structure and
participant education. Retirement Plan Consulting services typically include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
• Investment
Options – Our firm will work with the Plan Sponsor
to
evaluate
existing investment options and make recommendations for appropriate
changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation, and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and notify
the client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
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Hourly Consulting Services
PWMG, through its investment advisor representatives, may provide consulting services including,
as selected by the client in the consulting agreement, advice regarding tax planning, investment
planning, retirement planning, estate planning, cash flow/budget planning, business planning,
education planning, and personal financial planning. The services take into account information
collected from the client such as financial status, investment objectives and tax status, among other
data. Our firm may or may not deliver to the client a written analysis or report as part of the services.
Our firm tailors the hourly consulting services to the individual needs of the client based on the
investment objective chosen by the client. The engagement terminates upon final consultation with
the client. Fees for such services are negotiable and detailed in the client agreement.
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or
investments. The client’s individual investment strategy is tailored to their specific needs and may
include some or all of the previously mentioned securities. Portfolios will be designed to meet a
particular investment goal, determined to be suitable to the client’s circumstances. Once the
appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and
if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
Estate Planning:
We offer third-party estate planning services provided by EncorEstate Plans as a part of our ongoing
financial planning services for our clients to assist with general information as it applies to reviews
of existing plans, gathering information needed to provide outside firms in creation of documents,
and updating existing plans for clients. PWMG does not provide any legal advice and all legal
documents are completed by EncorEstate Plans or another third party.
ADV Part 2A – Firm Brochure 6 Provence Wealth Management Group
For clients with greater than $1,000,000 in assets under management with PWMG, there is no
separate or additional fee for estate planning services provided by EncorEstate Plans.
For clients with less than $1,000,000 in assets under management with PWMG who wish to obtain
estate planning services, EncoreEstate Plans will invoice the client directly, and the client will submit
payment for any services rendered directly to EncorEstate Plans. Clients are not required to utilize
any third-party products or services that we may recommend, and they may be able to receive similar
services from other professionals at a similar or lower cost.
The portion of the estate planning fees due to EncorEstate Plans that PWMG participates in may be
negotiable in certain cases. Negotiability is at the sole discretion of PWMG, factors to be considered
include, but are not limited to, complexity of the client’s estate plan, potential growth of the client
relationship, and other factors that will be applied evenly across all affected clients. Should the client
be responsible for estate planning fees, those fees are separate, and in addition to the client’s ongoing
financial planning or advisory fees. Estate planning fees are disclosed in Item 5 of this document.
Referrals to Third Party Money Managers:
(Investment Committee Recommending the Portfolios)
Our firm utilizes the services of a third-party money manager for the management of client accounts.
Investment advice and trading of securities will only be offered by or through the chosen third-
party money manager. Our firm will not offer advice on any specific securities or other investments
in connection with this service. Prior to referring clients, our firm will provide initial due diligence on
third party money managers and ongoing reviews of their management of client accounts. In order
to assist in the selection of a third-party money manager, our firm will gather client information
pertaining to their financial situation, investment objectives, and reasonable restrictions to be
imposed upon the management of the account.
Our firm will periodically review third party money manager reports provided to the client at least
annually. Our firm will contact clients from time to time in order to review their financial situation
and objectives; communicate information to third party money managers as warranted; and assist
the client in understanding and evaluating the services provided by the third-party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions
that could affect their financial standing.
LPL Sponsored Programs:
Our firm may provide advisory services through certain programs sponsored by LPL Financial LLC
(LPL), a registered investment advisor and broker-dealer. Below is a brief description of each LPL
advisory program available to our firm. For more information regarding the LPL programs, including
more information on the advisory services and fees that apply, the types of investments available in
the programs and the potential conflicts of interest presented by the programs please see the
program account packet (which includes the account agreement and LPL Form ADV program
brochure) and the Form ADV, Part 2A of LPL or the applicable program.
Personal Wealth Portfolios Program (PWP)
PWP offers clients an asset management account using asset allocation model portfolios designed by
LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s
investment objective. Advisor will also have discretion for selecting third party money managers
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(PWP Advisors), mutual funds and ETFs within each asset class of the model portfolio. LPL will act
as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on
a discretionary basis mutual funds, ETFs and equity and fixed income securities.
A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a
lower minimum account size.
Guided Wealth Portfolios (GWP)
GWP offers clients the ability to participate in a centrally managed, algorithm-based investment
program, which is made available to users and clients through a web-based, interactive account
management portal (“Investor Portal”). Investment recommendations to buy and sell open-end
mutual funds and exchange-traded funds are generated through proprietary, automated, computer
algorithms (collectively, the “Algorithm”) of Xulu, Inc., doing business as FutureAdvisor
(“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as
described below (such model portfolio selected for the account, the “Model Portfolio”).
Communications concerning GWP are intended to occur primarily through electronic means
(including but not limited to, through email communications or through the Investor Portal),
although PWMG will be available to discuss investment strategies, objectives, or the account in
general in person or via telephone.
A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45)
days to help users determine whether they would like to become advisory clients and receive ongoing
financial advice from LPL, FutureAdvisor and PWMG by enrolling in the
advisory
service
(the “Managed Service”). The Educational Tool and Managed Service are
described in more detail in the GWP Program Brochure. Users of the Educational Tool are not
considered to be advisory clients of LPL, FutureAdvisor or PWMG, do not enter into an advisory
agreement with LPL, FutureAdvisor or PWMG, do not receive ongoing investment advice or
supervisions of their assets, and do not receive any trading services.
A minimum account value of $5,000 is required to enroll in the Managed Service.
Manager Access Select (MAS)
Manager Access Select provides clients access to the investment advisory services of professional
portfolio management firms for the individual management of client accounts. PWMG will assist
the client in identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio
Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary
basis. PWMG will provide initial and ongoing assistance regarding the Portfolio Manager selection
process.
A minimum account value of $50,000 is required for Manager Access Select, however, in certain
instances, the minimum account size may be lower or higher.
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. We will obtain
the necessary financial data from the client, assist the client in determining the suitability of the MWP
program and assist the client in setting an appropriate investment objective. We initiate the steps
necessary to open an MWP account and have discretion to select a model portfolio designed by LPL
Financial’s Research Department consistent with the client’s stated investment objective. LPL
Financial’s Research Department is responsible for selecting the mutual funds
within
a
model portfolio and for making changes to the mutual funds selected. The client will
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authorize LPL Financial to act on a discretionary basis to purchase and sell mutual funds, including
in certain circumstances exchange traded funds and to liquidate previously purchased securities. The
client will also authorize LPL Financial to effect rebalancing for MWP accounts.
The MWP program may make available model portfolios designed by strategists other than LPL’s
Research Department. If such models are made available, we will have discretion to choose among
the available models designed by LPL and outside strategists. A minimum account value of $10,000
is required for MWP.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation program
using Optimum Funds Class I shares. Under OMP, the client will authorize LPL Financial
on a
discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen
by the client. We will assist the client in determining the suitability of OMP for the client and assist
the client in setting an appropriate investment objective. Adviser will have discretion to select a
mutual fund asset allocation portfolio designed by LPL consistent with the
client’s
investment objective. LPL Financial will have discretion to purchase and sell Optimum
Funds pursuant to the portfolio selected for the client. LPL Financial will also have authority to
rebalance the account. A minimum account value of $10,000 is required for OMP.
Small Market Solution Program (SMS)
Under SMS, LPL Research (a team of investment professionals within LPL) creates and maintains a
series of different investment menus (“Investment Menus”) consisting of a mix of different asset
classes and investment vehicles (“investment options”) for clients that sponsor and maintain
participant-directed defined contribution plans (“Plan Sponsors”). The Plan Sponsor is responsible
for selecting the Investment Menu that it believes is appropriate based on the demographics and
other characteristics of the Plan and its participants. LPL Research is responsible for the selection
and monitoring of the investment options made available through Investment Menus (“Fiduciary
Selection Services”). The investment options that are offered through SMS are limited to the specific
investments available through the record keeper that the Plan Sponsor selects. The Plan Sponsor may
only select an Investment Menu in its entirety and does not have the option to remove or substitute
an investment option.
If the Plan is subject to ERISA, LPL will be a “fiduciary” and serve as “investment manager” (as that
term is defined in section 3(38) of ERISA) in connection with the Fiduciary Selection Services. None
of the services offered under SMS other than the Fiduciary Selection Services will constitute
“investment advice” under 3(21)(A)(ii) of ERISA, or otherwise cause LPL or our firm to be deemed a
fiduciary.
In addition to the Fiduciary Selection Services, Plan Sponsor may also select from a number of non-
fiduciary consulting services available under SMS that are provided by our firm. These consulting
services may include, but are not limited to: general education, and support regarding the Plan and
the investment options selected by Plan Sponsor; assistance regarding the selection of, and ongoing
relationship management for, record keepers and other third-party vendors; Plan participant
enrollment support; and participant-level education regarding investment in the Plan. These
consulting services do not include any individualized investment advice to the Plan Sponsor or Plan
participants with respect to Plan assets, and LPL and our firm do not act as fiduciaries under ERISA
in providing such consulting services.
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Tailoring of Advisory Services
Our firm offers individualized investment advice to our Wrap Asset Management clients. General
investment advice will be offered to our Retirement Plan Consulting, and Referrals to Third Party
Money Management clients.
Each Wrap Asset Management client has the opportunity to place reasonable restrictions on the types
of investments to be held in the portfolio. Restrictions on investments in certain securities or types
of securities may not be possible due to the level of difficulty this would entail in managing the
account.
Participation in Wrap Fee Programs
Our firm offers and sponsors a wrap fee program, as further described in Part 2A, Appendix 1 (the
“Wrap Fee Program Brochure”). Our firm does not manage wrap fee accounts in a different fashion
than non-wrap fee accounts. All accounts are managed on an individualized basis according to the
client’s investment objectives, financial goals, risk tolerance, etc.
Regulatory Assets Under Management
Our firm manages $275,731404 on a discretionary basis as of 12/31/2023.