WEP offers a wrap fee program that is custodied at a non affiliated custodian. The Program provides
investment advice, brokerage, and custodial services under a “wrap fee” arrangement. Generally, in a
wrap fee arrangement, the Account pays a combined fee for investment advice, brokerage services,
clearance and settlement services, and custodial services. Please see the attached Part 2A Brochure for
additional information about the firm’s non‐wrap fee programs.
Investment Advisory Services
The Firm provides advisory services, giving continuous advice based on the client’s individual needs
through personal discussions in which goals and objectives, based upon the client’s personal objectives are
established. The Firm will develop a personal investment policy based upon an investment objective
questionnaire and/or personal interview and manage the portfolio according to the criteria.
Each client has the ability to impose reasonable restrictions on the management of his/her account,
including the designation of particular securities or types of securities that should not be purchased for the
account, or that should be sold if held in the account. If a client’s instructions are unreasonable or an
Investment Advisor Representative believes that the instructions are inappropriate for the client, the Firm
will notify the client that, unless the instructions are modified, it may cancel the instructions in the client’s
account. A client will not be able to provide instructions that prohibit or restrict the Investment Adviser of
an open‐end or closed‐end mutual fund or ETF with respect to the purchase or sale of specific securities or
types of securities within the fund.
Because the Firm is a registered investment adviser, we are required to meet certain fiduciary standards
when providing investment advice to clients. Additionally, when we provide investment advice related to a
retirement plan account or an individual retirement account, we are considered fiduciaries 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. As such, we are required to act in your best
interest and not put our interest ahead of yours, even though our compensation creates some conflicts
with your interests in that the more you have us manage, the more we can earn. Our clients however are
under no obligation to use services recommended by our associated persons. Furthermore, we believe
that our recommendations are in the best interests of our clients and are consistent with our clients’ needs.
The Firm may provide advice in the form of a Financial Plan. Clients may receive a written plan in
conjunction with the advisory services, providing the client with a detailed financial plan designed to
achieve their stated financial goals and objectives.
Information on clients will be gathered by in‐depth personal interviews and a review of personal financial
information including data concerning current financial status, future requirements, risk appetite and goals.
Based upon this thorough review, a written plan may be prepared for the client providing the client with a
detailed plan designed to achieve their stated financial goals and objectives. If such a plan is provided it is
recommended that the client review this plan with tax accountants, attorneys and other professional
service providers.
Use of Model Portfolios
The Firm offers the following model portfolios. Clients will be placed in one or more models based on
the information gathered during our interviews and review of personal financial information.
Relative Strength ‐ A dynamic asset class investment strategy that uses Point & Figure1 data to
evaluate the strength of six asset classes: Domestic Equity, International Equity, Fixed Income,
Foreign Currencies, Commodities, and Cash. ETFs representing the best performing two asset
classes compared to each other and cash are selected for investment.
Moving Averages ‐ A Trend following model that determines whether or not to invest in 5 assets
classes and 20 underlying investments based on the current 200‐day moving average.
Economic ‐ Uses 16 indicators grouped in four categories to determine whether or not to be
long the S&P500 or in cash. The four categories:
o Monetary indicators include levels, changes, and differences in various interest rates,
monetary policy, and money supply.
o Technical indicators reflect levels, changes, and other measures of stock market
activity.
o Sentiment indicators gauge emotion in the market.
o Fundamental indicators describe economic and valuation activities. These include measures
of inflation, growth, and other factors related to the overall economy
Momentum ‐ An active strategy that can go long, short, or to cash in four asset classes (US
Equities, Euro, Gold, and Oil) using Japanese Renko2 charts to determine current momentum.
Equity Income –
o The company must be number 1 in its industry and/or have top brand names.
o The company must have consistent profit margins and enormous pricing power.
o The company must have a "fortress" balance sheet. This means they have enough cash
or near cash assets to pay off debt multiple times over.
o The company has less than average price volatility; profit margins and cash flow are
better than S&P500 average.
o The company must have consistently shown increased dividends, though past yields are
no guarantee of future yields.
Managed Growth ‐ Uses a sector rotation model to identify major themes in the market, have
exposure to those sectors controlled by demand and eliminate exposure to those sectors
controlled by supply. The portfolio attempts to capture the stronger trends and avoid the
weaker trends.
Diversified Strategic Income ‐ The premise behind our Income portfolio is to choose asset classes
that historically pay high dividends, though past yields are no guarantee of future yields, and
diversify investments within those classes using ETFs, Closed End Funds, and securities trading
intra‐day. Designed to provide maximum liquidity along with high income. The main objectives for
the portfolio are to generate a 5‐7% current yield and preserve the overall portfolio value.
Use of Alternative Investments
As detailed in Item 9 below, some associated persons of WEP are also registered as registered representatives
(“RR”) of Triad Advisors, LLC (“Triad”), a broker/dealer and FINRA member firm. These individuals are subject
to Triad’s compliance policies and procedures and supervisory oversight.
Triad’s general policy prohibits an RR from recommending for purchase any “alternative investments” through
custodians not affiliated with Triad. For purposes of this disclosure, “alternative investments” include, but are
not limited to, limited partnerships, limited liability companies, private investment funds or other pooled
investment vehicles, real estate partnerships and REITs. Notwithstanding the foregoing, Triad has approved a
limited number of alternative investment sponsors and/or products, which will be available for RR’s to
recommend for purchase via custodians not affiliated with Triad. Triad will be compensated directly by the
product sponsor for its review of the product/sponsor and for Triad’s associated compliance and supervisory
oversight of all transactions conducted in connection with these approved sponsors and products. For more
information on these fees please go to www.triad‐advisors.com/customer‐information. Neither WEP nor any
RR will receive a share of Triad’s compliance and supervisory fee.
Clients are advised that there may be other alternative investment sponsors and/or products not
recommended by WEP that are suitable for the client
and that may cost more or less than those
recommended by WEP. While Triad reviews numerous alternative investment sponsors and/or products on an
on‐going basis, Triad approves only a select number of sponsors/products pursuant to its due diligence
requirements and reviews. Accordingly, your ability to obtain alternative investments through WEP will be
limited to those Triad approved products. While you are free to explore various alternative investments
independent of WEP, such investments cannot be obtained by means of WEP’s guidance or recommendation.
Fees and Compensation
The specific manner in which fees are charged by the Firm is established in a client’s written agreement.
Fees are based on a percentage of assets under management and calculated at an annual rate and billed in
advance on a quarterly basis. Fees are based on the assets in the account and in some instances, may be
negotiated. The maximum fees allowed under the Program are presented below. All fees are negotiable at
our sole discretion. Fees may be charged on a tiered basis, meaning a higher fee for assets below a certain
threshold and a lower fee charged on the assets above the threshold; or a single fee may be charged for all
assets based on the total in the account. Slightly higher fees may be charged for certain strategies.
The maximum account fee is 2.5%.
Account Size: Fee percentage:
$0 ‐ $999,999.99 1.5%
$1,000,000.00 ‐ $2,499,999.99 1.25%
$2,500,000 ‐ $Unlimited 1.00%
The initial fee is due upon the client’s opening and funding an account. The initial fee will be based on
the opening balance and will be prorated according to the number of days remaining in the calendar
quarter. Thereafter, the fee for each calendar quarter will be calculated by multiplying the fair market
value of the assets in the account as of the last trading day of the preceding calendar quarter by the
annual fee and then dividing that result by four. Upon termination of an account, any prepaid, asset‐
based fees will be prorated according to the days the account was opened during the calendar quarter
and unearned fees will be rebated to the client. Rebated fees will be credited to the account
automatically. Clients may elect to transfer the balance or request a check for the balance in the
account. The cost for creating Financial Plans is included in the fees listed above.
As noted in the clients’ Advisory Agreement all fees are debited directly from client accounts and are
calculated using the total assets in the account as shown on the client custodial statement.
You may incur additional charges including, but not limited to, mutual fund sales loads, 12b‐1 fees,
surrender charges, and IRA and qualified retirement plan fees. Also, there is a $100 per year custodial
account fee minimum. We will never receive any portion of such commissions or fees. We are only
compensated by the fee described above. We receive no other compensation in connection with your
account managed by a third‐party money manager. When we negotiate lower fees and expenses charged
by third parties, all negotiated improvements are for your benefit. Please see the manager’s Brochure for
additional important information regarding fees charged.
General Information
The advisory fees and transaction charges do not cover charges imposed by third‐parties for investments
held in the account, such as contingent deferred sales charges or 12(b)‐1 trails on mutual funds. In
addition, each mutual fund or third party money manager charges asset management fees, which are in
addition to the advisory fees charged by our firm. Accounts may require a minimum advisory fee or
quarterly maintenance fee that will be detailed in the applicable advisory agreement. The Management
Fee also does not cover fees and charges in connection with: debit balances; margin interest; odd‐lot
differentials; IRA fees; transfer taxes; exchange fees; wire transfers; extensions; non‐ sufficient funds;
mailgrams; legal transfers; bank wires; postage; costs associated with exchanging foreign currencies; and
SEC fees or other fees or taxes required by law.
Although WEP believes its fees are reasonable in light of the services provided, clients should be aware that
such fees may be more or less than the fees and commissions associated with investment advisory and
brokerage services purchased separately. The comparison is dependent upon a number of factors,
including the frequency of brokerage activity in the client’s account, the size of the account under
management, and any negotiated fee arrangements with respect to the account. Also, clients should be
aware that since WEP absorbs certain transaction costs in wrap program accounts, we may have a financial
incentive not to place trade orders in those accounts, so clients should be aware that this potential conflict
of interest may exist. An investor should consider these factors prior to opening an Advisory Account with
WEP. The wrap fees charged may be higher than those otherwise available if the services were provided
separately for a discrete fee or if an Investment Advisor were to select brokerage and negotiate
commissions in the absence of the extra consulting service provided. Clients should consider the value of
the additional consulting services when making such comparisons. The combination of custodial,
consulting, and brokerage services may not be available separately or may require multiple accounts,
documentation, and fees. All fees described herein may be subject to negotiation depending on a range of
factors including, but not limited to, account size and overall range of services requested.
Please see the attached Part 2A Brochure for additional information about the firm’s non‐wrap fee
programs.
Account Termination
The client and/or the firm may initiate termination of the contract at any time by sending written notice to
the contra party and will be accepted the day that it is received by the contra party. A termination fee may
apply if the account is terminated within the first year of the advisory contract; however, a full refund will
be provided without penalty if the client terminates the contract within 5 business days of signing the
advisory agreement.
If you instruct WEP to terminate your advisory contract and liquidate your account, we will proceed with
liquidation of your account in an orderly and efficient manner. There will not be a charge by us for such
redemption; however, the client should be aware that certain mutual funds impose redemption fees as
stated in each company’s fund prospectus in certain circumstances. Clients must keep in mind that the
decision to liquidate security issues or mutual funds may result in tax consequences that should be
discussed with the client’s tax advisor. Factors that may affect the orderly and efficient manner would be
size and types of issues, liquidity of the markets, and market makers’ abilities. Should the necessary
securities’ markets be unavailable and trading suspended, efforts to trade will be done as soon as possible
following their reopening. Due to the administrative processing time needed to terminate client’s
investment advisory service and communicate the instructions to client’s Investment Advisor, termination
orders received from clients are not market orders; it may take several business days under normal market
conditions to process the client’s request. During this time, the client’s account is subject to market risk.
WEP and its agent are not responsible for market fluctuations of the client’s account from time of written
notice until complete liquidation. All efforts will be made to process the termination in an efficient and
timely manner.