A. Firm Information
Choice Wealth Advisors LLC (“CWA” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company under the laws of
the State of Maine. CWA was founded in June 2018 and is a wholly-owned subsidiary of Choice Investments, a
Corporation under the laws of Maine. Christopher Markos (Chief Compliance Officer & Financial Advisor) is the
majority owner of Choice Investments. This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by CWA. For information regarding this
Disclosure Brochure, please contact Christopher Markos at (207) 873-0996.
B. Advisory Services Offered
CWA offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, businesses and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. CWA’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
CWA provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related
advisory services. CWA works closely with each Client to identify their investment goals and objectives as well as
risk tolerance and financial situation in order to create a portfolio strategy. CWA will then construct an investment
portfolio, consisting primarily of low-cost, diversified mutual funds and/or Exchange-Traded Funds (“ETFs”) to
achieve the Client’s investment goals. The Advisor may also utilize interests in limited partnerships, such as Real
Estate Investment Trusts and other types of investments, as appropriate, to meet the needs of the Client. The
Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
CWA’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. CWA
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and
risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on
the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
CWA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. CWA may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. CWA may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement. CWA may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s]
in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
Advisor will refer certain Clients to a bank[s] for loan options, including non-purpose. If a Client decides to utilize
a non-purpose loan they may use the assets in their account[s] as collateral for the non-purpose loan. The
recommendation of such a loan presents a conflict of interest as the Advisor will continue to receive investment
advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to
engage the Advisor for such offerings. For Additional information related to the risks involved with non-purpose
loans and lines of credit, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. The
Advisor does not receive any compensation for such referrals.
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At no time will CWA accept or maintain custody of a Client’s funds or securities, except for the limited authority
as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Plan Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a
Client roll over its retirement plan account into an account managed by the Advisor. In such instances, the
Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income
Security Act of 1974 (“ERISA”). Such a recommendation creates a conflict of interest as the Advisor will earn a
new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over
retirement plan assets to an account managed by the Advisor.
Use of Independent Managers
CWA in certain circumstances will recommend that Clients utilize one or more unaffiliated investment managers
or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment
portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with
the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment
management and related services. The Advisor may also assist in the development of the initial policy
recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing
oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’
strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.
The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s],
will be provided with the Independent Manager’s Form ADV 2A (or a brochure that makes the appropriate
disclosures).
Financial Planning Services
CWA will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written
financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement planning,
personal savings, education savings insurance needs and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
CWA may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract
date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
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Retirement Plan Advisory Services
CWA provides retirement plan advisory services on behalf of retirement plans (each a “Plan”) and the company
(the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in
meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the
needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Ongoing investment Recommendations and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
Certain of these services are provided by CWA serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of CWA’s fiduciary status, the specific services to be
rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging CWA to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
• Establishing an Investment Strategy – CWA, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – CWA will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – CWA will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – CWA will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
CWA does not sponsor or manage a wrap fee program.
E. Assets Under Management
As of December 31, 2022, CWA manages $220,412,228 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.