A. General Description of EverSource Wealth Advisors, LLC
EverSource Wealth Advisors, LLC (“EverSource,” “firm,” “we” or “us”) is a privately-owned, SEC-
registered investment advisor, with its principal offices located in Birmingham, Alabama. Formed
as a Delaware limited liability company on January 18, 2017, the two principal owners of
EverSource are FHG Ventures - EverSource, LLC and BMSS EverSource, LLC. FHG Ventures –
EverSource, LLC is wholly owned by Mark Wesson.
EverSource’s day-to-day operations are managed by its officers, including Mark Wesson, our
Chief Executive Officer. While EverSource’s executive officers and staff primarily operate from
our offices in Birmingham, Alabama, our business model entails a large network of investment
advisor representatives (“IARs” or “Advisors”) employed by EverSource and other registered
investment advisor (“RIA”) firms located throughout the United States under contract with
EverSource for back office and/or subadvisory services. Although all of the IARs are registered
with and subject to oversight and supervision by EverSource, some of the IARs or teams of IARs
operate under a separate team name disclosed on the firm’s Form ADV Part 2B, allowing IARs
flexibility in providing tailored individualized investment advice to the firm’s clients. EverSource’s
home office in Birmingham provides its IARs with investment programs, technology, operations
support, marketing, back-office functions, and compliance supervision.
Through our network of IARs and RIA firms which rely upon EverSource’s services, EverSource
offers a wide range of investment advisory, wealth management, consulting, and financial
planning services to meet the needs of clients, who include individuals, families, estates and
trusts, charitable foundations and funds, and institutions.
B. Description of EverSource’s Services
EverSource provides wealth management services, including investment advisory, financial
planning, and consulting services to its investor clients, and provides back-office support services
and serves as an investment subadvisor to RIAs. As fiduciaries, EverSource IARs seek to
understand their clients and to deliver a wide range of planning and investment solutions
according to each client’s particular goals, needs, values and passions.
1. Investment Advisory Services
Investment advisory services are provided to EverSource’s investor clients by our IARs through
EverSource’s Investment Programs:
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EverSource Firm as Portfolio Manager
EverSource Advisor as Portfolio Manager
Managed Accounts
Private Markets
Held-Away Assets
Retirement Plan Services
When entering a new client engagement, EverSource IARs interview their client to understand
the client’s investment experience, time horizon, portfolio withdrawal needs, risk tolerance, tax
sensitivity, personal values, and unique circumstances. The clients’ objectives and preferences
are documented in an Investor Profile Form or Investment Policy Statement and implemented
via the Investment Programs detailed below. Because EverSource earns more when a client
places more assets with the firm to manage, we have an incentive to recommend that the client
place more assets with us. Also, the client generally pays different fees for each of the
Investment Programs described here, which can give us an incentive to recommend particular
Investment Programs. We address this conflict of interest through disclosure and by seeking
always to put the client’s interest ahead of our own. In addition, these program fees are paid to
EverSource; the individual advisors do not receive any part of these fees and so has no incentive
to recommend one program over another.
EverSource Firm as Portfolio Manager
EverSource’s Firm as Portfolio Manager program provides centralized discretionary portfolio
management for clients’ accounts using EverSource’s model portfolios or third-party strategist
models of ETFs and mutual funds. At the request of the Advisor, the EverSource Investment
Department will manage the clients’ accounts to the selected model portfolio approved by the
EverSource Investment Committee.
EverSource Advisor as Portfolio Manager
EverSource’s Advisor as Portfolio Manager program gives IARs the flexibility to manage client
accounts using their own models or customizing portfolios to individual clients’ needs and
preferences. Oversight is provided by the EverSource Investment Department, but IARs are
responsible for executing day-to-day investment management decisions. Clients may elect for
EverSource Wealth Advisors | Form ADV Part 2A | March 8, 2024 Page 6
accounts to be managed on a discretionary basis (client consent not required before trading) or
a non-discretionary basis (client consent required before trading).
Managed Accounts
EverSource provides asset manager and investment strategy due diligence on and contracts with
third-party asset managers for unique equity, equity derived options, and fixed income managed
account strategies. IARs may delegate investment discretion of clients’ account(s) to third-party
asset managers and strategies approved by the EverSource Investment Committee through a
subadvisor relationship. EverSource also accesses asset manager strategies through subadvisor
contracts with turnkey unified managed account platforms.
Private Markets
EverSource provides investment and operational due diligence on private equity funds, private
credit funds, real asset funds, hedge funds, and direct real estate investment. IARs are
responsible for presenting eligible clients with appropriate private market investments approved
by EverSource’s Investment Committee and facilitating the client subscription commitments with
the EverSource Investment Department. IARs may learn of private market investment
opportunities which have not been and will not be reviewed, recommended or supervised by
EverSource, but which the IAR knows are of interest to specific eligible clients. In those
situations, the IAR is permitted to assist the client as requested, but must make it clear to the
client that neither EverSource nor the IAR is reviewing, recommending, or supervising the
investment and that no advisory or other fee will be charged to the client by EverSource related
to such non-recommended investment.
EverSource formed and manages EverSource Capital Access Fund I, LLC (“Fund”), a pooled closed-
end investment fund which allowed eligible clients to pool their funds and have access to a single
private market fund. This fund is now closed to new investors. The offering documents, including
private placement memorandums, contain a complete discussion about the Fund. Each investor
was required to complete a Subscription Agreement, through which the client established
eligibility and accepted the various risks associated with this type of investment. EverSource
clients were not obligated to invest in the Fund. One member of the EverSource board of
managers is a co-founder and co-CEO of Sovereign’s Capital, a private equity firm which sponsors
investment funds, including ones that EverSource recommends. Another board member and
part owner of the Firm is the CEO of a private real estate firm which sponsors real estate
investment funds, including ones that EverSource also recommends. EverSource addresses this
conflict of interest by disclosing these relationships and subjecting these funds to the same due
diligence process as any other private fund it recommends. Neither board member has any
involvement in the due diligence or recommendation process and clients are not obligated to
invest in any fund.
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Held-Away Asset Management
Held-away assets are those in accounts at financial institutions other than EverSource’s primary
custodial relationships (i.e., Schwab and Fidelity). This includes fee-only insurance and annuity
products, 529 plans, donor-advised funds, and defined contribution plan participant (e.g.,
retirement) accounts. EverSource uses a third-party platform to facilitate management of plan
participant accounts where the client has granted EverSource discretion. Because EverSource
does not have access to or use client log-in credentials to effect trades on this platform,
EverSource is not considered to have custody of these client funds. In those cases, clients receive
a link from the platform provider which allows them to connect their account to the platform
and to give the EverSource advisor access for the limited purpose of managing the investments
in the account. The advisor will review the account allocations and, when deemed necessary,
rebalance the account in light of the client’s investment goals. Because it is generally not possible
for EverSource to directly debit its fees from these accounts, fees will be assigned to another
client account or billed directly to the client. EverSource is not affiliated with this platform
provider in any way and receives no compensation for using the platform. EverSource IARs also
provide investment advisory, financial planning, and consulting services related to fee-based
annuity and insurance products and charge a percent of contract market value fee for providing
advice and investment recommendations for these products.
Retirement Plan Services
For certain retirement plans, EverSource has agreed to provide advice to the plan sponsor,
investment manager oversight, plan participant education and ongoing administrative support in
partnership with third-party administrators (“TPAs”), recordkeepers, and investment co-
fiduciaries for 3(21) or, in rare cases, 3(38) ERISA advice.
Rollover Recommendations
For clients who are participants in a retirement plan, we will evaluate whether it is in their best
interest to “roll over” their plan account to an individual retirement account (“IRA”), move their
assets to a different retirement plan, leave the plan as is, or reallocate the assets in the plan
account. EverSource will generally earn a fee if the client elects to rollover the plan account or to
contract with EverSource for the provision of investment advice on the plan account assets. This
creates a conflict of interest and an incentive for EverSource to recommend a rollover rather than
leaving the account as is. EverSource discloses this conflict, advises the client of its fiduciary
status, and documents the rationale for any rollover recommendation.
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2. Services to Independent RIAs
Turnkey Asset Management Program Services
For certain RIA firms, EverSource provides Turnkey Asset Management Program (“TAMP”)
services. EverSource’s TAMP services provide back-office investment services including, model
management, trading and rebalancing, advisor and client portal access, quarterly billing,
quarterly reporting, and providing access to marketing resources. EverSource utilizes the
Investment Programs described above to deliver these services and may use third-party
strategists as well to deliver model portfolios through its TAMP sub-advisory service. For some
clients, EverSource also provides due diligence and back-office support regarding private markets
funds.
EverSource also serves as a subadvisor to DPL Financial Partners, LLC (“DPL”), providing ongoing
portfolio management and investment advisory services for certain insurance and annuities
owned by a client. DPL pays EverSource an advisory fee for this subadvisory work and the
arrangement places no financial burden on the client.
Back Office Services
EverSource also provides to independent RIAs various “back office” services in such areas as
marketing, compliance, administration, technology, practice development and human resources.
The specifics of each engagement are covered in the written agreement between each RIA and
EverSource.
3. Planning Services
Financial Planning Services
EverSource’s IARs deliver Financial Planning Services based on either a comprehensive or limited
scope project engagement. In each case, Advisors seek to understand client’s current and
projected financial situation and circumstances. Depending on the type of engagement, financial
planning advice and ongoing guidance may address individual and family financial data
organization, cash flow planning, tax planning, risk identification and mitigation strategies,
insurance policy review, investment asset allocation review, retirement projections and planning,
business succession, life impact stewardship planning and an estate plan review.
Standard practice is for IARs to deliver the financial planning process over the course of multiple
meetings and to present analysis, options, and recommendations via financial planning software
and follow-up written recommendations. Financial planning is an iterative process that requires
regular realignment based on updated client needs, objectives, opportunities, risks, and available
options that arise from clients’ evolving life circumstances.
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Life Impact® Stewardship Planning Services
Life Impact Stewardship Planning is a service provided in addition to financial planning services which
focuses on the other aspects of a person or family’s life. The process is used to assist clients with aligning
their purpose, calling and values with all aspects of their life.
4. Consulting Services
EverSource Advisors’ Consulting Services complement Financial Planning Services and leverage
EverSource’s network of internal and external subject matter experts. Advisors assist clients with
unique projects and analysis to help them achieve specific objectives related to other financial
and life planning needs. Examples include business succession planning, resource stewardship,
estate planning, charitable and philanthropic planning, asset protection planning, family
dynamics and conflict resolution, and business and executive compensation.
EverSource has a relationship with Mutual Securities, Inc. (“MSI”), an unaffiliated broker-dealer
(member FINRA, MSRB and SIPC), under which EverSource provides investment consulting
services to certain of MSI’s clients (“Brokerage Customers”) who have requested that EverSource
provide those services. Brokerage Customers enter into a client agreement with EverSource for
these consulting services and, in most cases, also engage EverSource for investment advisory
services on separate assets managed by EverSource or its IARs. Consulting services include such
areas as diversification, risk tolerance, investment strategy, cash flow, estate planning and
anticipated future needs.
C. Customized Services
EverSource IARs tailor the financial planning process and recommended solutions for each client
based on personal life and family circumstances. IARs are also able to tailor investment
portfolios for clients, including establishing restrictions and limitations on investing in certain
securities or security-types based on the client’s unique objectives and values.
D. Wrap Fee Programs
A team of EverSource in Birmingham, Alabama previously offered a Wrap Fee Program, under
which investment advisory fees, transaction fees, and custodial broker-dealer commissions are
bundled into a single “Wrap Fee”. While that team does not offer that program to new clients,
existing wrap fee program participants are permitted to remain in the program. The objective of
that Wrap Fee program is for EverSource to cover commissions resulting from trades in client
accounts without increasing the fee clients would otherwise pay. In March 2024, a team of
advisors in Fairfax, Virginia joined EverSource and will offer the “Clarion Wrap Fee” to all of its
clients.
Please refer to EverSource’s Form ADV Part 2A – Appendix 1 (“Wrap Fee Program Brochure”)
for a full disclosure of the existing grandfathered wrap fee program and the Clarion Wrap Fee
EverSource Wealth Advisors | Form ADV Part 2A | March 8, 2024 Page 10
Program, including conflicts of interest. EverSource receives a portion of the revenue generated
by its advisors, which includes revenue from the Wrap Fee programs.
E. Assets Under Management
As of December 31, 2023, EverSource’s assets under management were as follows:
Assets Managed on Discretionary Basis $2,625,200,178
Assets Managed on Non-Discretionary Basis $69,161,482
Total Assets Under Management $2,694,361,660