EM
4
Who We Are
Financial Harvest Wealth Advisors1 (hereinafter referred to as the “Company”, “FHWA”, “we”,
“us”, and “our”) is a full-service registered investment advisor2 offering a wide range of wealth
management services3 since October 2008 to help you, our client4 cultivate and preserve your
wealth.
Owners
The following persons control the Company:
Name Title CRD#
David A. Witter Managing Member & Chief Executive Officer 4519401
Nancy K. Witter Managing Member 4553458
Assets Under Management
We offer two (2) investment management services: Portfolio Management and Portfolio
Monitoring. All Portfolio Management accounts are discretionary, and our Portfolio
Monitoring accounts are non-discretionary. As of December 31, 2022, our assets under
management totaled:
Discretionary Accounts ............................................. $276,051,271
Non-Discretionary Accounts ....................................... $375,173
For more information on our Portfolio Management and Portfolio Monitoring services see
“Investment Management” services below. You can also read more about our investment
services under “Portfolio Management” and “Portfolio Monitoring” that includes the cost of
our services in Item 5, “Fees & Compensation.”
Our Mission
We help families preserve their wealth, independence and autonomy in ever-changing
environments so that they can focus on what is most important to them. When clients are not
troubled with concerns about their wealth, they can then move autonomously to allow them to
have the greatest impact on their families, friends, clients, colleagues, and community
members. Our services amplify our clients' capacities for engaging their families and
communities to positively affect generations to come.
1 Financial Harvest Wealth Advisors is the d/b/a name for Financial Harvest, LLC.
2 The term “registered investment advisor” is not intended to imply that Financial Harvest Wealth Advisors has attained a certain level of skill or training. It
is used strictly to reference the fact that we are “registered” as a licensed “investment advisor” with the United States Securities & Exchange Commission –
and “Notice Filed” with such State Regulatory Agencies that may have limited regulatory jurisdiction over our business practices.
3 Financial Harvest, LLC is a fiduciary, as defined within the meaning of Title I of the Employer Retirement Income Security Act of 1974 (“ERISA”) and/or as
defined under the Internal Revenue Code of 1986 (the “Code”) for any wealth management services provided to a client who is: (i) a plan participant or
beneficiary of a retirement plan subject to ERISA or as described under the Code; or (ii) the beneficial owner of an Individual Retirement Account (“IRA”).
4 A client could be an individual and their family members, a family office, a foundation or endowment, a charitable organization, a corporation and/or small
business, a trust, a guardianship, an estate, or any other type of entity to which we choose to give investment advice.
What We Do
We are a wealth management firm that helps our clients efficiently and effectively address the
five fundamental concerns of the affluent. Through research and experience, the following
five fundamental concerns have been identified:
v Making wise investment decisions throughout their lifetime to protect their lifestyle,
independence, and dignity
v Mitigating income, capital gains and estate taxes
v Ensuring heirs are taken care of
v Protecting wealth from being unjustly taken
v Existential concerns such as charitable giving and leaving a legacy
We help our clients address these concerns with our Wealth Management Consultative Process
(discussed below), which delivers collaborative Wealth Management solutions. Wealth
Management equals Investment Consulting (“IC”), Advanced Planning (“AP”) and Relationship
Management (“RM”).
The Wealth Management Formula: WM = IC + AP + RM
Our wealth management formula consists of three (3) components: Investment Consulting,
Advanced Planning, and Relationship Management.
Investment Consulting
We offer two management options based on your financial needs. These services include:
(1) Portfolio Management; and (2) Portfolio Monitoring.
Portfolio Management
Our Portfolio management strategies focus on designing, building, and maintaining a
portfolio allocation, based on your Investment Plan and Investment Policy Statement
(“IPS”), using primarily open-end investment company (“mutual funds”) products, unit
investment trusts (“UITs”), and fixed income/debt (“bonds”) instruments. Occasionally
we may use exchange traded funds (“ETFs”) and direct participation programs (Private
Offerings) to also assist with implementing your Investment plan.
You will find more information about our management services under “Portfolio
Management” in Item 5, “Fees & Compensation” below and further description of our
investment strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk
of Loss.”
Portfolio Monitoring
We will recommend a third-party money manager (“Portfolio Manager”), whose
investment disciplines most closely resemble your investment objectives as outlined in
your IPS. Included in your IPS is:
v An asset allocation study illustrating the balancing of investment return and
risk by spreading risk among various asset classes and investment vehicles as a
classic way to increase portfolio security; and,
v A recommended Portfolio Manager to implement your asset allocation strategy.
Under these arrangements, we are not involved in the day-to-day management of your
portfolio assets, although we are in regular communication with the Portfolio Manager
concerning the services of your account. Our responsibility will be to continuously
evaluate the performance of your portfolio to ensure the Portfolio Manager adheres to
the standards of your IPS and will make recommendations regarding the Portfolio
Manager as changes in the marketplace and your personal objectives dictate. More
information about our “Portfolio Monitoring” services is available below under Item 5,
“Fees & Compensation.”
Advance Planning
We have found that most affluent clients want a comprehensive approach to addressing the
entirety of their financial lives in tandem with investment management. We care for the
array of wealth management concerns of our clients by collaborating with our Professional
Network Teams to deliver The Advanced Plan.
Our Professionals Network Teams include a private client lawyer, accountant, life
insurance specialist, personal lines insurance specialist, and our succession planning
professional consortium for business owners. We integrate their thinking and solutions into
the client's Advanced Plan, which specifically addresses wealth enhancement, wealth
transfer, wealth protection and charitable planning.
The initial step during our Wealth Management Consultative Process (described in detail
below) is to create a Total Client Profile (TCP) consisting of the client's concerns,
objectives, relationships, values, interests, assets, professional advisors and process
preferences. Once the client engages our Wealth Management Services, we present their
TCP (with personal information removed to protect privacy) in a Professional Network
Meeting to assess each client’s unique situation and propose appropriate actions to
consider. This assessment and proposed actions for consideration are the core elements to
a client's Advanced Plan.
Relationship Management
Relationship Management involves three key tactics:
1. Fully understanding our clients' critical needs and meeting those needs over time
through a consultative process
2. Assembling and managing a network of financial experts
3. Working effectively with our clients' other professional advisors, such as their
attorneys and accountants.
Summary – Wealth Management Formula
Initially we listen and learn from our clients to determine what is important to them and
then design an Investment Plan and Advance Plan that addresses their concerns and moves
them towards their financial and personal ambitions.
It is critical that the Investment and Advanced Plan be monitored on at least an annual
basis. Material changes in your personal circumstances or tax and estate law changes are
some of the reasons why the recommendations in your plan should be reviewed
periodically.
The Wealth Management Consultative Process
Our Wealth Management Consultative Process involves five distinct appointments to help our
clients care for their array of wealth management concerns. The first two meetings
combined represent our Second Opinion Service (S.O.S.) while the latter three implement
each client’s custom designed Investment Plan and Advanced Plan.
Discovery Meeting - During this 60 to 90 minute conversation, we ask questions to:
v Learn your core values and guiding principles
v Understand your financial concerns and how you have been addressing them
v Discover your financial objectives and what success looks like for you
v Create a Total Client Profile consisting of concerns, objectives, relationships,
values, interests, assets, professional advisors and process preferences
v Determine if it is appropriate to move to the Investment Plan Meeting
Investment Plan Meeting - During this meeting, we will present:
v Diagnostic of your current investment plan to properly care for all of your
financial concerns
v Our recommendations aimed at lowering cost, reducing risk, increase expected
return, and/or increasing tax efficiency to improve the likelihood of successfully
achieving your goals
v An explanation of your potential Advanced Plan for comprehensive evaluation of
your entire range of wealth management needs beyond just investment strategy
Mutual Commitment Meeting
Make a mutual commitment to work together and execute the documents necessary to
begin implementing your Investment Plan and proposed Advanced Plan to achieve your
objectives and care for your concerns.
45-Day Follow-up Meeting
We help you understand and organize all of the financial paperwork from the account
establishment process. We also establish which of your outlined objectives will be achieved
during each of the forthcoming Regular Progress Meetings.
Regular Progress Meetings
Before scheduling this meeting, we have discussed your Total Client Profile with our team
of carefully selected professionals, each with a high level of knowledge and skill in key
financial areas, at a Professional Network Meeting. We utilize their knowledge and
assessments to evaluate all aspects of your financial situation and devise appropriate
solutions for consideration. Wealth Management can be overwhelming and produce
unsatisfactory results when rushed. Therefore, meeting quarterly allows us to methodically
progress through your specific Advanced Plan to produce your objectives.
FEES & COMPENSATION
5
Financial Planning
How we charge to develop a financial plan depends on the size, complexity, and nature of your
personal and financial situation and the amount of time it will take to analyze, present, and
implement the plan with the services engaged.
Planning Fees
Second Opinion Service
The Second Opinion Service is an evaluation of your current financial situation – based on
your income and expenses, career, personal goals, investment strategy & deployment, and
time horizon – to then provide you an assessment of what adjustments to your investment
strategy could increase expected return, reduce risk, increase tax efficiency, and reduce
costs. We also recommend financial planning steps with our Actionable Wealth Plan to
achieve your outlined objectives and financial success.
The Second Opinion Service requires a two-hour retainer, which is $750, and will be due in
full at the end of the Discovery Meeting. If at the Investment Plan meeting you choose to
engage us to manage your investment portfolio(s), we will reimburse you the $750 in the
first management fee billing cycle (See “Billing” under “Protocols for Portfolio
Management” below to understand when and how we bill our management fees.).
We can prepare just a financial plan. If you are not interested in our investment
management services and only want to engage us to prepare a financial plan, you have two
options depending on your needs: a coordinated plan – a mutually defined review of multiple
areas of personal financial; or, a targeted plan – a review, analysis, and evaluation of a
single core area of personal finance.
Coordinated
Coordinated financial planning services are offered for a negotiated flat project fee not to
exceed $10,000 for the initial engagement.
The coordinated planning fee will be fully disclosed in a Financial Planning Agreement at
the “Planting” stage of our planning process. The Agreement will include the cost5 to
review your financial information and prepare the coordinated financial plan. We will
require full payment of the coordinated planning fee up-front at the time the Agreement is
signed6.
Targeted
If you desire only targeted planning – review, analysis and evaluation of a core area of
financial need – the fee will be billed at our negotiable hourly rate not to exceed $3757 per
5 Rarely will a fee exceed those costs outlined in the Agreement. However, there can be instances where we did not contract with you to perform a
particular task and therefore merit notifying you of the additional cost prior to beginning such services.
6 The recommendations made in a financial plan are generally completed within 30 to 45 days from you signing the Agreement. However, implementing the
plan using outside professionals (i.e., attorneys, CPAs, etc...)
may require additional time that is out of our control. Therefore when we refer to the
completion of the financial plan, we are referring to us (you and us) finalizing your financial benchmarks/objectives before approaching any outside
professional.
7 For a Targeted Financial Plan, we require a minimum of four hours consultation to address any personal and financial needs you may have.
hour. All fees will be completely itemized in a billing statement to you, or as otherwise
predetermined in a proposal, engagement letter and/or by retainer.
Annual Review
It is important to note that any planning is kinetic (always in motion) and alive. A financial
plan is a roadmap that is only as good as how well it reflects your current financial position
to then guide you on a clear path to a future financial situation. Continuously changing
circumstances in your life often necessitate annual reviews designed to systematically
address these unexpected diversions and continually keep you on the right road headed to
your future financial destination.
Annual Review
Once the initial financial planning services have been completed, we will establish future
“Annual Review” dates. The Annual Reviews generally occur after the first anniversary and
will be used to review and make adjustments, if necessary, to the financial plan. Together
we will set the calendar dates for your future reviews; inasmuch, an Annual Review may
consist of two or three visits during the calendar year.
Annual Review Fee
We reserve the option to waive our annual review fee if we are currently managing
your investments. If we are not managing your investment portfolio and you want us to
review your financial plan, we will notify you of the cost to perform the desired work
before commencing. Such retainer fee will generally range from 25% to 50% of the first
year planning fee depending on the length of time since our last review and on the
services you request (i.e., If the first year planning fee was $4,000, the annual review fee
would be from $1,000 to $2,000.). However, if you have experienced significant change in
your life circumstances since the date of your previously prepared plan, the fee could be
higher.
Termination
Coordinated or Targeted Planning Termination
You can terminate the Financial Planning Agreement at any time prior to the presentation
of any final planning documents. We will be compensated through the date of termination
for time spent in design of such financial documents at the hourly rate agreed to in the
Agreement. If you have prepaid any fees, such un-earned fees will be returned on a pro-
rata basis. Once the financial plan has been completed and presented to you,
termination of the Financial Planning Agreement is no longer an option.
Annual Review Termination
Annual Review services can be terminated at any time. The Company will bill you for any
services rendered from the date of the last bill up to the date of termination at the fee
rate that was agreed to in the proposal, engagement letter and/or retainer agreement.
Portfolio Management
Portfolio management is provided on an asset-based fee arrangement. Management fees are
calculated based on the aggregate market value of your account on the last business day of the
previous calendar quarter multiplied by one-fourth of the corresponding annual percentage
rate for each portion of your portfolio assets that fall within each tier (See “Billing” below
under “Protocols for Portfolio Management” for more information.).
We retain discretion to negotiate the management fee within each tier on a client-by-client
basis depending on the size and complexity of the portfolio managed. Fee break will occur as
assets in your portfolio increase past specified tiers:
Account Value
Annual Fee
Rate
Not to Exceed
First $500,000 ................................................... 1.35%
Next $1,000,000 ................................................ 0.95%
Next $1,000,000 ................................................ 0.90%
Next $2,500,000 ................................................ 0.80%
Next $5,000,000 ................................................ 0.70%
Over $10,000,000 ............................................... 0.50%
We have a $5,000 minimum annual fee requirement ($1,250 billed quarterly), which may be
waived or reduced if we feel circumstances are warranted. Accounts with portfolio values
that fall below $370,000 will be subject to this minimum annual fee, which can cause our
fee to exceed our highest published 1.35% Annual Fee Rate (e.g., a managed account of
$200,000 with a minimum annual fee charge of $5,000, will translate into an annual fee rate of
2.50%.). Keep in mind, the further your portfolio value drops below $370,000 the higher the
annual fee rate. We may recommend you engage another Investment Advisor if your account
continues to decline below $200,000, which would cause our management fee to approach
3.00%. We may decline to continue to manage accounts that fall below $167,000.
Protocols for Portfolio Management
The following protocols establish how we handle our portfolio management accounts and
what you should expect when it comes to: (i) managing your account; (ii) your bill for
investment services; and (iii) other fees charged to your account(s).
Discretion
We establish discretionary trading authority on all management accounts to execute
securities transactions at any time without your prior consent or advice. Our trading will
be limited to rebalancing your portfolio in alignment with your IPS or to fulfill a
disbursement request. At any time however, you may impose restrictions, in writing, on
our discretionary authority (i.e., limit the types/amounts of particular securities purchased
for your account, exclude the ability to purchase securities with an inverse relationship to
the market, limit our use of leverage, etc.).
Billing
Your account will be billed a blended fee quarterly in advance based on the fair market
value for the portion of your portfolio that falls within each tier of our fee schedule. For
example:
Account Value:
$1,200,000
Annual Fee %
(Per Tier)
Annual Fee
(Billed per Tier)
First $500,000 1.35% $6,750
Next $700,000 0.95% $6,650
Total Annual Fee: $13,400
Blended Annual Fee % 1.12%
For new managed accounts opened in mid-quarter, our fee will be based upon a pro-rated
calculation of your assets to be managed for the current quarterly period. Advisory fees
will be deducted first from any money market funds or cash balances. If such assets are
insufficient to satisfy payment of such fees, a portion of the account assets will be
liquidated to cover the fees.
Deposits and Withdrawals
Assets deposited by you into your portfolio management account between billing cycles will
not result in additional management fees being billed to your account unless such deposits
exceed $100,000. We do not want to discourage you from investing additional capital for
your future but deposits of this amount or greater, in most cases, will require modifications
and adjustments to your investment allocation. Therefore, we reserve the right to bill
your account a pro-rated fee based upon the number of days remaining in the current
quarterly period for deposits exceeding the above amount.
For assets you may withdraw during the quarter, we do not make partial refunds of our
portfolio management fee. Just as with deposits, withdrawals from your account will
require modifications and adjustments to be made to correct the allocation of assets in
your portfolio.
Fee Exclusions
The above fees for all of our management services are exclusive of any charges imposed by
the custodial firm including, but not limited to: (i) any Exchange/SEC fees; (ii) certain
transfer taxes; (iii) service or account charges, including, postage/handling fees, electronic
fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot
differentials and mutual fund short-term redemption fees; and (iv) brokerage and
execution costs associated with securities held in your managed account. There can also
be other fees charged to your account that are unaffiliated with our management services.
In addition, all fees paid to us for portfolio management services are separate from any
fees and expenses charged on mutual fund shares by the investment company or by the
investment advisor managing the mutual fund portfolios. These expenses generally include
management fees and various fund expense, such as: redemption fees, account fees, and
purchase fees that may occur but are the exception within managed accounts at
institutional custodians. A complete explanation of these expenses charged by the mutual
funds is contained in each mutual fund’s prospectus. You are encouraged to carefully read
the fund prospectus.
Termination of Investment Services
To terminate our investment advisory services, either party (you or us) by written
notification to the other party, may terminate the Investment Advisory Agreement at any
time, provided such written notification is received at least 30 days prior to the date of
termination (i.e.; To terminate services on October 1st, a request for termination should be
received in our office by September 1st.) Such notification should include the date the
termination will go into affect along with any final instructions on the account (i.e., liquidate
the account, finalize all transactions and/or cease all investment activity).
In the event termination does not fall on the last day of a calendar quarter, you shall be
entitled to a pro-rated refund of the prepaid quarterly management fee based upon the
number of days remaining in the quarter after the termination notice goes into effect. Once
the termination of investment advisory services has been implemented, neither party has any
obligation to the other – we no longer earn management fees or give investment advice and
you become responsible for making your own investment decisions.
Portfolio Monitoring
Under the arrangements with the Portfolio Managers, we are not involved in the day to day
management of your portfolio assets. Our responsibility to the Portfolio Manager(s) will be to
ensure you meet their minimum qualifications. Once your account has been established we
will perform all administrative and clerical duties as may be required to service your account.
The Portfolio Manager(s) may have little or no direct contact with you.
Our responsibility to you will be to evaluate the performance of your portfolio to ensure the
Portfolio Manager adheres to the standards of your IPS, and we will make recommendations to
you regarding the Portfolio Manager as changes in the marketplace and your personal
objectives and goals dictate.
Portfolio Managers Fee Structure
The Portfolio Managers who will be used to manage your account(s) will disclose their fees
for management services in their Disclosure Brochures (the Portfolio Manager’s ADV Part 2A:
Firm Brochure or Part 2A Appendix 1: Wrap Fee Program Brochure), which we will provide
you prior to, or at the same time as, opening an account. The fees that will be charged to
your account(s) are also disclosed in the executed investment management agreement and
will include:
1. The Portfolio Manager’s management fee;
2. Our Portfolio Monitoring fee (not to exceed 1.20%) that the Portfolio Manager will
pay us from the total management fee (not to exceed 1.50%) they collect; and,
3. Trading commissions and/or account charges, depending on if the Portfolio
Manager is “wrapping” all the fees, which may be imposed by the custodian or
broker/dealer used to custody your account(s).
The Portfolio Manager’s Disclosure Brochure contains all pertinent disclosures relating to
their management services, fee structure for such services, and their termination provisions –
you are encouraged to carefully review these disclosures.
Portfolio Monitoring Protocols
You will want to consult the Portfolio Manager’s Disclosure Brochure for their policies on how
they will handle your account; such as, billing, deposits and withdrawals, fee exclusions,
termination, and any other unique advisory costs associated with their service since we do
not take discretion over the management of your account and we do not handle any of the
billing. We will discuss these arrangements with you when we go to open your account with
a Portfolio Manager; however, you are encouraged to read their terms for management on
your own.
Educational Workshop
We teach adult education courses at education institutions including, but not limited to Rollins
College. The educational seminar/workshop is designed to teach how to build wealth and align
your money to accomplish your life goals. The course is completed in two 3-hour sessions
covering the following topics:
v Life Planning for Retirement
v Retirement Needs & Expenses
v Retirement Roadblocks & Mistakes
v Retirement Income Sources
v Retirement Plan Distributions
v Investments
v Risk Management & Asset Protection
v Estate Planning
We charge a registration fee not to exceed $250 per household, which covers the cost of the
materials and course study at the institution where the classes are being offered. At the
conclusion of the course, some participants voluntarily request appointments which can lead to
portfolio management and financial planning services.
PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
IT
EM
6
We do not charge fees based on a share of capital gains or the capital appreciation of the
assets held in your accounts.