A. OWNERSHIP/ADVISORY HISTORY
Advisor is a Washington Limited Liability Company formed on June 14th, 2014. At the time of
formation, Jeffery P. Lewis, the Advisor’s sole owner and managing member, used the firm as his
trade name while was registered as an investment adviser representative with Retirement Wealth
Advisors, LLC. On March 26, 2021, the firm transitioned from State of Washington registration
to being federally registered with the Securities and Exchange Commission (SEC). Additional
information about Mr. Lewis can be found under Item 19 of this brochure and in Supplemental
Brochure, Form ADV – Part 2B.
B. ADVISORY SERVICES OFFERED
Advisor is the asset management and financial planning division of Epic Trust Financial Group
LLC and offers a variety of investment management, financial planning, portfolio monitoring and
third-party manager monitoring services to individuals, high-net-worth individuals, trusts, estates,
charitable organizations, other investment advisers and the clients of such independent investment
advisers.
i. Investment Advisory and Portfolio Management Services
Advisor offers a diverse menu of investments strategies covering Strategic, Tactical, and Dynamic
Asset and Security Allocation approaches.
Advisor may use a combination of individual stocks, bonds, mutual funds, ETFs, or options
contracts in its investment strategies to reach the client’s long term investment objectives.
As with most long-term investment strategies, Advisor’s diverse investment strategy menu utilizes
strategies that are designed to purchase securities with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year. The risk
associated with using a long-term purchase strategy is that it generally assumes the financial
markets will go up in the long-term, which may not be the case. There is also the risk that the
segment of the market that the client is invested in or perhaps just that client’s particular investment
will go down over time even if the overall financial markets advance. Purchasing investments
long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the
short-term in other investments.
Advisor manages client accounts on a discretionary basis and has discretionary authority regarding
the securities to be bought or sold, the amount of securities to be bought or sold as well as the
authority to hire and terminate third-party money managers.
Account supervision is generally guided by the stated objectives of the client (e.g., capital
appreciation, growth, income, or growth and income). Consideration is also generally given to the
allocation of assets among securities-based investment strategies and managers and
recommendations and selections are generally tailored to the client’s overall investment objectives
and risk profiles. Advisor’s investment committee also seeks to perform due diligence on third-
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party money managers and investment solutions prior to these being offered through the Advisor
platform and then strives to perform ongoing due diligence as to such managers and solutions.
ii. Selection of Other Advisors
Advisor may utilize or recommend sub-advisers or third-party money managers (“TPMMs”) to
clients. Advisor will generally
be compensated via a fee share with the TPMMs to which it directs
those clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before
recommending TPMMs to clients, Advisor performs due diligence and research on such TPMMs.
iii. Financial Planning Services:
Advisor’s Financial Planning Services covers income planning, social security planning,
retirement planning and pension plan review. Over the course of three meetings, Advisor reviews
the client’s current financial situation and then compares it to other scenarios using Monte Carlo
Method software. The Monte Carlo Method projects the likelihood of achieving one’s financial or
retirement goals and whether a retiree will have enough income to live on for life, given a wide
range of outcomes in the markets. The service’s goal is to assist the client with his/her financial
decision-making process.
PLEASE NOTE: When we provide financial planning services and the client implements the
financial plan through one of our representatives, the representative will receive compensation in
the form of a commission or fee. This creates a conflict of interest between the representative and
the client. Therefore, when providing financial planning services, we would like clients to note:
(a) a conflict exists between the representative’s interests and the interests of the client, (b) the
client is under no obligation to act upon the recommendation, and (c) if the client elects to act on
any of the recommendations, the client is under no obligation to effect the transaction through the
representative.
iv. ERISA & Qualified Plan Services
Advisor offers to ERISA and other Qualified Plans consulting services that involve one or more
of the following services, either onsite or through an electronic medium, as requested by the Plan:
• Enrollment meetings to Plan participants
• Education as to the Plan’s options and features
• Education for employees on financial topics such as compound interest, debt, benefits of
financial planning as examples
• Discuss with HR payroll and related matters pertaining to Plan services and enrollment
issues that may arise
• Individual discussions with employees regarding Plan features and operations
• Discuss investment changes with the Plan’s trustees that the 3(38) Plan fiduciary makes
from time to time
• Acts as the 3(38) Plan investment fiduciary to select and monitor investment options
available to plan participants
• Periodically benchmark the plan as to costs and benefits to other plan providers to assess
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the Plan's competitiveness for industry, size, and features
C. CUSTOMIZED SERVICES
Advisor’s services may be customized to each client as requested and after review by a member of
the portfolio management team. Clients may place restrictions on securities held in accounts. All
restrictions must be presented in writing.
D. WRAP PROGRAM
Advisor does not offer a Wrap Program.
E. ASSETS MANAGED
As of December 31, 2022, the firm manages approximately $216,554,841 in individual client
accounts on a discretionary basis. Advisor also manages approximately $32,340,847 in employer
sponsored retirement accounts on both a non-discretionary and discretionary basis depending on
the employer and its engagement with Advisor.