A. Savior, LLC, which does business as Savior Wealth (“Savior Wealth”) is a Delaware
Limited Liability Company formed on September 21, 2018. Savior Wealth became
registered as an investment adviser on January 28, 2019. Savior Wealth is owned by Todd
M. Ingwersen.
Matthew McLaughlin may also conduct business using a separate DBA, McLaughlin
Financial Consulting.
Although each IAR of Savior Wealth is registered with, and subject to oversight and
supervision by Savior Wealth, each may operate their businesses independently and work
under a separate business name or “DBA”. As such, marketing materials provided to clients
and potentials clients may include the DBA name and may include a logo associated with
the DBA name. However, Savior Wealth continues to review and approve marketing
materials related to the IAR or IA firm services offered and provided to clients.
B.
INVESTMENT ADVISORY SERVICES
Savior Wealth provides discretionary and non-discretionary investment advisory services.
Typically, Savior Wealth provides services on a wrap fee basis, which means that the client
will pay a single fee for bundled services (i.e., investment advisory, brokerage, and
custody). Prior to engaging Savior Wealth to provide investment advisory services, clients
are required to enter into an Investment Advisory Agreement which contains the terms and
conditions of the engagement.
To begin the investment advisory process, an investment adviser representative will first
determine the client’s investment objectives and goals and then invest the client’s assets
consistent with their objectives and goals. Once invested, Savior Wealth provides periodic
monitoring and review of account performance and compares the account’s asset allocation
with the client’s investment objectives. From time to time, Savior Wealth will rebalance
the client’s account or buy and sell securities for the client’s account as it deems
appropriate.
When requested by the client, financial planning and consulting services will generally be
provided. In the event that the client requires extraordinary planning or consultation
services, Savior Wealth may determine to charge for these additional services in its sole
discretion. Prior to charging for these services, Savior Wealth will provide the client with
a separate written notice listing the cost of these additional services.
WRAP PROGRAM
As discussed above, Savior Wealth typically provides investment advisory services on a
wrap fee basis through its wrap fee program (the “Program”). The terms and conditions
pertaining to the Program are discussed in the Wrap Fee Program Brochure, which is
presented to all prospective Program participants. Under the Program, Savior Wealth offers
investment advisory services, for a single specified annual Program fee, inclusive of trade
execution, custody, reporting, and investment advisory fees. All prospective Program
participants should read both this Brochure and the Wrap Fee Program Brochure, and ask
any corresponding questions that they may have, prior to participation in the Program.
Because transaction fees and commissions are paid by Savior Wealth to the account
custodian, Savior Wealth would typically have an economic incentive to minimize the
number of trades in the client’s account to maximize its own compensation, which presents
a conflict of interest.
Savior Wealth does not currently impose a minimum asset requirement for participation in
the Program but, in its discretion, may establish one in the future.
Participation in a wrap program may cost the client more or less than purchasing these
services separately. When managing a client’s account on a wrap fee basis, Savior Wealth
receives the balance of the Program fee after all other costs incorporated into the wrap fee
have been deducted. The terms and conditions of a wrap program engagement are more
fully discussed in Savior Wealth’s Wrap Fee Program Brochure.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
Savior Wealth may provide financial planning or consulting services on a stand-alone
basis. The fees for these services are outlined in Item 5 below. Savior Wealth may provide
advice on investment or non-investment matters, such as estate planning or insurance
planning. Prior to rendering services, clients are required to enter into a Financial Planning
and Consulting Agreement that contains the terms and conditions of the engagement.
If requested, Savior Wealth may recommend the services of other professionals so that the
client can implement their plan, including certain employees of Savior Wealth (See
disclosures at Item 10.C below regarding certain employee’s status as licensed insurance
agents). The client is under no obligation to engage any recommended professional.
The client retains discretion over all implementation decisions and is free to accept or reject
any recommendation from Savior Wealth. If the client engages any unaffiliated
professional, and a dispute arises, the client agrees to seek recourse exclusively from and
against the engaged professional. It remains the client’s responsibility to promptly notify
Savior Wealth if there is ever any change in their financial situation or investment
objectives so that it can review, and if necessary, revise its previous recommendations.
RETIREMENT PLAN SERVICES
Savior Wealth also provides non-discretionary pension consulting services, pursuant to
which it assists sponsors of self-directed retirement plans with the selection and/or
monitoring of investment alternatives (generally open-end mutual funds) from which plan
participants shall choose in self-directing the investments for their individual plan
retirement accounts. In addition, to the extent requested by the plan sponsor, Savior Wealth
may also provide participant education designed to assist participants in identifying the
appropriate investment strategy for their retirement plan accounts. The terms and
conditions of the engagement shall generally be set forth in a Retirement Plan Services
Agreement between Savior Wealth and the plan sponsor.
MISCELLANEOUS
Limitations of Financial Planning and Consulting.
As indicated above, to the extent requested by a client, Savior Wealth may provide
financial planning and related consulting services. Neither Savior Wealth nor its
investment adviser representatives assist clients with the implementation of any financial
plan, unless they have agreed to do so in writing. Savior Wealth does not monitor a client’s
financial plan, and it is the client’s responsibility to revisit the financial plan with their
investment adviser representative, if desired.
Furthermore, although Savior Wealth may provide recommendations regarding non-
investment related matters, such as estate planning, tax planning and insurance, Savior
Wealth does not serve as a law firm, accounting firm, or insurance agency, and no portion
of its services should be construed as legal, accounting, or insurance implementation
services.
Accordingly, Savior Wealth does not prepare estate planning documents, tax returns or sell
insurance products. To the extent requested by a client, Savior Wealth may recommend the
services of other professionals for certain non-investment implementation purposes,
including certain of Savior Wealth’s owners or employees (e.g., attorneys, accountants,
insurance agents.). Some of these professionals may be affiliated with Savior Wealth. (See
disclosures at Item 10.C below regarding certain employee’s status as licensed insurance
agents).
Clients are reminded that they are under no obligation to engage the services of any
recommended professional. The client retains absolute discretion over all implementation
decisions and is free to accept or reject any recommendation made by Savior Wealth or its
representatives.
If the client engages any unaffiliated recommended professional, and a dispute arises, the
client agrees to seek recourse exclusively from and against the engaged professional.
Retirement Rollovers: 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). If
Savior Wealth recommends that a client roll over their retirement plan assets into an
account to be managed by Savior Wealth, such a recommendation creates a conflict of
interest if Savior Wealth will earn new (or increase its current) compensation as a result of
the rollover. If Savior Wealth provides a recommendation as to whether a client should
engage in a rollover or not (whether it is from an employer’s plan or an existing IRA),
Savior Wealth is acting as 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. No client is under any obligation to roll over
retirement plan assets to an account managed by Savior Wealth, whether it is from an
employer’s plan or an existing IRA.
Non-Discretionary Service Limitations. Clients that determine to engage Savior Wealth
on a non-discretionary investment advisory basis must be willing to accept that Savior
Wealth cannot effect any account transactions without obtaining prior consent to such
transaction(s) from the client. Therefore, in the event that Savior Wealth would like to
make a transaction for a client’s account (including in the event of an individual holding
or general market correction), and the client is unavailable, Savior Wealth will be unable
to effect the account transaction(s) (as it would for its discretionary clients) without first
obtaining the client’s consent.
Account Aggregation Tools. Savior Wealth, in conjunction with the services provided
through Advyzon may also provide periodic comprehensive reporting services which may
incorporate all of the client’s investment assets, including those investment assets that are
not part of the assets managed by Savior Wealth (the “Excluded Assets”). Savior Wealth’s
service relative to the Excluded Assets is limited to reporting services only, which does not
include investment implementation. Because Savior Wealth does not have trading
authority for the Excluded Assets, to the extent applicable to the nature
of the Excluded
Assets (assets over which the client maintains trading authority vs. trading authority
designated to another investment professional), the client (and/or the other investment
professional), and not Savior Wealth, shall be exclusively responsible for directly
implementing any recommendations relative to the Excluded Assets. The client and/or their
other advisors that maintain trading authority, and not Savior Wealth, shall be exclusively
responsible for the investment performance of the Excluded Assets. Without limiting the
above, Savior Wealth shall not be responsible for any implementation error (timing,
trading, etc.) relative to the Excluded Assets. In the event the client desires that Savior
Wealth provide non-discretionary investment management services (whereby Savior
Wealth would have trading authority) with respect to the Excluded Assets, the client may
engage Savior Wealth to do so pursuant to the terms and conditions of the Investment
Advisory Agreement between Savior Wealth and the client.
Affiliated Private Investment Funds. Savior Wealth is the investment manager for Savior
Acrylic SPV I LP, Savior APP SPV LP, Savior CL SPV LP, Savior ON SPV LP, Savior
FB SPV LP, Savior BTC SPV LP, Savior CSPRING SPV LLC, Savior JOB-G SPV LLC,
Savior NFC SPV LP, Savior PLSTQ SPV LP, Savior ORCH SPV LP, Savior ORCH II
SPV LP, Savior PSC SPV LLC and Savior Archetype Fund II SPV LP (the “affiliated
private funds”). Savior Wealth, on a non-discretionary basis, may recommend that
qualified clients consider allocating a portion of their investment assets to the affiliated
private funds. The terms and conditions for participation in the affiliated private funds,
including management and incentive fees, conflicts of interest, and risk factors, are set forth
in the fund’s offering documents. Savior Wealth’s clients are under absolutely no
obligation to consider or make an investment in a private investment fund(s).
Unaffiliated Private Investment Funds. Savior Wealth may also recommend that certain
qualified clients consider an investment in unaffiliated private investment funds. Savior
Wealth’s role relative to the unaffiliated private investment funds shall be limited to its
initial and ongoing due diligence and investment monitoring services. Savior Wealth’s
clients are under absolutely no obligation to consider or make an investment in an
unaffiliated private investment fund(s).
Risk Factors: 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 he/she is qualified
for investment in the fund and acknowledges and accepts the various risk factors that are
associated with such an investment.
Fund Valuation: If Savior Wealth bills an investment advisory fee based upon the value of
private investment funds or otherwise references private investment funds owned by the
client on any supplemental account reports prepared by Savior Wealth, the value for all
private investment funds owned by the client will reflect the most recent valuation provided
by the fund sponsor. The current value of any private investment fund could be
significantly more or less than the original purchase price or the price reflected in any
supplemental account report.
Inverse/Enhanced Market Strategies. Savior Wealth may utilize long and short mutual
funds and/or exchange traded funds that are designed to perform in either an: (1) inverse
relationship to certain market indices (at a rate of 1 or more times the inverse [opposite]
result of the corresponding index) as an investment strategy and/or for the purpose of
hedging against downside market risk; and (2) enhanced relationship to certain market
indices (at a rate of 1 or more times the actual result of the corresponding index) as an
investment strategy and/or for the purpose of increasing gains in an advancing market.
There can be no assurance that any such strategy will prove profitable or successful. To the
contrary, such funds and/or strategy(ies) can suffer substantial losses. In light of these
enhanced risks/rewards, a client may direct Savior Wealth, in writing, not to employ any
or all such strategies for their accounts.
Use of Exchange Traded Funds and Mutual Funds. While Savior Wealth may
recommend allocating investment assets to exchange traded funds (“ETFs”) or mutual
funds that are not available directly to the public, Savior Wealth may also recommend that
clients allocate investment assets to publicly available ETFs or mutual funds that the client
could obtain without engaging Savior Wealth as an investment adviser. However, if a client
or prospective client determines to allocate investment assets to publicly available ETFs or
mutual funds without engaging Savior Wealth as an investment adviser, the client or
prospective client would not receive the benefit of Savior Wealth’s initial and ongoing
investment advisory services.
Portfolio Activity. Savior Wealth has a fiduciary duty to provide services consistent with
the client’s best interest. As part of its investment advisory services, Savior Wealth 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 Savior Wealth 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 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 Savior Wealth 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 Savior
Wealth 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 Savior Wealth
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 Savior Wealth
unmanaged accounts.
Cybersecurity Risk. The information technology systems and networks that Savior
Wealth and its third-party service providers use to provide services to Savior Wealth’s
clients employ various controls, which are designed to prevent cybersecurity incidents
stemming from intentional or unintentional actions that could cause significant
interruptions in Savior Wealth’s operations and result in the unauthorized acquisition or
use of clients’ confidential or non-public personal information. Clients and Savior Wealth
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 Savior Wealth has established
processes to reduce the risk of cybersecurity incidents, there is no guarantee that these
efforts will always be successful, especially considering that Savior Wealth 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.
Client Obligations. In performing its services, Savior Wealth 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 on the information in its possession. Clients are responsible
for promptly notifying Savior Wealth if there is ever any change in their financial situation
or investment objectives so that Savior Wealth can review, and if necessary, revise its
previous recommendations or services.
C. Please see Item 4.B for a discussion on how Savior Wealth tailors its services to the
individual needs of clients. Clients may impose reasonable restrictions on Savior Wealth’s
services, including limiting specific securities or types of securities used by Savior Wealth,
by notifying their adviser of those restrictions in writing.
D. Savior Wealth sponsors a wrap fee program and there is very little, if any difference, in the
way that Savior Wealth manages wrap fee program accounts and non-wrap fee program
accounts. Please see Item 4.B for more information about Savior Wealth’s services.
E. As of January 1, 2024, Savior Wealth had $96,115,957 in assets under management on a
discretionary basis and $5,400,000 on a non-discretionary basis.