Provenance Wealth Advisors, LLC ("PWA" or the "Firm") is a limited liability company formed under the
laws of the State of Florida. We have been providing investment advisory services since 2000. We are
a Securities and Exchange Commission (SEC) registered investment advisor based in Fort Lauderdale,
Florida. We are owned by the following entity:
• PWA Holdings, LLC
The following paragraphs describe the services we provide and what we charge for those services.
The term Investment Advisor Representative (IAR), as used in this Brochure, refers to an individual from
PWA who is an officer, employee, or individual providing investment advice on behalf of PWA.
Currently, we offer the following investment advisory services, personalized to each Client:
• Portfolio Management Services
• Financial Planning Services
• Retirement Planning Services
• Portfolio Consulting Services
Portfolio Management Services
Portfolio management refers to the management of money, including investments. Assets are held in
what is called a portfolio. Determining the types and quantities of securities to hold in a portfolio is
referred to as portfolio management.
PWA offers discretionary and non‐discretionary portfolio management services to our Clients and
prospective Clients. Discretionary portfolio management means we will make investment decisions
and place buy or sell orders in your account without contacting you. These decisions would be made
based upon your stated investment objectives. Non‐discretionary portfolio management means we
will contact you before a trading decision is implemented.
Our investment advice is tailored to meet our Clients’ needs and investment objectives. If you decide
to hire PWA to manage your portfolio, we will gather your financial information, assess your goals, and
assess how much risk we recommend that would be appropriate for your investments. The information
we collect will help us implement an asset allocation strategy specific to your goals, whether we are
actively investing for you or simply providing you with advice.
PWA mainly uses equity securities, exchange-traded funds, mutual funds, corporate securities,
municipal securities, and U.S. government securities in its portfolio management programs. From time
to time, and if appropriate, we also recommend that Clients invest in alternative investments.
When we construct Clients’ investment portfolios, we will monitor the portfolio’s performance on an
ongoing basis and rebalance the portfolio as we feel necessary, as changes occur in market
conditions or financial circumstances, or both.
As outlined above, discretionary portfolio management services mean that once the portfolio has
been agreed upon, the portfolio's ongoing supervision and management will be PWA's responsibility.
This authority is granted to us by you in a written agreement. This authority allows PWA to decide on
specific securities, the quantity of the securities, and placing buy or sell orders for your account without
obtaining your approval for each transaction. This type of authorization is done using either the
Investment Management Agreement you sign with PWA, a limited power of attorney agreement, or
trading authorization forms. You may limit this authority by setting a limit on the type of securities that
can be purchased for your account. Limitations will be outlined in writing.
The non‐discretionary portfolio management service means that we must obtain your approval before
placing any transactions in your account.
Financial Planning Services
We offer broad-based financial planning, including charitable gifting strategies, risk analysis, insurance
analysis, estate planning, and retirement planning. PWA strives to achieve Clients' long‐term financial
goals by implementing a financial planning process that includes, but is not limited to, any or all the
following steps:
• Assessing the Client's present financial situation by collecting information regarding net worth
and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans,
employee benefit statements, etc.
• Identifying the Client's financial goals, personal goals, and objectives. Goals or objectives may
include financing a child's college education, retirement planning, etc. The identified goals or
objectives are specific, realistic, and measurable.
• Resolution of financial-related problems. Obstacles to achieving financial independence are
identified so that possible resolutions may be found. Examples of problem areas can include too
little or too much insurance coverage, inadequate cash flow, or lack of a tax plan.
• A written financial plan is prepared that includes recommendations and solutions to any
financial-related problems.
• Implementation of the financial plan. Once the financial plan is finalized and agreed upon, the
recommendations and solutions are executed to reach the desired goals and objectives. You
may choose to accept or reject our recommendations. If you decide to proceed with our
recommendations, you are under no obligation to implement them through us.
• Evaluation of the financial plan is conducted periodically. The financial planning service
provides periodic reviews and revisions of the plan to ensure that the financial goals are
achieved.
Financial plans are based on your situation and the information you provide to PWA. If your financial
situation, goals, objectives, or needs change, it is imperative that you notify us promptly.
We also provide financial planning services that cover a specific area, such as retirement or estate
planning. We offer consultative services where we set an appointment to meet with you for financial
planning advice for an hourly fee. Additional information regarding the fees associated with our
Financial Planning Services is set forth in Item 5 of this Brochure.
Retirement Planning Services
PWA provides retirement planning-related services separately or in combination with our other services.
While the primary Clients for these services will be pension, profit-sharing, 403(b), and 401(k) plans, PWA
also offers similar services, where appropriate, to individuals, trusts,
estates, and charitable
organizations. Retirement Planning Services is comprised of four distinct services, discussed below.
Clients may choose to use any or all these services.
Investment Policy Statement Preparation
PWA will meet with the Client (in person, over the telephone, or video conference) to assess the Client’s
investment needs and goals. PWA will then prepare a written Investment Policy Statement (IPS) stating
those needs and goals and creating a policy to help achieve these goals. The IPS will also list the criteria
for selecting investment vehicles and the procedures and timing intervals for monitoring investment
performance.
Selection of Investments
PWA will review various investments, consisting of one or all of the following: individual equities, bonds,
other investment products, and mutual funds (both index and managed) to determine which of these
investments are appropriate to implement the Client’s IPS. The number of investments recommended
will be determined by the Client based on the IPS.
Monitoring of Investment Performance
Client investments will be monitored continuously, based on the procedures and timing intervals
outlined in the Investment Policy Statement. Although PWA will not be involved in any way in the
purchase or sale of these investments, PWA will monitor the Client’s portfolio and make
recommendations to the Client as market factors and the Client’s needs dictate.
Employee Communications
For pension, profit-sharing, 403(b), and 401(k) plans where the individual account participant exercises
control over assets in their account (from now own self‐directed plans), PWA also provides educational
support and investment workshops designed for the Plan participants. PWA and the Client will
determine the nature of the topics covered under the guidelines established in ERISA Section 404(c).
The educational support and investment workshops will not provide plan participants with
individualized, tailored investment advice or individualized tailored asset allocation
recommendations.
Other retirement planning services are available on request. All of our retirement planning services,
whether general or customized, will be outlined in an agreement showing the services to be provided,
as well as the fees that will be charged for those services.
ERISA and Individual Retirement Accounts Disclosure
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 interests ahead of yours.
Under this special rule's provisions, we must:
• 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.
For the purposes of ERISA § 3(21), PWA does not exercise any discretionary authority or control
with respect to the management of the plan or management or disposition of its assets or
have any discretionary authority or discretionary responsibility in the administration of the plan.
The participants are responsible for any individual investment selections made under the plan.
Under ERISA § 3(21), PWA acts as the advisor making investment recommendations, but it is up
to the plan sponsor to decide whether and how to implement these recommendations.
For the purposes of ERISA § 3(38), PWA serves as the investment manager, who exercises
discretionary authority with regard to the model portfolios it develops and with regard to the
mutual funds and other investment vehicles that it selects for investment under the Plan. The
participants are responsible for any individual investment selections made under the plan.
Under ERISA § 3(38), PWA acts as the advisor with discretionary authority with regard to the
investments managed for the plan, allowing the plan sponsor to transfer liability for selecting'
monitoring' and replacing the investment options to PWA, the investment manager.
All of our retirement plan consulting services, whether general or customized, will be outlined
in an Agreement that shows the services that will be provided and the fees that will be
charged for those services.
Portfolio Consulting Services
We offer Portfolio Consulting Services that primarily involve advising clients on a one-time,
ongoing, or periodic basis to provide one or more of the following non-discretionary
investment services:
• Determination of Risk Parameters
• Design/construction of a model portfolio
• Assistance in selecting money managers
• Periodic oversight
• Review of investment strategies
• Annual meetings where guidelines, performance and research are discussed
You will be required to provide us with all pertinent data and information with respect to your
financial and investment situation so we can properly analyze your situation and make
recommendations within that context.
Services Provided to Affiliated Accounting Firm
We are affiliated by common ownership with the accounting firm of Berkowitz Pollack Brant
Advisors and Accountants, LLC ("BPB"). BPB may engage us to provide analysis and consulting
services for clients or refer clients to us to provide advisory services. Fees for analysis and
consulting services vary and are paid by BPB to us.
Assets Under Management
As of September 15, 2023 we had $2,830,195,316 in total assets under management. We manage
$1,979,512,582 in Client assets on a discretionary basis, $850,682,734 in non-discretionary assets.