Divergent Wealth Advisors, LLC is dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed under the laws of the State of Utah in 2017. As of August 1, 2023, Divergent Wealth Advisors, LLC was wholly acquired by NFP Retirement Inc. and its affiliated owners, however Divergent Wealth Advisors will maintain its separate registration as an investment adviser. NFP Retirement Inc. is owned by NFP Corp. NFP Retirement Inc. provides comprehensive qualified and non-qualified retirement plan consulting, investment advice and fiduciary due diligence services, employee plan and investment education, asset allocation services, plan service provider proposal and provider research and analysis, and plan design guidance to individuals, qualified and non-qualified retirement plan sponsors, and business entities.
Our firm provides asset management and investment consulting services for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in the client's best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process facilitates the kind of working relationship we value.
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 "DWA", "we", "our", and "us" refer to Divergent Wealth Advisors, LLC and the words "you", "your", and "client" refer to you as either a client or prospective client of our firm.
Client Investment Process We provide discretionary and non-discretionary portfolio management services in accordance with your individual investment objectives. If you participate in our discretionary investment advisory services, we require you to grant our firm discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. We will also have discretion over the broker or dealer to be used for securities transactions, and over the commission rates that we pay. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and/or through trading authorization forms. DWA does not allow you to place restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities is not possible due to the level of difficulty it would entail in managing the account and the types of investments we normally use in our portfolios. Prior to becoming a client you will be required to enter into a separate written agreement with us that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid.
Types of Advisory Services We Provide Clients of DWA can engage with our firm in any of the following five investment advisory programs. DWA shall be responsible for assisting you in the selection of the most appropriate program(s) based on our assessment of your needs and objectives. 4 Divergent Wealth Signature Portfolios If you elect this program we shall be responsible for assisting you in the selection of one or more of our Divergent Wealth Signature Portfolios. Once selected, you grant us full discretion for the investment and reinvestment of assets in this program. Our firm is authorized, without prior consultation with you, to manage your assets in accordance with your selected Signature Portfolio strategy. This includes the authorization to buy, sell, and trade on your behalf through your custodian in stocks, bonds, mutual funds, ETFs and other securities and/or contracts relating to the same, and to liquidate any securities used to fund the account.
If your investment objectives change, you are responsible for notifying us so that we can evaluate whether a change to the portfolio needs to be made and you grant us full discretion to make such changes on your behalf, which may include: changing to another Divergent Wealth Signature Portfolio, changing to another program described in this section, or the termination of our investment advisory relationship.
Accounts in this arrangement are subject to the agreed-upon advisory fee described in Item 5 below and, if applicable, are included as assets that determine the amount Divergent Wealth may pay towards costs incurred by engaging a Signature Professional as outlined in Item 5 below. (See "Signature Professional Program" disclosures below for more information).
Divergent Wealth Fixed Income Portfolios In this program, we shall be responsible for assisting you in the selection of one or more of our Divergent Wealth Fixed Income Portfolios. Once selected, you grant us full discretion for the investment and reinvestment of assets in this program. Our firm is authorized, without prior consultation with you, to manage your assets in accordance with your selected Fixed Income strategy. This includes the authorization to buy, sell, and trade through your custodian in bonds, notes, certificates of deposit, mutual funds, ETF's and other fixed-income securities and/or contracts relating to the same, and to liquidate any securities used to fund the account.
If your investment objectives change, you are responsible for notifying us so that we can evaluate whether a change to the portfolio needs to be made and you grant us full discretion to make such changes on your behalf, which may include: changing to another Divergent Wealth Fixed Income Portfolio, changing to another program described in this section, or the termination of our investment advisory relationship.
Accounts in this arrangement are subject to the agreed-upon advisory fee described in Item 5 below. However, they are NOT included as assets that determine the amount Divergent Wealth may pay towards costs incurred by engaging a Signature Professional (See "Signature Professional Program" disclosures below for more information).
Divergent Wealth Custom Portfolios Under this program, we assist you in the selection of a customized investment strategy. This strategy may include a combination of our Divergent Wealth Signature Portfolios, our Divergent Wealth Fixed Income Portfolios, or a customized strategy mutually agreed upon by you and Divergent Wealth at the onset of our appointment. Once selected, you grant us full discretion for the investment and reinvestment of assets in this program. Our firm is authorized, without prior consultation with you to manage your assets in accordance with the agreed-upon customized investment strategy. This includes the authorization to buy, sell, and trade on your behalf through 5 your custodian in stocks, bonds, notes, certificates of deposit, mutual funds, ETFs and other securities and/or contracts relating to the same, and to liquidate any securities used to fund the account.
If your investment objectives change, you are responsible for notifying us so that we can evaluate whether a change to the portfolio needs to be made and you grant us full discretion to make such changes on your behalf, which may include: changing to another Custom Portfolio, changing to another program described in this section, or the termination of our investment advisory relationship.
Accounts in this program are subject to the agreed-upon advisory fee described in Item 5 below. However, they are not included as assets that determine the amount Divergent Wealth may pay towards costs incurred by engaging a Signature Professional (See "Signature Professional Program" disclosures below for more information).
Divergent Wealth Portfolio Consulting Services Under this program, we will assist you in the management of your assets using a qualified custodian of your choice. A qualified custodian should allow Divergent Wealth Advisors access to the information needed to evaluate the investment options and to track the performance of the assets on their platform.
For accounts held under this program, you hereby appoint our firm as an Investment Adviser and Portfolio Consultant, and we accept such appointment to perform the following services: We shall be responsible for assisting you in the selection of a suitable investment strategy utilizing your custodian's available investment options. If your custodian allows discretionary management of your account by Divergent Wealth Advisors, you hereby authorize us without prior consultation with you to manage your assets in accordance with the agreed-upon investment strategy. This includes the authorization to buy, sell, and trade through your custodian in stocks, bonds, mutual funds, ETF's, annuity sub-accounts, and other securities and/or contracts relating to the same, and to liquidate any securities used to fund the account.
If your custodian does not allow discretionary management of your account, you will be responsible for executing any of the recommendations provided to you by DWA.
If your investment objectives change, you are responsible for notifying us so that we can evaluate whether a change to the investment portfolio needs to be made and, if allowed by the custodian, you grant us full discretion to make such changes on your behalf, which may include: changing to another financial institution's platform, changing to another program as described in this section, or the termination of our investment advisory relationship.
We reserve the right to revoke this appointment if the custodian's requirements change, if we are no longer able to receive the information needed to perform our agreed-upon services, or if you are unable or unwilling to implement recommendations we have made regarding these assets. You will be notified of the revocation and any unused fees will be rebated to you.
Accounts in this program are subject to the agreed-upon advisory fee set forth in Schedule A of the advisory agreement. However, they are not included as assets that determine the amount Divergent Wealth may pay towards costs incurred by engaging a Signature Professional (See "Signature Professional Program" disclosures below for more information). Our advisory fee may be withdrawn from another account if authorized by you in Schedule A of the advisory agreement.
6 Divergent Wealth Courtesy Accounts Under this arrangement, you are solely responsible for the management of the assets in the account. Divergent Wealth does not have discretion with which to manage the account or execute trade orders without your approval. However, we may, under your direction, execute non- discretionary trade orders with the custodian on your behalf. Also, with your authorization, we will transfer money or assets into and out of this account on your behalf. Accounts in this program are not subject to an advisory fee nor are they included as assets that determine the amount Divergent Wealth may pay towards costs incurred by engaging a Signature Professional (See "Signature Professional Program" disclosures below for more information). However, you are responsible to pay your own trading costs at the custodian's prevailing rate, as well as any other custodial charges that might be incurred.
Divergent Wealth Signature Professional Program The Signature Professional Program is a value-added service only for qualified clients. This program allows DWA to cover some, and in many cases, all costs a client might incur when engaging a "Signature Professional". A Signature Professional is defined as an estate-planning attorney DWA has pre-screened for their experience, their credentials, their fee structure, their process, and their ability and desire to collaborate with other key financial professionals.
For admittance into the Signature Professional Program, DWA will conduct the pre-screening and interview the attorneys being considered. After this vetting process, Divergent Wealth then approves a pool of several estate planning attorneys (Signature Professionals) for a client to choose from. The client is responsible for interviewing, selecting, and engaging the Signature Professional and is responsible to alert DWA when a selection has been made.
Divergent Wealth Signature Professionals are not affiliated with DWA. A client's relationship with them is independent of our firm's contractual agreement. DWA cannot guarantee their work or services as we have no control over their processes or procedures. DWA is simply offering a pool of several attorneys that a client might consider working with. The client has the ultimate responsibility to engage with the estate planning attorney.
Provided the

client elects to work with a Signature Professional, and that the client has at least $500,000 invested in our Divergent Wealth Signature Portfolios, DWA will pay the Signature Professional's fees up to the amounts set forth in Item 5 below provided that the services go towards the creation or modification of the client's estate planning documents (e.g., wills, trusts, medical directives, and powers of attorney) within 12 months of the signing of this agreement. We reserve the right to waive the $500,000 minimum investment amount at our discretion and individually determine the amount our firm is willing to pay on the client's behalf. It should be also noted that the Signature Professional offering does not apply to institutional or corporate clients.
In the event that the amount that we contribute towards the Signature Professional's estate planning fees does not cover the full amount of the costs incurred, the client will be solely responsible to cover the difference, or the remaining fees.
Estate plans and legal documents should be reviewed by a competent legal professional periodically to ensure accuracy and adherence to federal and state laws as well as the client's stated objectives. Under this program, Divergent Wealth is not required to supplement future estate planning costs that may be incurred after the initial 12-month period has expired.
7 Clients are not obligated to use a Signature Professional for their estate planning services. However, if a client chooses not to use a Signature Professional, Divergent Wealth will not contribute funds on the client's behalf to the non-participating attorney or estate planning firm.
We are not attorneys. Even though we may pay some or possibly all of the legal fees incurred with a Signature Professional, the attorney-client relationship will be strictly between the client and the attorney. The client expressly understands and agrees that our firm does not and will not provide any legal services to any client, including the preparation of legal documents or the providing of legal advice.
By participating in the Signature Professional program, the client agrees to allow DWA to collaborate with the Signature Professional. This means the client authorizes DWA to share personal information pertinent to the scope of the engagement with the selected attorney.
Financial Planning & Consulting Our firm provides a variety of standalone financial planning and consulting services to clients for the management of financial resources based upon an analysis of their current situation, goals, and objectives. Financial planning services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the client's financial goals and objectives. This planning or consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general recommendations for a course of action or specific steps to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Our firm provides clients with a summary of their financial situation, and observations for financial planning engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. Assuming that all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within 6 months of the client signing a contract with our firm.
Retirement Plan Consulting Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure, and participant education. Retirement Plan Consulting services typically include:
•Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives.
•Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes.
•Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk.
•Investment Monitoring – Our firm will monitor the performance of the investments and notify the 8 client in the event of over/underperformance and in times of market volatility. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REIT's), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, "Excluded Assets"). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans ("Plan") governed by the Employee Retirement Income Security Act of 1974, as amended ("ERISA"). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein.
Private Fund-Related Advisory Business We provide discretionary investment advisory services to private funds (the "Funds"). Divergent Wealth Advisors provides day-to-day asset management and advisory services to the Divergent Capital Fund 2, LP, Divergent Capital Fund 3, LP and Foothills AT Francis Gate Fund 1, LP. The Managing Member of the Fund, DC FOF 2 GP, LLC, DC FOF 3 GP, LLC and Foothills AT Francis Gate GP, LLC, respectively, have complete discretion and exclusive responsibility and authority for all investment making decision of the Funds. The Managing Members have delegated certain of its authority to Divergent Wealth Advisors pursuant to an Asset Management Agreement. Such delegation will not relieve the Managing Members of any of their duties or responsibilities.
The Funds makes investments in other funds such as, mutual funds, venture capital and private equity funds. The Fund's investment objectives and/or parameters are set forth in the Fund's organizational documents, offering documents, and/or other governing documents, (together with the Fee Letter and any applicable side letters, the "Fund Documents") provided to each Investor in the Fund (each, an "Investor"). We tailor the advisory services for a Funds based on that Fund's investment objective and investment strategy, including guidelines regarding the types of investments the Funds will make and portfolio limits (if any). We do not tailor our advisory services to the individual needs of Investors, and Investors may not impose restrictions on investing in certain securities or types of investments for these Funds.
The Divergent Capital Fund 2, LP and the Foothills AT Francis Gate Fund 1, LP, typically requires a minimum investment of $100,000, while the Divergent Capital Fund 3, LP. requires a minimum investment of $500,000; however, these requirements may be waved or reduced by the Funds' Managing Members and founding investors. A General Partner to the Divergent Capital Fund 2, LP known as DC FOF 2 GP, LLC, owns 6% of the Fund, as a co-investor. While the General Partner to the Divergent Capital Fund 3, LP known as DC FOF 3 GP, LLC, owns 3% of the Fund, as co- investors. The General Partner to the Foothills AT Francis Gate Fund 1, LP known as Foothills AT Francis Gate GP, LLC does not have an ownership position in the Fund.
NFPR provides services that may recommend the purchase of services and/or products that are also offered by NFP Corp. and its affiliates. There is an inherent conflict of interest when a product or service recommends use of other products or services offered by NFP Corp. and its affiliates. The Adviser or its associated persons may receive compensation for these products and services. The Adviser does not make any representation that these products and services are offered at the lowest 9 available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of the Adviser or use the services and/or products of the Adviser in particular.
Types of Investments We primarily offer advice on ETFs. We also offer advice on equity securities, mutual funds, corporate debt, municipal securities and alternative investment including interests in partnerships and private placements that invest in a variety of other investment vehicles. 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.
Tailoring of Advisory Services Our firm offers individualized investment advice to our investment advisory clients. General investment advice will be offered to our Financial Planning & Consulting clients and Retirement Plan Consulting clients. Changes in Your Financial Circumstances In providing the contracted services, we are not required to verify any information we receive from you or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on the information you provide. Furthermore, unless you indicate to the contrary, we shall assume that there are no restrictions on our services, other than to manage your account in accordance with your designated investment objectives. It is your responsibility to promptly notify us if there are ever any changes in your financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services.
Participation in Wrap Fee Programs DWA does not participate in a Wrap Fee Program.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), 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: 10
•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);
•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.
Regulatory Assets Under Management As of January 1, 2024, we provide continuous management services for $613,069,399 in client assets on a discretionary basis, and $4,290,157 in client assets on a non-discretionary basis.