Description of Firm GWN Securities, Inc. ("GWN Securities") is a Florida corporation headquartered in Palm Beach Gardens, Florida. We have been in business since 2004 and we are registered with the SEC as an investment adviser. We are also registered with the SEC and all 50 states and the District of Columbia as a broker-dealer. As a broker-dealer, we are a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). We are directly owned by World Investment Network, Inc.
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 GWN Securities Inc. and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. "IAR" refers to your financial professional (also known as an investment adviser representative) in their role of providing investment advice on behalf of GWN.
Managed Accounts We offer discretionary portfolio management services in managed accounts offered through our IARs and various independent sub-advisers. Our investment advice is tailored to meet our clients' needs and investment objectives. If you participate in our Managed Account Program, we require you to grant our firm discretionary authority to manage each of your accounts. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for each of your accounts 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 required by the custodian and sub-adviser, if applicable.
As part of our portfolio management services, we may use one or more sub-advisers to manage a portion of your account which will also be on a discretionary basis. Each selected sub-adviser uses 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) and may hire and fire any sub-adviser without your prior approval. Our IARs will regularly monitor the performance of your accounts managed by a sub-adviser, and the IAR may hire and fire any sub-adviser without your prior approval, as long as the new sub-adviser participates in the same managed account and the IAR chooses a new sub- adviser that remains within your risk tolerance and investment objectives. We may pay a portion of our advisory fee to the sub-advisers we use; however, you will not pay our firm a higher advisory fee as a result of any sub-advisory relationships. A change in the sub-advisor managing your account can increase the fees you pay if the new sub-adviser charges more than the originally selected sub-adviser but you must sign a new advisory agreement if that occurs. You will be notified before you are charged additional fees based on the new sub-adviser.
As previously mentioned, we may invest your assets according to one or more model portfolios developed by the selected sub-adviser(s). In most, but not all, cases, the sub-adviser is unaffiliated with GWN. 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 for most programs. Some portfolios are managed by your IAR and not a sub-adviser. These portfolios are sometimes referred to as "Advisor as Portfolio Manager" or "Rep as Portfolio Manager" accounts.
4 If the client is participating in our Total Access or our Premier Choice Programs restrictions can be placed on the management of the assets. Not all managed accounts offered by other advisers prohibit you from placing restrictions on the management of your account. For more information, refer to the Investment Discretion section 16.
Prior to client entering into the "Advisory Agreement." GWN's IAR will discuss with the client the risks and potential benefits of the Program, the Program's investment strategy, and the Program investments. Clients may complete an Investor Profile Worksheet, which assists the Representative in determining which of the available programs is best suited for the client. Based upon the information provided by the client, the Representative will assist the client in selecting a suitable Program and then work with the client to designate one or more of the portfolios offered through the third-party portfolio managers available through the Program.
Client will grant the Program portfolio manager full authority and investment discretion to manage the client's account according to the terms of the GWN Premier Program, the particular portfolio the client selects, and the mutual fund families, ETF funds or sub-accounts of a variable product the client has designated for the account to be managed through the Program. The portfolio manager will have the authority and discretion to buy, sell, exchange, redeem, or otherwise effect transactions with respect to the client's account and the assets of the account, to accept or reject any signals, in whole or in part, and to allocate and reallocate the account, as the portfolio manager deems appropriate, in its sole discretion, without prior notice or consent of client.
Upon GWN approval, the portfolio manager may also change investment strategy of a portfolio, change the allocations or weightings of a portfolio, or close and liquidate a portfolio, and may change the mutual fund families, ETF funds or variable products approved for the portfolio, without prior notice or consent of client. GWN will notify client of material changes made to a strategy or portfolio, or the investment options approved for a portfolio, and will manage the account as explained in the notice unless client objects within the time period specified in the notice.
No commissions or 12b-1 fees are earned by GWN Securities on any assets held in advisory accounts with these exceptions:
•New deposits made to legacy accounts with SBG or Valic will pay compensation (commissions) to GWN in its capacity as a broker-dealer. New deposits into an existing variable annuity contract that originally paid a commission will also pay commissions on the new deposit to GWN in its capacity as a broker-dealer. These legacy accounts are in the SAM and Premier programs. Managed Accounts The following sub-sections provide an overview of our Managed Accounts: 1) the GWN Managed Account Program, 2) the GWN Premier Program, 3) the GWN Total Access Program, and 4) the FMAX Program. 1. GWN Managed Account Program Through the GWN Managed Account Program, GWN offers investment management services designed for clients with assets invested directly with a mutual fund family or insurance company that permits exchanges among the individual funds offered by the mutual fund family or among the sub- accounts of a variable annuity or variable life insurance contract (collectively, "variable products"). GWN believes that allocating investments among funds and sub-accounts may provide diversification and reduce portfolio volatility.
5 To serve the investment needs of these clients, the portfolio managers of the GWN Managed Account subprograms have constructed their respective portfolios from mutual funds and sub-accounts of variable products of various investment styles, assets classes, and objectives, including income, growth and income, growth, international growth, and international income. The subprograms offer differing investment strategies to manage their respective portfolios. The portfolio manager for each subprogram determines the specific asset allocation and weightings of the portfolios he/she manages. GWN periodically reviews the allocations and weightings for consistency with portfolio objectives.
Clients are not required or expected to purchase a variable product to participate in the Program; however, certain investments may only be available as sub-accounts of a variable product. Additionally, the Program's portfolios are limited to certain mutual fund families and variable products, which will likely change from time to time. The IAR will explain the fund families and variable products that are currently eligible for the GWN Managed Account Program, and each of the portfolios.
Please refer to Item 5 for further information about compensation the Representative will receive if you purchase securities or insurance products. Prior to client entering into the "Advisory Agreement" for the GWN Managed Account Program, GWN's investment adviser representative assigned to the Account (the "Representative") will discuss with the client the risks and potential benefits of the Program, the Program's investment strategy, and the Program investments. Clients may complete an Investor Profile Worksheet, which assists the Representative in determining which model is best suited for the client. Based upon the information provided by the client, the Representative will assist the client to designate one or more of the portfolios available in the Program and identify the eligible mutual fund families or variable annuities through which the client's Program account will be invested.
Although the Representative will assist the client to understand the available options and portfolios available through the GWN Managed Account Program, the Representative is not responsible for providing on-going investment advice for the account or for managing the assets of the account. Accounts are managed by a designated portfolio manager.
Client will grant the Program portfolio manager full authority and investment discretion to manage the client's account according to the terms of the Program, the particular portfolio the client selects, and the mutual fund families or sub-accounts of a variable product the client has designated for the account to be managed through the Program. The portfolio manager will have the authority and investment discretion to buy, sell, exchange, redeem, or otherwise effect transactions with respect to the client's account and the assets of the account, to accept or reject any signals, in whole or in part, and to allocate and reallocate the account, as the portfolio manager deems appropriate, in its sole discretion, without prior notice or consent of client.
Upon GWN approval, the portfolio manager may also change investment strategy of a portfolio, change the allocations or weightings of a portfolio, or close and liquidate a portfolio, and may change the mutual fund families or variable products approved for the portfolio, without prior notice or consent of client. GWN will notify client of material changes made to a strategy or portfolio, or the investment options approved for a portfolio, and will manage the account as explained in the notice unless client objects within the time period specified in the notice. 6 Limitation on Changes to Models These Programs allow the client to choose more than one model portfolio for the client's account and permit the client to specify the percentage of the account to be allocated to each model. However, the client cannot change or impose restrictions on the underlying allocations within each model portfolios the client selects.
GWN Managed Account Program Sub-Advisers Each of the subprograms in the GWN Managed Account Program is managed by a sub-adviser engaged by GWN. The SAM, HDSAM Direct and StAR 1.0 Direct Programs are managed by an investment adviser representative of GWN Securities and not by an independent sub-adviser. The IARs or sub-advisers for the GWN Managed Account Programs (depending on the selected program) are responsible for determining the specific model portfolios, the selection of the mutual funds or other securities in which the account will invest to reflect the model, and for the periodic adjustment of the models to achieve each portfolio's objective and risk profile. GWN is responsible for the periodic rebalancing of each account in a portfolio to reflect the current portfolio allocation and mutual funds designated by the Sub-adviser for each portfolio. The Sub-advisers are compensated from a share of the Program Fees that are paid by the client for participating in the GWN Managed Account Program, and are also compensated from the purchase or sale of any securities occurring to reflect the model portfolio, including from the initial allocation of the account and subsequent rebalancing of the account to reflect to the model portfolio or any adjustments to the model.
2. GWN Premier Program The GWN Premier Program is also a Managed Account comprised of the GWN Premier Select, GWN MAP Program and GWN Premier Choice Programs, and the Money by Design Platinum Advisory Program ("Platinum Program").
GWN Premier Select Program The GWN Premier Select Program is managed by Money Concepts, a registered investment adviser under common ownership with GWN Securities. GWN Premier Select is an allocation program offering various models comprised of ETFs, no-load and load-waived mutual funds developed by selected institutional investment managers.
Each model will have a recommended allocation as well as a list of suitable investment selections by category, allowing the client and the IAR to customize the model to the specific needs and objectives of the client.
Clients interested in the GWN Premier Select Program will be allowed to choose from a series of computer-based, asset allocation models based on risk tolerance. GWN Premier Select Models are categorized as Ultra Conservative, Conservative, Balanced, Moderate, Growth Appreciation and Maximum Appreciation. GWN Premier Select Portfolios are based on the Modern Portfolio Theory.
Please refer to Item 8 for further explanation of Modern Portfolio Theory. All funds are purchased at net asset value (NAV) for the GWN Premier Select Program. Certain GWN Select Program Portfolios are available for non-qualified and qualified assets. Qualified assets may be separately established in an IRA, 403(b)(7) or qualified plan. The schedule would apply to each separate plan established. No commissions or 12b-1 fees are earned by GWN Securities for accounts in the GWN Premier Select Program. 7 Once the client and IAR have selected a suitable program and portfolio through the GWN Premier Select Program, management of the account and Program portfolios will be the responsibility of the portfolio manager. Your IAR will be responsible for periodic contact with you to determine any changes in your investment objectives or other suitability information, and to answer your questions about the Program. However your IAR will not provide ongoing investment advice or recommendations regarding the account or manage the account(s). The portfolio manager is responsible for managing all accounts in the Premier Select Program.
GWN Premier Choice Program The GWN Premier Choice Program permits an individual and an IAR of GWN Securities to design and implement a diversified mutual fund and ETF fund portfolio tailored to the individual's needs. All mutual funds and ETF funds are purchased at net asset value (NAV). All mutual funds and ETF funds are purchased at net asset value (NAV) and no commissions or 12b-1 fees are earned by GWN Securities.
Premier Choice is available for non-qualified and qualified assets. Qualified assets may be separately established in an IRA, 403(b)(7), or a qualified plan.
The Premier Choice Program is not offered by promoters (formerly solicitors). The Premier Choice Program can only be offered by IARs of GWN. Clients receive advice and guidance regarding investment decisions from your IAR while maintaining complete discretion over investment decisions in your account. GWN Securities receives a portion of the total fee paid by the client for providing advisory services. Clients participating in the Castellum Select and Premier Choice programs are required to establish custodial accounts with a third-party broker-dealer, such as Fidelity Institutional Wealth Services (or another affiliate of Fidelity, Inc., "Fidelity") or other custodian that may be required and approved by GWN.
GWN MAP Program The GWN MAP Program ("MAP Program") is also part of the GWN Premier Program. The MAP Program is an asset allocation program utilizing a wide selection of mutual funds and ETF funds which provides an individual the opportunity to choose among a series of computer-based asset allocation models based on risk tolerance or leverage multiple portfolio managers available on the platform. Clients interested in the GWN MAP Program will be allowed to choose from a series of computer- based, asset allocation models based on risk tolerance.
All funds are purchased at net asset value (NAV) for the MAP Program. Certain GWN MAP Program Portfolios are available for non-qualified and qualified assets. Qualified assets may be separately established in an IRA, 403(b)(7) or qualified plan. The schedule would apply to each separate plan established. No commissions or 12b-1 fees are earned by GWN Securities for accounts in the GWN MAP Program.
Once the client and IAR have selected a suitable program and portfolio through the GWN MAP Select Program, management of the account and Program portfolios will be the responsibility of the portfolio manager Your IAR will be responsible for periodic contact with you to determine any changes in your investment objectives or other suitability information, and to answer your questions about the Program.
However, your IAR will not provide ongoing investment advice or recommendations regarding the account or manage the account(s). The portfolio manager is responsible for managing all accounts in the GWN MAP Program.
There are multiple portfolio managers engaged as sub-advisers to the Program and are responsible for day-to-day management of the portfolios assigned to them. Some sub-advisers in the MAP Program are unaffiliated with GWN but some are affiliated with GWN. 8 Money by Design Platinum Advisory Program The Money by Design Platinum Advisory Program ("Platinum Program") is also part of the GWN Premier Program. The investment objective is to seek capital appreciation and provide current income.
This Program utilizes computerized modeling and employs technical, economic, fiscal, and monetary considerations to determine whether individual market trends are considered to be advancing or declining. The basic concept underlying these services is commonly known as asset allocation. The advisor intends to allocate investments between and among the funds available in weightings dictated by the investment advisory committee. The advisor will continuously monitor the investments and adjust holdings in the individual funds in an effort to meet its investment objectives.
Money by Design is an asset allocation program utilizing a wide selection of mutual funds and ETF funds which provides an individual the opportunity to choose from a series of computer-based asset allocation models based on risk tolerance. Accounts in the Money by Design Program are qualified accounts for individual participants with self-directed accounts and are limited to a specific group of IARs. The Program is not open to all accounts.
There are two tiers of portfolio managers, and one or more separate portfolio managers for each tier who are engaged as sub-advisers to the Program and are responsible for day-to-day management of the portfolios assigned to them. Some sub-advisers in the Platinum Program are unaffiliated with GWN but Money by Design and Castellum are affiliated with GWN. Tier 1 Sub-Advisors
•GWN Castellum Select Portfolios*
•GWN Castellum Select ETF Portfolios*
•Platinum Advisory Select*
•BlackRock, Inc. ETF Portfolios
•Platinum Vanguard ETF Portfolios
•American Funds Models
•ICON Advisers, Inc.
•CLS Investments
•Portfolio Strategies, Inc. (PSI)
•Russell Investments
•Main Management, LLC
•Toews Asset Management Tier 2 Sub-Advisors
•Absolute Capital
•Advanced Asset Management Advisors, Inc. (AAMA)
•Donoghue Forelines
•Frontier Asset Management
•Clark Capital Management *GWN Castellum Select Portfolios, GWN Castellum Select ETF Portfolios and Platinum Advisory Select are sub-advisers affiliated with GWN.
No commissions or 12b-1 fees are earned by GWN Securities for accounts in the Money by Design Platinum Advisory Program. 9 3. GWN Total Access Program The GWN Total Access Program is only offered by a limited number of IARs, so client availability is limited. The GWN Total Access Program permits an individual and a Representative to allocate the client's portfolio into general securities, no-load and load-waived funds at net asset value and other investments. Pershing, LLC serves as the custodian for the GWN Total Access Program and provides administrative, brokerage, and custodial services for the advisory accounts.
A client participating in the GWN Total Access Program will pay an annualized fee in addition to transaction charges in accordance with the fee schedule. The fee will be payable quarterly in advance. The first payment is due upon execution of the Total Access Program Advisory Agreement and will be assessed pro rata in the event the Advisory Agreement is executed at any time other than the first day of the calendar quarter.
No commissions or 12b-1 fees are earned by GWN Securities for accounts in the GWN Total Access Program.
4. Fidelity Institutional Wealth Advisors Advisory Program (FMAX) The FMAX platform ("FMAX") is sponsored by Fidelity Institutional Wealth Advisors ("FIWA"). FMAX is a comprehensive wealth advisory platform that integrates planning, managed accounts, clearing and custody capabilities, and other third-party products and services into one technology supported solution. The investment products available through this platform include separately managed accounts, model portfolios, mutual funds, exchange-traded funds, individual equities and fixed income products. Although the FMAX program is supported by various technology platforms, these accounts are not managed strictly by algorithms or considered "robo-advice." The FMAX Advisory Programs allow clients and Representatives of GWN access to select one or more separately managed accounts ("SMA") or fund strategists (collectively, "Investment Managers") offered on the platform. FIWA is responsible for the due diligence of the Investment Managers available in the Program and the GWN Representative will select the appropriate Investment Manager(s) based on the predetermined client risk profile. Additional overlay portfolio management strategies are available to provide a customizable solution for clients with certain tax focus considerations or other individualized unique circumstances.
Clients participating in the FMAX Program will complete a risk tolerance questionnaire that will assist your Representative in creating an asset allocation tailored to your risk profile. Your Representative will have discretion to hire and fire Investment Managers within certain parameters discussed in more detail in the Fees and Compensation section below. The FMAX Program provides you with access to online performance reports.
The following sub-sections provide an overview of the FMAX Advisory Programs.
Fund Strategist Portfolios (FSP)

The FSP program provides access to a universe of professionally managed asset-allocated models composed of mutual funds and ETFs. These models are created by Investment Managers who determine the asset allocation and underlying investment selection for the various models, as well as ongoing portfolio changes. Each model is assigned a risk tolerance, allowing the Representative to view all available risk-appropriate models on the basis of the client's risk profile. Some models created by FIWA are also included in the FSP Program.
10 Separately Managed Accounts (SMA) The SMA program provides your Representative with access to a universe of investment style-specific professionally managed portfolios composed of individual securities. Representatives selecting the SMA Program have access to investment portfolios chosen from a roster of Investment Managers specializing in a variety of investment disciplines. Representatives may combine the SMA with mutual funds or ETFs in order to meet a client's personal asset allocation requirements. These SMA accounts are managed on a discretionary basis by the selected Investment Managers.
Unified Managed Accounts (UMA) The UMA Program enables Representatives to create personalized client portfolios within a single account. UMAs offer the ability to create unique investment "sleeves" within a single account (e.g., mutual fund and ETF sleeves, individual SMA manager sleeves and Fund Strategist sleeves) managed either by an Investment Manager or your Representative.
The Intermediary may also select a version of the UMA, whereby an Investment Manager will create a prepackaged asset allocation and investment solution ("Packaged UMA"), typically provided as a model. In this situation the Packaged UMA will be traded by the Implementation Manager.
Advisor Directions (AD) Separate from the Advisory Programs discussed above, FMAX AD provides risk-based portfolio management tools enabling Representatives to allocate the client's portfolio into general securities, no- load or load-waived funds and other investments that may be selected. This program includes portfolio modeling and diagnostic tools, enabling Representatives to act as portfolio managers and manage model portfolios for their clients. Other tools available to the Representatives include rebalancing, drift tolerance controls, and system-generated alerts related to drift and rebalancing.
No commissions or 12b-1 fees are earned by GWN Securities for accounts in the FMAX Program.
Programs Closed to New Investors The following programs are closed to new investors, although some existing clients have grandfathered accounts that remain active in the programs:
•DRM Program
•CyAM Direct Program
•SAM Direct Program
•MOM Direct Program
•StAR 1.0 Direct Program
•HDSAM Direct Program Clients should consider that the portfolio managers will invest in mutual funds that will carry up-front or contingent deferred sales charges, which will be an additional cost charged to the client's account. Although many clients in the Program will already own mutual funds or a variable product that provides "exchange" privileges within the fund family or variable product sub-accounts without charge, the portfolio manager will have the authority, when consistent with seeking the portfolio's objectives, to exchange the client's investments for shares to which the client's exchange privileges may not apply, or to redeem the client's investment in a fund and reinvest in a different fund family that will charge an up-front or contingent deferred sales charge.
Similarly, if the client wishes to add additional assets to be managed through the Program, the client will be required to pay the up-front sales charges (or contingent deferred sales charges) to purchase shares of the funds that comprise the account's particular portfolio. Similarly, if the client wishes to 11 participate in a program through sub-accounts of a variable product but does not already own a variable annuity or variable life insurance contract, the client will be required to purchase a variable annuity or variable life contract and will incur sales charges and other transaction expenses.
These programs no longer earn commissions and/or 12b-1 fees from the assets in your account(s).
SAM Legacy Accounts: New deposits made to legacy accounts with SBG or Valic will pay compensation (commissions) to GWN in its capacity as a broker-dealer. New deposits into an existing variable annuity contract that originally paid a commission will also pay commissions on the new deposit to GWN in its capacity as a broker-dealer. DRM Direct Program – Closed to New Investors The objectives of the DRM Direct Program are: (a) to preserve capital and (b) attain capital appreciation through a strategy of "market timing." A market timing strategy seeks to minimize unfavorable performance in a falling market and to provide appreciation possibilities in a rising market by investing and reinvesting the portfolio based on investment "signals" the portfolio manager identifies using computerized modeling and analysis of technical, economic, fiscal, and monetary factors.
A market timing strategy involves trading in and out of positions based on the signals and is not a "buy and hold" or long-term investment strategy (although there may be periods of months or longer that positions are held). Although the portfolio manager will generally follow the signals to manage accounts, the portfolio manager may, in its discretion, reject, delay implementation, or modify, in whole or in part, actions suggested by a signal and may engage in other transactions for client accounts, as the portfolio manager deems appropriate to achieve each portfolio's objective. There is no set minimum or maximum number of positions which will be held in a portfolio or specific frequency according to which portfolio positions will be traded.
The signals will determine the investment posture of each portfolio as either defensive or aggressive. The DRM "A" (Aggressive) portfolio and DRM "M" (Moderate) portfolio (collectively, the "DRM Portfolios") may utilize similar investments; however, DRM "A" will trend toward a more aggressive goal whereas DRM "M" will utilize a more moderate approach. GWN's intent is to have program accounts investing in funds emphasizing capital appreciation when the signals indicate a rising market and exchanging portfolio holdings for cash or money market funds during declining markets.
Accounts in the DRM Direct Program are managed by Allen Fred Secor of Dynamic Assets Management, an affiliated investment adviser representative.
CyAM Direct Program – Closed to New Investors CyAM "A" and CyAM "M" portfolios will determine investment allocation percentages based on momentum trends. CyAM "A" (Aggressive) accounts will remain invested until modeling programs trigger a move by the underlying portfolio. For CyAM "M" (Moderate) accounts, investment changes will occur based on modeling programs and will trigger a complete movement of investments. The portfolio manager's determination of "Asset Momentum" will determine investment allocation percentages based on momentum trends. Asset Momentum investments will remain invested until modeling programs trigger a change in the underlying portfolios. CyAM "A" and CyAM "M" may utilize equity, fixed income, or money market funds or sub-account positions or a combination of these positions, as determined by its modeling program.
Accounts in the CyAM Direct Program are managed by Allen Fred Secor of Dynamic Assets Management, an affiliated investment adviser representative. 12 SAM Direct Program – Closed to New Investors SAM "A" and SAM "M" will determine allocation investment percentages based on asset classes. SAM "A" (Aggressive) and SAM "M" (Moderate) may utilize similar asset classes for the underlying investments; however, SAM "A" will trend towards a more fully invested program. SAM "M" may utilize more fixed income or money market positions to minimize volatility.
Accounts in the SAM Direct Program are managed by David Hornard of Castellum, an investment adviser representative of Money Concepts, an affiliate of GWN.
StAR 1.0 Direct Program – Closed to New Investors The StAR 1.0 Direct Program primarily uses a momentum analysis, with a secondary filter applied that measures velocity, to evaluate the securities to be included (or excluded) in the model portfolios. The Program will then rank the available investment options based on the results of such analysis to help determine the investments selected for the model portfolios. Momentum Analysis is an indicator used in technical analysis that determines overbought and oversold conditions of a particular asset. This indicator is very similar to the relative strength index (RSI). The main difference between the two is that the RSI uses a fixed number of time periods (usually 14), while the dynamic momentum analysis uses different time periods as volatility changes.
Accounts in the StAR 1.0 Direct Program are managed by Don Puff of DJ Puff Advisors, an affiliated investment adviser representative.
MOM Direct Program – Closed to New Investors The MOM Direct Program primarily uses a momentum analysis. Momentum Analysis is an indicator used in technical analysis that determines overbought and oversold conditions of a particular asset. Individual investments will remain invested until modeling programs trigger a move by the underlying portfolio.
Accounts in the MOM Direct Program are managed by Anthony Romeo of CGAA, an affiliated investment adviser representative.
HDSAM Direct Program – Closed to New Investors The HDSAM Direct Program uses multiple strategies and methods of analysis in seeking its objectives of growth, with a secondary objective of future income. The portfolio recommendations are derived from a series of macro and micro economic calculations that consider Modern Portfolio Theory, beta analysis, alpha comparisons, standard deviation analysis, and Rate of Return comparison. An encrypted web-based portfolio optimization platform is used to get the macro portfolio recommendations and a fund comparison application is used to screen individual mutual funds. Morningstar Advisor Workstation is used to make final fund choices. Portfolio optimization and fund screening take place monthly, with the average re-allocation of the portfolio occurring approximately two to three times per year. The portfolio will automatically rebalance to the original target portfolio if no reallocation occurs within a 12-month period. The benchmark for this portfolio is the S&P 500 and the goal is to meet or exceed performance while maintaining a 70-75% risk exposure.
Accounts in the HDSAM Direct Program are managed by Gary Hutto of Millennium Asset Management, an affiliated investment adviser representative Please refer to Item 8 for additional information regarding the methods of analysis and strategies used in managing the various SAM Programs. 13 Financial Consulting and Financial Planning Services We offer financial consulting and financial planning 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 to single subject financial planning or financial consultative services. The financial planning topics may include, but are not limited to, organization and assessment, retirement planning, education planning, long-term care, insurance planning, debt management, investments, tax planning, estate planning, and life events. Our consultative financial-related topics may include, but are not limited to, asset allocation, risk assessment/management, financial organization, estate planning, retirement planning, reviewing the client's existing portfolio, or other specific topics.
If you retain our firm for financial consulting or financial planning services, we will meet with you to gather information about your financial circumstances 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, 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 financial planning or financial consulting recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the recommendation(s) through us or through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
OTHER IMPORTANT INFORMATION REGARDING THESE PROGRAMS Types of Investments We primarily offer advice on mutual funds. However, 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. Refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
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 conflict with the advice we give to other clients regarding the same security or investment. IRA Rollover Recommendations 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 you.
When we provide investment advice to you regarding your 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 your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. 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); 14
•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; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your 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. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Changes In the Client's Circumstances Clients are advised that changes in your financial situation, investment objectives, tolerance for risk, or investment time horizon may cause the program or strategy selected by the client to no longer be suitable. In the event of any change, the client should contact their IAR or GWN promptly in order to identify another program or strategy, if required.
Negotiability of Program Fees, Account Minimums, & Other Terms For all services, we have the discretion to negotiate our fees, minimum account size, minimum annual fees, and other terms of each client's relationship with us, and to negotiate alternative fees, minimums, or other terms on a client-by-client basis.
When considering and negotiating these matters, we usually consider, among other factors, the dollar amount of assets to be placed under management by the client and related accounts, anticipated future revenues and anticipated future additional assets or accounts from the client or related persons, and other existing or anticipated relationships. We may elect, in our discretion, to aggregate related client accounts for the purpose of achieving the minimum account size requirements and determining annualized fees. Waivers, discounts or more favorable terms not generally available to other clients may be offered to family members and friends of our current and former employees and affiliates. The specific terms of each client's advisory relationship will be agreed upon in writing by GWN and the client. Selection of Other Advisers (Third-Party Managed Model and Custom Portfolio) GWN, acting as co-advisor, sub-advisor, or promoters (formerly solicitors) may introduce you to third- party money managers in order to provide you with certain unique investment advisory services. Neither GWN nor your advisor performs the ongoing discretionary asset management in your portfolio; this is done by the third-party money manager. GWN and your advisor will charge an additional fee over and above the money manager's fee to work with both you and the money manager to ensure that their program continues to meet your needs and goals. As co-advisor, sub-advisor, or promoter, GWN typically is responsible to work with you to collect all necessary information and documentation to assist the money manager in managing your assets, and to answer any questions you may have about the money manager or the managed portfolio. Certain third-party managers allow you and your advisor to create a custom portfolio. You are responsible for notifying your advisor of any changes in your financial situation or investment objectives and to let us know of any investment restrictions for you. GWN, and/or your advisor, may have the ability to hire and fire third-party money managers at their discretion and without your prior approval, depending on the platform or program selected.
Some third-party money managers offer wrap fee programs, which is a type of investment program that provides clients with access to several money managers or mutual fund asset allocation models for a single fee that includes management fees, administrative and custodial fees, and commissions and/or certain transaction costs. Wrap fee accounts are typically more appropriate for active accounts and are managed accordingly. For more information regarding the advisory services and fees that 15 apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs, please refer to the Form ADV, Part 2A or Appendix 1, of the applicable third-party money manager or program.
When GWN or your IAR acts as a promoter, we introduce you to a third-party money manager that we have determined could best manage all or a portion of your assets. Should you choose to do business with the third-party money manager, the Advisor will be paid an ongoing percentage of the fee you pay the manager for the introduction. The fee arrangement will be disclosed to you at the time that you are referred to the money manager. Neither GWN nor your Advisor performs any other role with respect to the management of the assets placed with the money manager. For more information on our promoter arrangements, refer to the Client Referrals and Other Compensation section (Item 14).
Tailored Advisory Services & Client-Imposed Restrictions We tailor our advice to the specific needs and objectives of the client. The Representative will help the client to understand and complete an account profile or questionnaire so that it accurately reflects the account's financial situation, investment objectives, tolerance for risk, and investment time horizon, among other considerations, and will also answer client questions about the programs and our services. Based on the client's investment profile, the Representative will recommend one of our investment management programs, or financial planning or consulting services suited to the needs of the client. Alternatively, for clients not interested in our advisory programs, the Representative (acting in his or her capacity as a registered representative of our broker-dealer and as a licensed insurance agent) will recommend the client purchase securities or insurance products.
For clients seeking investment management services, the Representative will assist the client in selecting a suitable program, asset allocation or model portfolio, and where applicable, separate account manager. We permit clients to impose reasonable restrictions on the types of securities we recommend for their account, and permit clients to change the restrictions by written instruction to us. However, clients should be aware that the terms of any agreements with a third-party investment manager or sub adviser may restrict the client's ability to impose restrictions on account investments.
Once the client has approved the specific investment management program, asset allocation or model portfolio, and where applicable, third-party portfolio manager, the account will be managed to reflect the allocation or model and achieve the objectives of the program and portfolio which the client has selected, subject to reasonable restrictions imposed by the client. Due to client restrictions and other differences regarding each account, performance of a client's account may be different from the performance of other accounts in the same program or portfolio.
Differences Among Advisors' Accounts Representatives follow different investment strategies and styles and adjust their investment selections depending on their Clients' personal and financial situation, and the investment objectives, risk tolerance, liquidity needs, and investment time horizon of the account they are managing. Consequently, it is expected that the levels of volatility, fees, expenses, returns, and performance will, and do, vary significantly among Managed Accounts managed by the same Representative and among Managed Accounts managed by different Representatives. In managing Client accounts, Representatives are acting on behalf of GWN, and the discretion granted by the Client, is granted to GWN. Representatives exercise such discretion in their capacity as GWN's investment adviser representative. As supervisor of the Representatives, GWN monitors Client Accounts. However, GWN does not direct or mandate the investment strategies or styles the Representatives follow in managing their Clients' Accounts.
16 Since our investment strategies and advice are based on each Client's specific financial situation, the investment advice Representatives provide to you may be different or conflicting with the advice our Representatives give to other Clients regarding the same security or investment.
Wrap Fee Programs We do not sponsor or serve as a portfolio manager to a wrap fee program. We may recommend that you invest in a wrap fee program sponsored by third-party money managers. Please refer to the Selection of Other Advisers section for additional details on third-party money manager programs. A wrap fee is generally higher because it includes costs other than an advisory fee that does not cover brokerage and custody services. Advisory fees for non-wrap accounts charge these costs separately.
Assets Under Management As of December 31, 2023, we provide continuous management services for $3,079,617,915 in client assets on a discretionary basis. We do not have assets managed on a non-discretionary basis.