This Disclosure document is being offered to you by Avera Capital Wealth Management,
LLC (“ACWM” or “Firm”) about the investment advisory services we provide. It discloses
information about our services and the way those services are made available to you, the
client.
We are an investment management firm located in Grand Junction, Colorado. We
specialize in investment advisory services for individuals, high net worth individuals,
employee sponsored retirement plans, and government entities. Our Firm became a
registered investment adviser in June 2021. Alex Maurer and Adam Camacho are Managing
Members of the Firm. Alex Maurer is the Chief Compliance Officer.
We are committed to helping clients build, manage, and preserve their wealth, and to
provide assistance that helps clients to achieve their stated financial goals. We will offer an
initial complimentary meeting upon our discretion; however, investment advisory services
are initiated only after you and ACWM execute an Investment Management Agreement.
Investment Management Services
We manage advisory accounts on a discretionary and non-discretionary basis. For
discretionary accounts, once we have determined a profile and investment plan with a
client, we will execute the day-to-day transactions without seeking prior client consent.
Account supervision is guided by the written profile and investment plan of the client. We
may accept accounts with certain restrictions if circumstances warrant. We primarily
allocate client assets among various equities, Exchanged Traded Funds (“ETFs”), mutual
funds and debt securities in accordance with their stated investment objectives.
During personal discussions with clients, we determine the client’s objectives, time
horizons, risk tolerance and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. Based on client needs,
we develop a client’s personal profile and investment plan. We then create and manage
the client’s investments based on that policy and plan. It is the client’s obligation to notify
us immediately if circumstances have changed with respect to their goals.
Once we have determined the types of investments to be included in your portfolio and
allocated them, we will provide ongoing investment review and management services.
This approach requires us to periodically review your portfolio.
With our discretionary relationship, we will make changes to the portfolio, as we deem
appropriate, to meet your financial objectives. We trade these portfolios based on the
combination of our market views and your objectives, using our investment process. We
tailor our advisory services to meet the needs of our clients and seek to ensure that your
portfolio is managed in a manner consistent with those needs and objectives. You will have
the ability to leave standing instructions with us to refrain from investing in particular
industries or invest in limited amounts of securities.
If a non-discretionary relationship is in place, calls will be placed to the client presenting
the recommendation made including a rebalancing recommendation and only upon your
authorization will any action be taken on your behalf.
We do have limited authority to direct the Custodian to deduct our investment advisory
fees from your accounts, but only with the appropriate written authorization from you.
Where appropriate, we provide advice about any type of legacy position held in client
portfolios. Typically, these are assets that are ineligible to be custodied at our primary
custodian. Clients will engage us to advise on certain investment products that are not
maintained at their primary custodian, such as annuity contracts and assets held in
employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that adversely affect
an account’s performance. This could result in capital losses in your account.
Third-Party Managers
ACWM may provide investment advice and recommendations based on the investment
strategies of Third-Party Managers (“Managers” or “TPM”). Selected Managers are
evaluated by ACWM for client use. (See more about Third Party Managers in Item 8 below).
Our services include assisting you in identifying your investment objectives and matching
personal and financial data with a select list of Managers. The intent of this service is to
have a selected list of high quality and recognizable third-party investment management
firms from which you select one or more Managers to handle the day-to-day management
of your account(s). Managers selected for your investments need to meet several
quantitative and qualitative criteria established by ACWM. Among the criteria that may be
considered are the Manager’s experience and regulatory record, assets under
management, performance record, client retention, the level of client services provided,
investment style, buy and sell disciplines, capitalization level, and the general investment
process. Information collected by our firm regarding Managers is believed to be reliable
and accurate, but ACWM does not necessarily independently review or verify it on all
occasions.
Following recommendations by our Investment Adviser Representatives (“IAR”), you will
have final authority to select a Manager. The IAR will assist you in completing appropriate
documents. ACWM IARs assist clients with identifying their risk tolerance and investment
objectives. IARs will recommend TPMs in relation to the client’s stated investment
objectives and risk tolerance. A client may select a recommended TPM based upon the
client’s needs. Clients will enter a Third-Party Advisory Program Agreement directly with
ACWM.
You are advised and should understand that:
• A Manager’s past performance is no guarantee of future results;
• There is a certain market and/or interest rate risk which may adversely affect
any Manager’s objectives and strategies, and could cause a loss in a Client's
account(s); and
• Client risk parameters or comparative index selections provided to ACWM
are guidelines only and there is no guarantee that they will be met or not
be exceeded.
ACWM IARs shall be available to answer questions the client may have regarding their
account and act as the communication conduit between the client and the Manager.
Managers may take discretionary authority to determine the securities to be purchased
and sold for the client. Neither ACWM nor its associated persons will have any trading
authority with respect to clients’ managed account with the TPM(s).
All accounts are managed by the selected Manager and ACWM does not have any
discretionary trading authority with respect to such accounts. All performance reporting
will be the responsibility of the respective Manager. Such performance reports will be
provided directly to you and ACWM. ACWM does not audit or verify that these results are
calculated on a uniform or consistent basis as provided by a manager directly to ACWM or
through the consulting service utilized by the Manager.
ACWM has entered into agreements with various independent Managers. Under these
agreements, ACWM offers client’s various types of programs sponsored by these
Managers. All third-party Managers to whom ACWM will refer clients will be licensed as
registered investment advisors by their resident state and any applicable jurisdictions
or
registered investment advisors with the Securities and Exchange Commission.
Third-party managed programs generally have account minimum requirements that will
vary from investment advisor to investment advisor. Account minimums are generally
higher on fixed income accounts than equity-based accounts. A complete description of
the Manager’s services, fee schedules and account minimums will be disclosed in the
Manager’s Form ADV or similar Disclosure Brochure which will be provided to clients at the
time an agreement for services is executed and account is established.
Financial Planning
Through the financial planning process, our team strives to engage our clients in
conversations around the family’s goals, objectives, priorities, vision, and legacy – both for
the near term as well as for future generations. With the unique goals and circumstances
of each family in mind, our team will offer financial planning ideas and strategies to address
the client’s holistic financial picture, including estate, income tax, charitable, cash flow,
wealth transfer and family legacy objectives. Our team partners with our client’s other
advisors (CPA, estate attorney, insurance broker, etc.) to ensure a coordinated effort of all
parties toward the client’s stated goals. Such services include various reports on specific
goals and objectives or general investment and/or planning recommendations, guidance
to outside assets and periodic updates.
Our specific services in preparing your plan may include:
• Review and clarification of your financial goals;
• Assessment of your overall financial position including cash flow, balance sheet,
investment strategy, risk management and estate planning;
• Creation of a unique plan for each goal you have, including personal and business
real estate, education, retirement or financial independence, charitable giving,
estate planning, business succession and other personal goals;
• Development of a goal-oriented investment plan, with input from various advisors
to our clients around tax suggestions, asset allocation, expenses, risk and liquidity
factors for each goal. This includes IRA and qualified plans, taxable and trust
accounts that require special attention;
• Design of a risk management plan including risk tolerance, risk avoidance,
mitigation and transfer, including liquidity as well as various insurance and
possible company benefits; and
• Crafting and implementation of, in conjunction with your estate and/or corporate
attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the
event of an incapacity or death.
A written evaluation of each client's initial situation or Financial Plan is provided to the
client.
Employer Sponsored Retirement Plan Services
Retirement Plan Advisory Services consists of helping employer plan sponsors to establish,
monitor and review their company's retirement plan. As the needs of the plan sponsor
dictate, areas of advising could include investment selection and monitoring, plan
structure, and participant education. Pursuant to Section 402(c)(3) of ERISA, the client may
appoint us as the Plan’s “investment manager” with respect to the Plan’s portfolio of
investment options. Our firm acts as a “fiduciary” within the meaning of Section 3(21) of
ERISA with respect to the Plan.
When serving as an ERISA 3(21) investment adviser, the Plan Sponsor and our Firm share
fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for
the investments and may accept or reject the recommendations in accordance with the
terms of a separate ERISA 3(21) Plan Sponsor Investment Management Agreement
between our Firm and the Plan Sponsor. Under the 3(21) agreement, our Firm can provide
the following services to the Plan Sponsor:
• Review or Development of an Investment Policy Statement
• Perform Due Diligence on Money Managers
• Provide Initial Investment and Management Selection - Our Firm typically uses
mutual funds/managed accounts/collective trusts/cash equivalents to structure
portfolios designed to meet client objectives and risk profiles.
• Provide ongoing Performance Evaluation and Monitoring of Money Managers
• Make Investment Recommendations when necessary
• Retirement Plan Services Analysis - Our Firm will conduct an analysis of a client’s
retirement plan to evaluate the services currently provided to the client by third
parties. The areas of analysis may include asset management services, record
keeping, administration, customer service, participant education, etc. These
services may also include a cost/benefit analysis, recommendation of alternative
vendors, facilitation of the RFP process for solicitation of a new vendor, and/or
assistance in fee negotiations with proposed vendors.
• Provide Employee Education Services - Our Firm will provide enrollment and
educational services the content of the program will be generic in nature.
Participant one-on-ones
We can also be engaged to provide financial education to plan participants. The scope of
education provided to participants will not constitute “investment advice” within the
meaning of ERISA and participant education will relate to general principles for investing
and information about the investment options currently in the plan.
As part of our investment advisory services, our Investment Adviser Representative (“IAR”)
can make recommendations to plan participants regarding the rollover of employer
sponsored retirement plan assets. In the case where an IAR recommends a retirement plan
rollover into our individual wealth management advisory program, the IAR will earn a
portion of the advisory fee. This presents a conflict of interest because IARs have an
economic incentive to recommend you to rollover your retirement plan assets into our
individual wealth management services at our Firm. Plan participants are under no
obligation to rollover retirement plan assets to an IRA with our Firm and should carefully
consider all relevant factors, such as penalty-free withdrawals, whether loans are
permitted, legal protections, required minimum distributions, fees and expenses, service
levels, available investment options, employer stock considerations and state taxes.
Consulting Services
We also provide clients investment advice on a more-limited basis on one-or-more isolated
areas of concern such as small business consulting, real estate, retirement planning, or any
other specific topic. Additionally, we provide advice on non-securities matters about the
rendering of estate planning, insurance, real estate, and/or annuity advice.
In these cases, you will be required to select your own investment managers, custodian
and/or insurance companies for the implementation of consulting recommendations. If
your needs include brokerage and/or other financial services, we will recommend the use
of one of several investment managers, brokers, banks, custodians, insurance companies
or other financial professionals. You must independently evaluate these firms before
opening an account or transacting business, and you have the right to effect business
through any firm you choose. Also note, you have the right to choose whether to follow
the consulting advice that we provide.
Wrap Fee Programs
Our Firm does not sponsor a Wrap Fee Program.
Assets
As of December 31, 2023, we have $132,708,438 of discretionary assets under
management and $0 of non-discretionary assets under management.