A. Description of the Advisory Firm
Evoke Wealth, LLC d/b/a Evoke Advisors (“EVOKE” or the “Firm”) is a limited liability company
organized in Delaware. EVOKE is an investment advisory firm registered with the United States Securities
and Exchange Commission (“SEC”). EVOKE is owned by Evoke Holdings, LLC with a 1% minority
interest held by passive estate planning entities owned by Mr. David Hou and Mr. Mark Sear through their
trusts. The principal owner of Evoke Holdings, LLC as of the time of this Brochure filing is David Hou.
B. Types of Advisory Services
EVOKE provides holistic and personalized financial planning and discretionary and non-discretionary
investment advisory services to individuals, including high and ultra-high net worth individuals, and
entities, including, but not limited to, family offices, trusts, and estates. EVOKE also offers services to
pension and retirement/profit-sharing plans, pooled investment vehicles, foundations, endowments,
charitable organizations, guilds and health plans, investment companies, family offices, corporations, and
other business entities.
Financial Planning and Consulting Services
EVOKE provides a variety of comprehensive financial planning and consulting services to clients. Such
engagements may be part of the investment advisory engagement or pursuant to a separate engagement.
Generally, such financial planning services will involve preparing a financial plan or rendering a 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, cash flow analysis, investment planning,
retirement planning, estate planning, personal savings, educational savings, and other areas of a client’s
financial situation.
A financial plan developed for, or financial consultation rendered to, a client will typically 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. EVOKE may
recommend the services of itself and/or other professionals to implement its recommendations. Clients are
advised that a conflict of interest exists if EVOKE recommends its own services, as such a recommendation
may increase the advisory fees paid to EVOKE. The client is under no obligation to act upon any of the
recommendations made by EVOKE under a financial planning or consulting engagement to engage the
services of any such recommended professional, including EVOKE itself.
Investment Management Services
EVOKE seeks to tailor its investment management services to meet the needs of its individual clients and
seeks to manage client portfolios in a manner consistent with those needs and objectives. EVOKE consults
with clients on an initial and periodic basis to assess their specific risk tolerance, time horizon, liquidity
constraints, and other related factors relevant to the management of their portfolios. Clients are advised to
promptly notify EVOKE if there are changes in their financial situation or if they wish to place any
limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates
on the management of their accounts if EVOKE determines, in its sole discretion, the conditions would not
materially impact the performance of a management strategy or prove overly burdensome to EVOKE’s
management efforts.
In designing and implementing customized models and portfolio strategies, EVOKE can manage, on a
discretionary or non-discretionary basis, a broad range of investment strategies and vehicles. EVOKE
primarily allocates client assets among various investment managers’ mutual funds, exchange-traded funds
(“ETFs”), closed-end funds (“CEFs”), structured products, options, debt securities, and alternative
investments in accordance with clients’ stated investment objectives, risk profile and financial condition.
EVOKE may recommend to clients that all or a portion of their investment portfolio be managed on a
discretionary basis by one or more unaffiliated or affiliated money managers or investment platforms
(“External Managers”). The client may be required to enter into a separate agreement with the External
Manager(s), which will set forth the terms and conditions of the client’s engagement of the External
Manager. In addition to this Brochure, clients may also receive the written disclosure documents of the
respective External Managers engaged to manage their assets. EVOKE generally renders services to the
client relative to the discretionary selection of External Managers. EVOKE also assists in establishing the
client’s investment objectives for the assets managed by External Managers, monitors and reviews the
account performance and defines any restrictions on the account. The investment management fees charged
by the designated External Managers, together with the fees charged by the corresponding designated
broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, advisory fees charged
by EVOKE. EVOKE evaluates a variety of information about External Managers, which may include the
External Managers’ public disclosure documents, materials supplied by the External Managers themselves
and other third-party analyses it believes are appropriate and reputable. To the extent possible, EVOKE
seeks to assess the External Managers’ investment strategies, past performance, and risk results in relation
to its clients’ individual portfolio allocations and risk exposure. EVOKE also takes into consideration each
External Manager’s management style, returns, reputation, financial strength, reporting, pricing, and
research capabilities, among other factors.
EVOKE may also recommend that clients invest in unaffiliated or affiliated private investment vehicles
whose interests are not publicly offered under the Securities Act of 1933 (“Private Funds”). Such Private
Funds may be structured as fund of funds or as access vehicles to underlying funds or portfolios managed
by third-party investment advisors. EVOKE will, from time to time and as appropriate, solicit clients to
invest in such vehicles, and EVOKE will decide which clients to approach for some or all of these
investments at its own discretion. All relevant information pertaining to Private Fund recommendations,
including the compensation received by EVOKE (if any) or an EVOKE affiliate or related person (as
applicable), and by the third-party manager resulting from a client’s investment in a Private Fund, other
fees and expenses paid by the respective Private Fund, withdrawal rights, minimum investments,
qualification requirements, suitability, risk factors, and potential conflicts of interest is set forth in the
respective Private Fund’s disclosure documents, governing documents and other offering materials
pertaining to such interest (the “Offering Materials”). Each investor is required to receive, review, and
execute (as applicable) the Offering Materials prior to being accepted as an investor in any such Private
Fund.
It is important to note that any EVOKE advisory fee charged to clients for investing in a Private Fund is in
addition to the fees charged by the Private Funds to investors. This is a conflict of interest with the multiple
fees charged because EVOKE affiliates may serve as general partners of affiliated Private Funds and will
receive multiple forms of compensation. It should also be noted that certain members of EVOKE may
directly participate in any of the investment opportunities described for which an affiliated Private Fund is
established and/or may participate through the Private Fund itself for the purposes of investing. This right
to participate and any corresponding economic interest therefrom will likely mean that certain members of
EVOKE will derive a direct or indirect benefit from their direct participation and may also receive
management fees, carried interest, and other fees that a Private Fund charges to investors and clients for
their participation in the respective investment opportunity. As such, a conflict of interest arises between
the presentation of a private market investment opportunity to EVOKE clients and prospective clients, and
those members of EVOKE who will have an interest in the alternative investment opportunity and who,
through an affiliated Private Fund, may also be charging clients and investors a variety of fees for
investment in the respective investment opportunity. Therefore, it should be understood that members of
EVOKE may be highly incentivized to recommend an alternative investment opportunity to clients. Clients
are strongly advised and encouraged to discuss this conflict of interest with their advisors and to assess the
risks, merits, charges, suitability, and appropriateness of the opportunity prior to making any investment
decision.
ERISA Services
EVOKE can provide either discretionary or non-discretionary, fiduciary, and non-fiduciary advisory
services to the sponsors of defined contribution, defined benefit and non-qualified deferred compensation
plans, who in certain circumstances have ultimate authority to direct the investing and reinvesting of plan
assets as they deem appropriate, considering each plan’s stated objective, liquidity needs, stated policies
and guidelines. Providing investment services to plans under the Employee Retirement Income Security
Act of 1974, as amended (“ERISA”), means that the ERISA plan client retains and exercises the final
decision-making authority for implementing or rejecting EVOKE’s recommendations. Certain of the
foregoing services are provided by EVOKE as a fiduciary. When EVOKE provides investment advice for
a fee to an ERISA plan or ERISA plan participant, it is a fiduciary under ERISA. In addition, EVOKE is a
fiduciary under the Internal Revenue Code when it provides investment advice to an ERISA plan, ERISA
plan participant, an IRA, or an IRA owner (collectively, a “Retirement Account Client”). EVOKE is subject
to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other
things, prohibited transaction rules which are intended to prohibit fiduciaries from engaging in specified
conflicts of interest.
Retirement Plan and Investment Consulting Services
EVOKE also offers clients a broad range of retirement plan and investment consulting services, which may
include advice regarding asset allocation, manager selection, and investment risk management, among other
areas.
EVOKE may recommend clients engage the Firm for additional related services and/or other professionals
to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage
EVOKE or its affiliates to provide additional services for compensation. Clients retain absolute discretion
over all decisions regarding implementation and are under no obligation to act upon any of the
recommendations made by EVOKE under a retirement plan or investment consulting engagement. In
performing these services, EVOKE is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely
on such information. Clients are advised that it remains their responsibility to promptly notify the Firm of
any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating, or
revising EVOKE’s’ recommendations and/or services.
Advisory Services to the Alpha Funds
EVOKE entered into an investment management agreement with Advanced Research Alpha Fund, L.P. and
Advanced Research Alpha Fund, Ltd. (individually, the “Onshore Fund” and the “Offshore Fund”,
respectively, and collectively, the “Alpha Funds”), whereby EVOKE provides investment management and
investment advisory services to the Alpha Funds.
EVOKE provides investment management and advisory services to the Alpha Funds through the direct
investment of a portion of the Alpha Funds’ assets as well as through the investment in other privately
offered investment funds. As part of its investment management and advisory role, EVOKE evaluates and
selects a group of investment managers to manage certain of the Alpha Funds’ assets.
For the services rendered, EVOKE receives a management fee as follows:
(a) For advisory clients of EVOKE who are also investors in the Alpha Funds, the management fee is based
on the advisory contract with EVOKE. Advisory clients will only be subject to the agreed upon fees and
will not incur a separate management fee with respect to an investment in the Alpha Funds.
(b) Investors in the Alpha Funds who are not advisory clients or employees of EVOKE are subject to the
applicable fee schedule which is detailed in the offering documents for each of the Alpha Funds,
respectively.
Affiliated Sponsor and Index Provider for the RPAR Risk Parity ETF
In January 2022, Tidal ETF Services launched the RPAR Risk Parity ETF (“RPAR”) with EVOKE’s
affiliate, Advanced Research Investment Services, LLC (“ARIS”) serving as fund sponsor. While EVOKE
does not manage, advise, or sub-advise RPAR, EVOKE’s affiliate, RPAR, LLC, currently serves as the
fund sponsor and manages the Advanced Research Risk Parity Index (“RPARTR”) which RPAR seeks to
replicate. As such, RPAR, LLC is considered an affiliated index provider to RPAR. To mitigate any
potential for conflicts with respect to its affiliated Index Provider, EVOKE has retained a separate,
unaffiliated, and independent third party to serve as calculation agent to RPAR (the “Calculation Agent”).
EVOKE has no affiliation with RPAR’s Calculation Agent, RPAR’s adviser, RPAR’s sub-adviser, RPAR’s
distributor, nor any of their respective affiliates. The Calculation Agent, using the applicable rules-based
methodology, calculates, maintains, and disseminates RPARTR on a daily basis. RPAR, LLC monitors the
results produced by the Calculation Agent to help ensure that RPARTR is being calculated in accordance
with the applicable rules-based methodology. In addition, EVOKE has established policies and procedures
designed to prevent non-public information about pending changes to RPARTR from being used or
disseminated in an improper manner. Furthermore, EVOKE has established policies and procedures
designed to prevent improper use and dissemination of non-public information about RPAR’s portfolio
strategy.
It is important to note that as EVOKE’s affiliate RPAR, LLC is the sponsor of RPAR, EVOKE receives a
portion of the fees collected, and therefore, is incentivized to market RPAR to EVOKE clients and
prospective investors. This inherently creates a conflict of interest that both EVOKE clients and prospective
investors should carefully consider when deciding whether to invest in RPAR. To the extent that EVOKE
invests advisory client assets in RPAR, EVOKE or its related persons may charge management fees both
at the RPAR level and client account level; however, we or our related persons may also waive management
fees (or certain portions thereof) on client assets invested in RPAR, credit or rebate a client account for the
fees paid by RPAR to us or our related persons, or otherwise avoid or limit the payment of duplicative fees
to us and our related persons.
Affiliated Sponsor and Index Provider for the UPAR Ultra Risk Parity ETF
In January 2022, Tidal ETF Services launched the UPAR Ultra Risk Parity ETF (“UPAR”) with EVOKE’s
affiliate, Advanced Research Investment Services, LLC (“ARIS”) serving as fund sponsor. While EVOKE
does not manage, advise, or sub-advise UPAR, EVOKE’s affiliate, RPAR, LLC, currently serves as the
fund sponsor and manages the Advanced Research Ultra Risk Parity Index (“UPARTR”) which UPAR
seeks to replicate. As such, RPAR, LLC is considered an affiliated index provider to UPAR. To mitigate
any potential for conflicts with respect to its affiliated Index Provider, EVOKE has retained a separate,
unaffiliated, and independent third party to serve as calculation agent to UPAR (the “Calculation Agent”).
EVOKE has no affiliation with UPAR’s Calculation Agent, UPAR’s adviser, UPAR’s sub-adviser,
UPAR’s distributor, nor any of their respective affiliates. The Calculation Agent, using the applicable rules-
based methodology, calculates, maintains, and disseminates UPARTR on a daily basis. RPAR, LLC
monitors the results produced by the Calculation Agent to help ensure that UPARTR is being calculated in
accordance with the applicable rules-based methodology. In addition, EVOKE has established policies and
procedures designed to prevent non-public information about pending changes to UPARTR from being
used or disseminated in an improper manner. Furthermore, EVOKE has established policies and procedures
designed to prevent improper use and dissemination of non-public information about UPAR’s portfolio
strategy.
It is important to note that as EVOKE’s affiliate RPAR, LLC is the sponsor of UPAR, EVOKE receives a
portion of the fees collected, and therefore, is incentivized to market UPAR to EVOKE clients and
prospective investors. This inherently creates a conflict of interest that both EVOKE clients and prospective
investors should carefully consider when deciding whether to invest in UPAR. To the extent that EVOKE
invests advisory client assets in UPAR, EVOKE or its related persons may charge management fees both
at the UPAR level and client account level; however, we or our related persons may also waive management
fees (or certain portions thereof) on client assets invested in UPAR, credit or rebate a client account for the
fees paid by UPAR to us or our related persons, or otherwise avoid or limit the payment of duplicative fees
to us and our related persons.
C. Client-Tailored Advisory Services
Financial counsel and investment advice is customized and tailored to the unique goals, objectives, and
needs of each client. The planning process begins with an in-depth discovery of the client’s goals,
objectives, and attitudes toward risk and reward. The goals and objectives for each client are documented
in writing and approved by the client. The stated goals and objectives for each client are reflected in the
client’s overall recommended financial and investment program and advice that we provide on an ongoing
basis.
D. Donor Advised Fund Services
Certain EVOKE clients will establish donor advised funds through various third-party charitable programs,
including the Fidelity Charitable Gift Fund Program and the Schwab Charitable Fund (each, a “Charitable
Platform”), in which funds will be managed in accordance with the specific investment policies and
guidelines of the applicable the Charitable Platform. Clients will establish a donor advised account, transfer
funds earmarked for charitable donation and recognize a tax deduction in the year that funds are transferred
into an account opened on a Charitable Platform. The funds remain in such account until the client
designates a charity, an amount, and a date to donate to such charity.
Under independent advisor programs established within each Charitable Platform, donors nominate an
independent investment adviser, including EVOKE, to manage accounts established on the Charitable
Platforms. If nominated, EVOKE will manage the donor's account pursuant to investment guidelines
established by each Charitable Platform.
E. Administrative Services
As an accommodation to clients, EVOKE may provide administrative services to certain of its clients
ranging from client reporting, asset allocation, back-office functions, and consolidated reporting on client
non-advisory assets (“Administrative Services”). Non-advisory assets are assets independently owned by
clients but not included as assets under management by EVOKE. These non-advisory assets will not be
subject to EVOKE’s portfolio diversification review and no investment advice will be provided with respect
to such non-advisory assets. EVOKE will report the value of each non-advisory asset to the client, based
solely on the valuations received by EVOKE from the third-party managers of the non-advisory assets, the
clients themselves, or other third parties, but EVOKE will not have any obligation to independently
examine, confirm, or review non-advisory asset valuations. These Administrative Services are in addition
to other advisory services and are offered and may be performed at an additional charge.
F. IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance
Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction
Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment
to clients and prospective clients.
When we provide investment advice regarding a client’s or prospect’s retirement plan account or individual
retirement account, we are 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. The way we make money creates some conflicts with a client’s interests, so we operate under a
special rule that requires us to act in a client’s best interest and not put our interest ahead of our clients.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of a client’s assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management and, in
turn, our advisory fees. A conflict of interest exists if EVOKE recommends a rollover of retirement
accounts, as such a recommendation may increase advisory fees paid to EVOKE. While EVOKE may
educate clients as to investment options available to them in rolling over their assets, EVOKE has adopted
a policy of not recommending such rollovers and clients are advised to carefully review their options before
choosing to roll over their retirement assets to EVOKE’s management. As a fiduciary, we only recommend
a rollover on an exception basis when we believe it is in a client’s best interest.
G. Assets Under Management
As of December 31, 2023, EVOKE manages approximately $11,015,206,751 in assets on a discretionary
basis and $2,347,732,632 on a non-discretionary basis.