A. Firm Information
Dakota Wealth, LLC (“Dakota Wealth Management” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC)
under the laws of the State of Florida. Dakota Wealth Management was founded in May 2018 and is a wholly
owned and controlled subsidiary of Dakota Wealth Management, LLC, a Florida limited liability company.
Dakota Wealth Management, LLC is owned by several members. This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by Dakota Wealth
Management.
B. Advisory Services Offered
Dakota Wealth Management offers investment advisory services to individuals, high net worth individuals, trusts,
foundations, retirement plans, charitable organizations, insurance companies, business enterprises, pooled
investment vehicles and registered investment companies (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the 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. Dakota Wealth Management's fiduciary commitment is further described in the Advisor’s Code
of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or
Interest in Client Transactions and Personal Trading.
Wealth Management Services
Dakota Wealth Management may provide Clients with wealth management services, which generally includes a
broad range of comprehensive financial planning and consulting services in connection with discretionary
management of investment portfolios. Investment Management and Financial planning services may also be
offered on a stand-alone basis.
Investment Management Services – Dakota Wealth Management provides customized investment advisory
solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing
discretionary and/or non-discretionary investment management and related advisory services. Dakota Wealth
Management works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. Dakota Wealth Management will then
construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds
(“ETFs”), individual equities and fixed income to assist with the Client’s investment goals. The Advisor may also
utilize real estate investment trusts (“REITs”), options contracts and/or proprietary investments to meet the needs of
its Clients. The Advisor may retain certain types of investments based on a Client’s legacy investments based on
portfolio fit and/or tax considerations.
Dakota Wealth Management’s investment strategies are primarily long-term focused, but the Advisor may buy, sell
or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to
market conditions. Dakota Wealth Management 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.
Dakota Wealth Management evaluates and selects investments for inclusion in Client portfolios only after applying
its internal due diligence process. Dakota Wealth Management may recommend, on occasion, redistributing
investment allocations to diversify the portfolio. Dakota Wealth Management 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. Dakota Wealth Management 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 the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk
tolerance.
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All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the
advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
Use of Independent Managers – Dakota Wealth Management may recommend that Clients utilize one or more
unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion
of a Client’s investment portfolio, based on the Client’s needs and objectives. In such instances, the Client will be
required to authorize and enter into an investment management agreement with an Independent Manager that
defines the terms in which the Independent Manager will provide its services. The Advisor will perform initial and
ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with
Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development
of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into
an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A -
Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning Services – Dakota Wealth Management will typically provide a variety of financial planning and
consulting services to Clients, either as a component of wealth management or pursuant to a written financial
planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals
and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a
specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement planning,
personal savings, education savings, insurance analysis and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
Divorce Planning Services –The Advisor may also be engaged separately for divorce planning services. These
services may include, but are not limited to, pre-divorce financial counseling and education, assistance with
financial forms, analysis of financial positions, analysis of proposed marital settlement, financial mediation, analysis
of income tax effects and financial impact forecasting. The Advisor may also serve in either a mediation or financial
neutral capacity, separate from advisory services rendered. Please see Item 10 – Financial Industry Affiliations for
additional details.
Dakota Wealth Management may also refer Clients to an accountant, attorney or other specialists, as appropriate
for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of
the 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 (6) months of
contract date, assuming all information and documents requested are provided
promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
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recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
The Advisor may also be engaged separately for divorce planning services. These services may include, but are
not limited to, pre-divorce financial counseling and education, assistance with financial forms, analysis of financial
positions, analysis of proposed marital settlement, financial mediation, analysis of income tax effects and financial
impact forecasting. The Advisor may also serve in either a mediation or financial neutral capacity, separate from
advisory services rendered. Please see Item 10 – Financial Industry Affiliations for additional details.
Family Office Services – The Advisor also offers family office services to Clients with investable assets of
$5,000,000 and above. The Advisor’s family office model includes, in addition to the wealth management services
described above, additional services such as: complex multi-generation estate and wealth planning, family
governance and education, business liquidity planning, philanthropic planning and execution, bill pay services, tax
planning, and will analyze and introduce Clients to private investment review and analysis. Each family’s situation is
unique so the level of service the Advisor delivers in this model is tailored to the specific needs of each Client.
Investment Consulting Services
The Advisor offers a variety of investment consulting services to individuals and families, pursuant to a written
investment consulting agreement. This service is ideal for Clients seeking a smaller scope engagement and to
utilize the expertise of the Advisor but without having an account managed by the Advisor or developing a financial
plan as described below. Services are offered in several areas of a Client’s financial situation, depending on their
goals, objectives and financial situation. Generally, such consulting services will involve rendering an investment
consultation based on the Client’s financial goals and objectives.
As investment consulting can be similar in nature as developing a financial plan but with a restricted scope of
engagement, the consultation for the Client will usually include general recommendations for a course of activity or
specific actions to be taken by the Client. For certain investment consulting 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. Consultations are typically completed within six
months of contract date, assuming all information and documents requested are provided promptly.
Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing
relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the
Client is under no obligation to implement the transaction through the Advisor.
Retirement Plan Advisory Services
Dakota Wealth Management provides advisory services on behalf of company retirement plans (each a “Plan”) and
the company/sponsor (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist
the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Employee Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Management
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
These services are provided by Dakota Wealth Management serving in the capacity as a fiduciary under the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section
408(b)(2), the Plan Sponsor is provided with a written description of Dakota Wealth Management’s fiduciary status,
the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under
the engagement.
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Private Fund Advisor Services
The Advisor also serves as the investment manager to the Persimmon Absolute Return Fund, a master/feeder
hedge fund of funds complex (herein the “Feeder Fund”). The Feeder Fund is a series of Persimmon Research
Partners, L.P., a Delaware limited partnership (the “Partnership”), formed to invest in Persimmon Absolute Return
Master Fund, L.P., a Delaware limited partnership (the “Master Fund”). The Feeder Fund and Master Fund are
herein collectively the “Private Funds”. The services offered to the Private Funds are detailed in the offering
documents, which include as applicable, operating agreements, private placement memorandum and/or term
sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering
Documents”).
The investment objective of the Private Funds is to seek to achieve positive consistent annual performance by
investing in various limited partnerships and other pooled investment vehicles (managed by experienced
investment managers. The Private Funds are a multi-manager investment vehicle formed to provide investors,
through its investment in the Master Fund, with the opportunity to purchase units in a diversified portfolio of largely
non-correlated hedge funds employing various hedged strategies such as multi-strategy, global macro, credit,
distressed, volatility trading, short-term trading, managed futures, relative value, market-neutral, event-driven,
special situations, and direct lending. For more detailed information on investment objectives, policies and
guidelines, please refer to the
respective Private Fund’s Offering Documents.
Registered Investment Company Advisor Services
The Advisor also serves as the investment advisor to the Persimmon Long/Short Fund, Ticker LSEIX (herein the
“Mutual Fund”). The Mutual Fund is a diversified series of Northern Lights Fund Trust III, a Delaware statutory trust
organized on December 5, 2011 (the "Trust"). The Trust is registered as an open-end management investment
company. The Trust is governed by its Board of Trustees (the "Board ") and in accordance with the investment
objectives, policies and restrictions, the Advisor provides the Mutual Fund with ongoing investment management
and administrative oversight.
A full description of the services provided by the Advisor for managing the Mutual Fund is available in the current
prospectus and statement of additional information (“SAI”). The prospectus and statement of additional information
are available from the SEC’s website
(www.SEC.gov) or by contacting the Advisor at (561) 774-8101.
C. Client Account Management
Prior to engaging Dakota Wealth Management to provide investment advisory services, each Client is required to
enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities
of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Dakota Wealth Management, in connection with the Client, will
develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Dakota Wealth Management will develop a strategic asset allocation that is targeted to
meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Dakota Wealth Management will develop a portfolio for the Client that is intended to
meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Dakota Wealth Management will provide investment
management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Dakota Wealth Management does not manage or place Client assets into a wrap fee program. Investment
management services are provided directly by Dakota Wealth Management.
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E. Assets Under Management
As of January 31, 2024, Dakota Wealth Management manages approximately $5,334,134,989 in Client assets,
$5,328,702,147 of which are managed on a discretionary basis and $5,432,842 on a non-discretionary basis.
Clients may request more current information at any time by contacting the Advisor.