The Weaver Consulting Group Wrap Program (the “Program”) is an investment advisory program sponsored by Weaver
Consulting Group. Prior to Weaver Consulting Group rendering any of the foregoing advisory services, clients are required to
enter into one or more written agreements with Weaver Consulting Group setting forth the relevant terms and conditions of
the advisory relationship (the “Advisory Agreement”).
Weaver Consulting Group has been registered as an investment adviser since May 2017 and is principally owned by Jason
Weaver and Travis Weaver. As of December 2023, Weaver Consulting Group had $ 775,404,545.00 assets under management,
$ 775,404,545.00 of which was managed on a discretionary basis and $0.00 of which was managed on a non-discretionary
basis.
While this brochure generally describes the business of Weaver Consulting Group, certain sections also discuss the activities of
its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or
performing similar functions), employees or any other person who provides investment advice on Weaver Consulting Group’
behalf and is subject to the Firm’s supervision or control.
Description of the Program
The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain investment products
without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered any arrangement
under which clients receive investment advisory services (which may include portfolio management or advice concerning the
selection of other investment advisers) and the execution of client transactions for a specified fee or fees not based upon
transactions in their accounts. Clients must also open a new securities brokerage account and complete a new account
agreement with Fidelity Institutional Wealth Services (“Fidelity”) or another broker-dealer that Weaver Consulting Group
approves under the Program (collectively “Financial Institutions”).
At the onset of the Program, clients complete an investor profile describing their individual investment objectives, liquidity and
cash flow needs, time horizon and risk tolerance, as well as any other factors pertinent to their specific financial situations.
After an analysis of the relevant information, Weaver Consulting Group assists its clients in developing an appropriate strategy
for managing their assets. Clients’ investment portfolios are generally managed on a discretionary or non-discretionary basis by
Weaver Consulting Group’ investment adviser representatives. Weaver Consulting Group generally allocates clients’ assets
among the various investment products available under the Program, as described further in Item 6 (below).
Financial Planning and Consulting Services
Weaver Consulting Group offers clients a broad range of financial planning and consulting services, which may include any or all
of the following functions:
Education Planning
Cash Flow / Net Worth Planning
Trust and Estate Planning
Financial Reporting
Investment Planning
Insurance Planning
Retirement Planning
Tax Planning
While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with
investment portfolio management as part of a comprehensive wealth management engagement (described in more detail
below). The Firm will use third parties for certain financial planning and consulting services.
In performing these services, Weaver Consulting Group is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information.
Weaver Consulting Group may recommend clients engage the Firm for additional related services, its Supervised Persons in
their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to
implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients
engage Weaver Consulting Group or its affiliates to provide (or continue to provide) additional services for compensation,
including investment management services. Clients retain absolute discretion over all decisions regarding implementation and
are under no obligation to act upon any of the recommendations made by Weaver Consulting Group under a financial planning
or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in
their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Weaver Consulting Group’
recommendations and/or services.
Investment and Wealth Management Services
Weaver Consulting Group manages client investment portfolios on a discretionary or non-discretionary basis. In addition,
Weaver Consulting Group may provide clients with wealth management services which includes a broad range of
comprehensive financial planning and consulting services as well as discretionary and/or non-discretionary management of
investment portfolios.
Weaver Consulting Group primarily allocates client assets among various mutual funds, structured notes, individual debt and
equity securities, and exchange-traded funds (“ETFs”) including closed-end and leveraged ETFs, in accordance with their stated
investment objectives.
Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client
portfolios. Clients may engage Weaver Consulting Group to manage and/or advise on certain investment products that are not
maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer
sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Weaver Consulting Group directs or
recommends the allocation of client assets among the various investment options available with the product. These assets are
generally maintained at the underwriting insurance company or the custodian designated by the product’s provider.
Weaver Consulting Group tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Weaver
Consulting Group consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon,
liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly
notify Weaver Consulting Group if there are changes in their financial situation or if they wish to place any limitations on the
management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts
if Weaver Consulting Group determines, in its sole discretion, the conditions would not materially impact the performance of a
management strategy or prove overly burdensome to the Firm’s management efforts.
Fees for Participation in the Program
Investment and Wealth Management Fee
The Program is offered on a fee basis, which may include fixed fees for financial planning and consulting, as well as fees based
upon assets under management for investment management or wealth management services (the “Program Fee”).
Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, may offer securities brokerage services
and/or insurance products under a separate commission- based arrangement.
This Program Fee generally varies between .20 and 1.5 basis points (0.20% – 1.50%), depending upon the size and composition
of a client’s portfolio, the complexity of services, the client’s risk tolerance, and the type of services rendered. The annual fee is
prorated and charged monthly, in arrears, based upon the market value of the average daily account balance for that month.
Since the asset-based fee is determined by average daily account balance, if assets are deposited into or withdrawn from an
account after
the inception of a quarter, the base fee payable with respect to such assets is adjusted accordingly. For the initial
period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee
for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of
the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets,
accommodation accounts, alternative investments, etc.), Weaver Consulting Group may negotiate a fee rate that differs from
the range set forth above.
Financial Planning and Consulting Fees
Weaver Consulting Group charges a fixed fee for providing financial planning and consulting services under a stand-alone
engagement. These fees are negotiable, but generally range from $500 to $2,500, depending upon the scope and complexity of
the services and the professional rendering the financial planning and/or the consulting services. If the client engages the Firm
for additional investment advisory services, Weaver Consulting Group may offset all or a portion of its fees for those services
based upon the amount paid for the financial planning and/or consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement and
Weaver Consulting Group generally requires one-half of the fee payable upon execution of the Advisory Agreement. The
outstanding balance is generally due upon delivery of the financial plan or completion of the agreed upon services. The Firm
does not, however, take receipt of $1,200 or more in prepaid fees in excess of six months in advance of services rendered.
Fee Comparison
As referenced above, a portion of the fees paid to Weaver Consulting Group are used to cover the securities brokerage
commissions and transactional costs attributed to the management of its clients’ portfolios.
Services provided through the Program may cost clients more or less than purchasing these services separately. The number of
transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of
the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Fees paid for
the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs.
Because the Firm pays for the brokerage fees, the Firm has an incentive to engage in less transactions, or transactions that cost
less to the Firm, and choose Independent Managers whose fees fall outside of the Program Fee.
Fee Discretion
Weaver Consulting Group, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, pre-existing/legacy client relationship, account retention and pro bono activities.
Other Charges
In addition to the advisory fees paid to Weaver Consulting Group, clients may also incur certain charges imposed by other third
parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These additional charges
include fees charged by the Independent Managers, fees attributable to alternative assets, reporting charges, margin costs,
mark-ups or mark-downs priced in to fixed income products by the broker-dealer, charges imposed directly by a mutual fund or
ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), fees and
commission for assets not held with Fidelity (such as 401(k) or 529 plan assets), fees for trades executed away from Fidelity,
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees.
Direct Fee Debit
Clients generally provide Weaver Consulting Group with the authority to directly debit their accounts for payment of the
investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm
retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all
account transactions, including any amounts paid to Weaver Consulting Group.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to Weaver Consulting Group’ right to
terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any
transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on
notice to Weaver Consulting Group, subject to the usual and customary securities settlement procedures. However, Weaver
Consulting Group designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a
client’s investment objectives. Weaver Consulting Group may consult with its clients about the options and implications of
transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction
fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charge) and/or tax ramifications.
Commissions and Sales Charges for Recommendations of Securities
Clients can engage certain persons associated with Weaver Consulting Group (but not the Firm directly) to render securities
brokerage services under a separate commission-based arrangement outside of the
Program. Clients are under no obligation to engage such persons and may choose brokers or agents not affiliated with Weaver
Consulting Group.
Under this arrangement, the Firm’s Supervised Persons, in their individual capacities as registered representatives of Purshe
Kaplan Sterling Investments, Inc. (“PKS”), may provide securities brokerage services and implement securities transactions
under a separate commission based arrangement. Supervised Persons may be entitled to a portion of the brokerage
commissions paid to PKS, as well as a share of any ongoing distribution or service (trail) fees from the sale of mutual funds.
Weaver Consulting Group may also recommend no-load or load-waived funds, where no sales charges are assessed. Prior to
effecting any transactions, clients are required to enter into a separate account agreement with PKS.
A conflict of interest exists to the extent that Weaver Consulting Group recommends the purchase or sale of securities where
its Supervised Persons receive commissions or other additional compensation as a result of the Firm’s recommendation. The
Firm has procedures in place to ensure that any recommendations made by such Supervised Persons are in the best interest of
clients. For certain accounts covered by the Employee Retirement Income Security Act of 1974 (“ERISA”) and such others that
Weaver Consulting Group, in its sole discretion, deems appropriate, Weaver Consulting Group may provide its investment
advisory services on a fee-offset basis. In this scenario, Weaver Consulting Group may offset its fees by an amount equal to the
aggregate commissions and 12b-1 fees earned by the Firm’s Supervised Persons in their individual capacities as registered
representatives of PKS.
Use of Margin
Weaver Consulting Group does not recommend the use of leverage in accounts, but may recommend margin on accounts
where clients have borrowing needs. In these cases the fee payable to the Firm will be assessed on the assets managed by the
Firm (gross of margin).
Compensation for Recommending the Program
Weaver Consulting Group has no internal arrangements in place whereby persons recommending the Program are entitled to
receive additional compensation as a result of clients’ participation. A person recommending the Program will not earn more
compensation than he or she would otherwise receive if a client elected another investment management program.