Description of Firm
Premier Private Wealth, LLC ("Premier") is a registered investment adviser located in
Franklin, TN. We are organized as a limited liability company ("LLC") under the laws of
the State of TN. We have been providing investment advisory services since June 2021.
The firm is primarily owned by Michael R. Comstock and Julie D. Comstock.
The following paragraphs describe our services and fees. Refer to the description of
each investment advisory service listed below for information on how we tailor our
advisory services to your individual needs. As used in this brochure, the words "we,"
"our," and "us" refer to Premier Private Wealth, LLC and the words "you," "your," and
"client" refer to you as either a client or prospective client of our firm.
Portfolio Management Services
We offer discretionary portfolio management services. Our investment advice is tailored to meet
our clients' needs and investment objectives.
If you participate in our discretionary portfolio management services, we require you to
grant our firm discretionary authority to manage your account. Discretionary authorization
will allow us to determine the specific securities, and the amount of securities, to be
purchased or sold for your account without your approval prior to each transaction.
Discretionary authority is typically granted by the investment advisory agreement you sign
with our firm and the appropriate trading authorization forms.
We have entered into an agreement to offer clients access to certain programs offered by
Commonwealth Financial Network® ("Commonwealth"), a FINRA-registered broker-dealer
and SEC-registered investment adviser. Specifically, Commonwealth's PPS Custom
Account Program, PPS Select Account Program and PPS Direct Account Program are
offered. In the case of the PPS Custom Account Program, we will assist you in the
development of personalized asset allocation programs. In the case of the PPS Select
Account Program, we will assist you in selecting a portfolio option appropriate for your risk
tolerance, while portfolio management is provided by Commonwealth's Investment
Management and Research team. In the case of the PPS Direct Account Program, we
offer the services of approved money management firms referred to as "Sub-Advisors" to
assist in managing Client portfolios. Clients who participate in one or more of
Commonwealth's PPS Programs will receive Commonwealth's Form ADV Part 2 and/or
Wrap Fee Brochure, in addition to the Premier Form ADV Part 2. Clients should refer to
Commonwealth's Form ADV Part 2 and/or Wrap Fee Brochure for detailed information
about Commonwealth and Commonwealth's PPS Programs.
Premier and Commonwealth are not affiliated.
As part of our portfolio management services, we may use one or more sub-advisers to
manage a portion of your account. The sub-adviser(s) may use one or more of their
model portfolios to manage your account. We will regularly monitor the performance of
your accounts managed by sub- adviser(s). The sub-adviser(s) will charge a separate
fee in addition to our fee.
As part of our portfolio management services, in addition to other types of investments
(see disclosures below in this section), we may invest your assets according to one or
more model portfolios developed by our firm. These models are designed for investors
with varying degrees of risk tolerance ranging from a more aggressive investment strategy
to a more conservative investment approach. Clients whose assets are invested in model
portfolios may not set restrictions on the specific holdings or allocations within the model,
nor the types of securities that can be purchased in the model.
Commonwealth Consulting Programs
Premier Private Wealth has entered into an agreement with Commonwealth to offer
Commonwealth’s Wealth Management Consulting and Retirement Plan Consulting programs.
Wealth Management Consulting Services
We offer wealth management consulting services which typically involve providing a
variety of advisory services to clients regarding the management of their financial
resources based upon an analysis of their individual needs. These services can range
from broad-based financial planning to consultative or single subject planning that
primarily involves advising clients on specific financial-related topics. The topics we
address may include, but are not limited to, investment analysis, education planning,
individual retirement plan benefits review, retirement income planning and/or investment
tax analysis. If you retain our firm for wealth management consulting services, we will
meet with you to gather information about your financial circumstances and objectives.
We may also use financial planning software to determine your current financial position
and to define and quantify your long-term goals and objectives. Once we specify those
long-term objectives (both financial and non-financial), we will develop shorter-term,
targeted objectives. Once we review and analyze the information you provide to our firm
and the data derived from our financial planning software, we will deliver a written plan to
you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to
you, and on the financial information you provide to us. You must promptly notify our firm
if your financial situation, goals, objectives or needs change.
You are under no obligation to act on our wealth management consulting
recommendations. Should you choose to act on any of our recommendations, you are
not obligated to implement the financial plan through any of our other investment
advisory services. Moreover, you may act on our recommendations by placing
securities transactions with any brokerage firm.
Retirement Plan Consulting Services
We offer retirement plan consulting services to employee benefit plans and their
fiduciaries based upon the needs of the plan and the
services requested by the plan
sponsor or named fiduciary. In general, these services may include an existing plan
review and analysis, plan-level advice regarding fund selection and investment options,
education services to plan participants, investment performance monitoring and/or
ongoing consulting. These retirement plan consulting services are non-discretionary and
advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the
plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-
related educational seminars to plan participants on such topics as:
Diversification;
Asset allocation;
Risk tolerance; and
Time horizon
Our educational seminars may include other investment-related topics specific to the particular
plan.
We may also provide additional types of retirement plan consulting services to plans on an
individually negotiated basis. All services, whether discussed above or customized for the
plan based upon requirements from the plan fiduciaries (which may include additional
plan-level or participant-level services) shall be detailed in a written agreement and be
consistent with the parameters set forth in the plan documents.
Either party to the retirement plan consulting agreement may terminate the agreement
upon written notice to the other party in accordance with the terms of the agreement
for services. The retirement plan consulting fees will be prorated for the quarter in
which the termination notice is given and any unearned fees will be refunded to the
client.
Selection of Other Advisers
When appropriate, we refer clients to the PPS Select Program, a Third-Party Money Manager
(TPMM), and/or other outside managers, for asset management services. Depending on your
needs and circumstances we will recommend that you use the services of a TPMM to manage
all, or a portion of, your investment portfolio. After gathering information about your financial
situation and objectives, we will recommend that you engage a specific TPMM or investment
program. Factors that we take into consideration when making our recommendation(s) include,
but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your
financial needs, investment goals, risk tolerance and investment objectives. We will monitor the
TPMM(s)' performance to ensure its management and investment style remains aligned with
your investment goals and objectives.
The TPMM(s) will actively manage your portfolio and will assume discretionary investment
authority over your account. With some TPMM programs, we will assume discretionary authority
to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem such
action appropriate.
The TPMM must be appropriately licensed as an Investment Adviser with the U.S. Securities
and Exchange Commission or state(s) in which they conduct business.
Family Office and Wealth Planning Services
We offer Family Office and Wealth Planning Services designed to help our clients organize their
financial situation and plan for the successful transfer of wealth to the next generation in
the most tax-advantaged manner. Such services generally include assistance or advice in
the following areas:
Family Continuity;
Estate Planning and Trustee Oversight;
Integrated Tax and Financial Planning;
Lifestyle Management;
Personal Assistant;
Family Philanthropy; and
Risk Management
Types of Investments
We primarily offer advice on ETFs and Mutual Funds. Refer to the Methods of Analysis,
Investment Strategies and Risk of Loss below for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals
and objectives. We may also provide advice on any type of investment held in your portfolio at
the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial
situation, the investment advice we provide to you may be different or conflicting with
the advice we give to other clients regarding the same security or investment.
Wrap Fee Programs
Premier Private Wealth, LLC does not sponsor any wrap fee programs. As disclosed
above, we may refer clients to Commonwealth’s PPS Select program when appropriate.
PPS Select is a wrap fee program. Clients participating in PPS Select will receive
Commonwealth’s wrap fee program brochure.
Assets Under Management
As of December 31, 2022, Premier Private Wealth, LLC provides continuous management
services on a discretionary basis for approximately $227 million in client assets.
The specific advisory program you select may cost the client more or less than purchasing
program services separately. Factors that bear upon the cost of a particular advisory
program in relation to the cost of the same services purchased separately include, but may
not be limited to, the type and size of the account; the historical or expected size or number
of trades for the account; the types of securities and strategies involved; the amount of fees,
commissions, and other charges that apply at the account or transaction level; and the
number and range of supplementary advisory and client-related services provided to the
account. Lower fees for comparable services may be available from other sources.
Investment recommendations and advice offered by Premier Private Wealth and its
advisors do not constitute legal, tax, or accounting advice. You should coordinate and
discuss the impact of the financial advice you receive from your advisor with your attorney
and accountant. You should inform your advisory representative promptly of any changes
in your financial situation, investment goals, needs, or objectives. Failure to notify your
advisory representative of any material changes could result in investment advice not
meeting your changing needs.