A. Firm Information
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Great
Point.
Great Point Wealth Advisors, LLC (“Great Point,” the “Adviser” or the “Firm”) is a federally Registered Investment Adviser with the U.S.
Securities and Exchange Commission (“SEC”), which is organized as a Limited Liability Company (“LLC”) under the laws of the
Commonwealth of Massachusetts. Great Point was founded in 2008 and is owned and operated by Peter V. Disch, Jr., CFP®, Managing
Member and Chief Compliance Officer.
The Adviser’s compensation is solely from fees paid directly by Clients. Great Point does not receive commissions based on the Client’s
purchase of any financial product, including insurance. No commissions in any form are accepted. Assets managed by Great Point are held
by independent custodians (Please see Item 12).
As part of Great Point’s consulting, we may recommend certain professionals (e.g., attorneys, accountants, insurance agents, real estate
agents, mortgage brokers, etc.) to assist with the implementation of recommended strategies. Conflicts of interest, if present, will be
disclosed to the Client.
B. Advisory Services Offered
Great Point offers wealth advisory services to individuals, high net worth individuals (and related entities, trusts and estates and family
businesses) and retirement plans throughout the United States (each herein referred to as “Client”).
The Adviser acts as a fiduciary to Clients, as defined under applicable laws and regulations. As such, each recommendation made as part
of the advisory services are based on the belief that the recommendation is in the Client's best interest. Our fiduciary commitment to
each Client is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of
Ethics, Participation or Interest in Client Transactions and Personal Trading.
Wealth Management Services
Great Point will typically provide a variety of wealth management services to individuals and families, pursuant to a written Wealth
Management Agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and
resources.
Generally, such wealth management services will involve preparing key documents such as a Statement of Net Worth, Pro-forma Income
Statement, Statistical Analysis Summary of Financial Projections, or rendering a financial consultation for Clients based on the Client’s
financial goals and objectives. This service may encompass one or more areas of need, including, but not limited to investment planning,
retirement planning, tax planning, estate planning, personal savings, education savings and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to, the Client will usually include 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. Great Point may also refer Clients to an accountant, attorney or
other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Adviser will provide a written
summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Adviser may not
provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and
documents requested are provided promptly.
Under the terms of the Wealth Management Agreement, Great Point will also provide customized investment management solutions for
its Clients. This is achieved through personal Client contact and interaction while providing discretionary investment management and
consulting services. Great Point works with each Client to identify their investment goals and objectives as well as risk tolerance and financial
situation in order to create a portfolio allocation. Great Point will then construct a portfolio consisting of exchange traded funds (“ETFs”),
mutual funds, individual stocks and bonds, or other securities. For certain high net worth Clients, Great Point may also recommend limited
partnerships and other types of investments.
Great Point’s investment strategy is primarily long-term focused, but the Adviser may buy, sell or re-allocate positions that have been held
less than one year to meet the objectives of the Client or due to market conditions. Great Point will construct, implement and monitor the
portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the
opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by
the Adviser.
Great Point evaluates and selects investments for inclusion in Client portfolios only after applying their internal due diligence process. Great
Point may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Great Point may recommend specific
positions to increase sector or asset class weightings. The Adviser may recommend employing cash positions as a possible hedge against
market movement. Great Point may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains
or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in
the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed acceptable for the Client’s risk
tolerance.
All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Wealth Management Agreement.
Prior to rendering investment management services, Great Point will ascertain, in conjunction with the Client, the Client’s financial situation,
risk tolerance, and investment objective[s].
Special Projects
Under certain circumstances,
Great Point will consult on special projects for a fee. Details of this service are mutually agreed upon by
Client and Adviser and are specifically outlined in a separate agreement.
Retirement Plan Advisory Services
Great Point provides advisory services to retirement plans (each a “Plan”) and the company/sponsor of the Plan (the “Plan Sponsor”). The
Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its
Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
Great Point will have the discretion to select the investments for the Plan and/or make investment decisions on behalf of Plan Participants.
Independent Managers
Occasionally, Clients elect to use an investment model provided to us by an Independent Manager, for a portion of their assets, for a fee
that is separate and distinct from the fees we charge.
We do not receive compensation for the recommendation of Independent Managers.
A complete description of the programs and services (including fees to be charged and other contractual information) will be provided to
Clients upon receipt and review of the applicable Independent Manager’s Form ADV and/or Brochure; investment advisory contracts; and
account opening documents.
Private Fund Investments
We act as the investment manager to the Race Rock Multi-Strategy Fund LP (the “Fund”), a private investment fund in which certain
Clients invest. This can present a conflict of interest since the Fund charges a separate fee. The Fund’s investment objective is to provide
superior capital appreciation over time through a diversified multi-strategy approach that invests in both public and private capital
markets. The Fund expects to invest directly in equity securities as well as in private investment vehicles (“Portfolio Funds”) that are
managed by third-party managers. The Portfolio Funds are expected to include hedge funds that typically pursue a more liquid
investment strategy and private equity funds that typically pursue a less liquid investment strategy. Additional information, including fees,
specific procedures, and restrictions for withdrawals from and terminations of a position in the Fund, are described in the Fund’s Private
Placement Memorandum.
C. Client Account Management
Prior to engaging Great Point to provide investment management services, each Client is required to enter into a Wealth Management
Agreement with the Adviser that defines the terms, conditions, authority and responsibilities of the Adviser and the Client. These services
may include:
• Establishing an Investment Strategy – Great Point, in connection with the Client, will develop a strategy that seeks to achieve the
Client’s goals and objectives.
• Asset Allocation – Great Point will develop a strategic asset allocation that is targeted to meet the investment objectives, time
horizon, financial situation and tolerance of risk for each Client.
• Portfolio Construction – Great Point will develop a portfolio for the Client that is intended to meet the stated goals and
objectives of the Client.
• Investment Management and Supervision – Great Point will provide investment management and ongoing oversight of the
Client’s investment portfolio.
D. Wrap Fee Programs
Great Point does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by
Great Point.
E. Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement
plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some
conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when
working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way
to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and
representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and
exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading,
promoting our services, and engaging in other professional activities.
F. Assets Under Management
As of December 31, 2023, Great Point manages $525,431,178 in discretionary assets and $20,462,549 in non-discretionary assets. Total
assets under management are $545,775,190. Current information is available upon request.