A. Description of the Advisory Firm
EWG Elevate Inc. (hereinafter “EEI”) dba Protection Point Advisors is a Corporation
organized in United States. The firm was formed in October 2017, and the principal owner
is Richard Lee Watson.
B. Types of Advisory Services
Portfolio Management Services
EEI offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. EEI creates an Investment Policy
Statement for each client, which outlines the client’s current situation (income, tax levels,
and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio
that matches each client's specific situation. Portfolio management services include, but
are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
EEI evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. EEI will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
EEI seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of EEI’s economic, investment or
other financial interests. To meet its fiduciary obligations, EEI attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, EEI’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is EEI’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
Model Portfolios/ Strategies
EEI offers the following Model Portfolios/Strategies
APM (Advance and Protect Model): Riskalyze risk: 26 - 32
This momentum model is designed to have no specific asset allocation. In can be any mix
of stock, commodities, managed futures, and cash, but limits exposure to anyone asset
class to 20%. It looks to limit market downturns to about 5% in a given year (although not
guaranteed) and does this by using a three part decision process (statistical momentum,
chart review and institutional bias) which evaluates each position within the portfolio
each week. Should two of these measures agree, the position might be replaced by
another positions or is moved to cash. This is a fairly active model which can be nimble.
Because of its responsiveness, it can lag initially in a recovering market and potentially be
lead incorrectly in a large volatility oscillating market.
EWG Growth: Riskalyze risk: 40 - 50
This momentum model is based the best index and its relative performance of 10 separate
categories. These categories are: Growth, Sectors, Value, World, Markets, Quality,
Dividend, Clean Green, Innovation and US Heartland, using primarily Exchange Traded
Funds (EFTs). It leans toward a 100% stock exposure in a positive market environment.
It has two levels of defense: 1 using a 60% stock/40% bond position if that position scores
better per category sort, or a movement towards bonds/gold, or cash, if our proprietary
Stormguard indicator triggers .
Stable Growth: Riskalyze risk: 15 - 26
This model was designed to be an alternative to low cash returns with low to moderate
volatility. It seeks to earn 2 - 5%/year with limited down years using defensive positions,
less trading, and broad diversification. Each quarter, each position is reviewed for
momentum and adjusted as necessary. Typical holdings might be real estate, bonds,
long/short stock funds – hedge funds, managed futures.
EWG Dividend: Riskalyze risk: 34 - 45
The goal is a consistent 5-6% yield and primarily uses this yield as the model’s defense
and. The minimum yield for a position is 3%. Uniquely, the model could be made up of
any combination of mutual funds, Real estate, ETFs, or individual stocks. This is not a
specifically tactical portfolio and generally remains invested, unless suitable replacement
positions don’t exist.
STAR 25/75: Riskalyze risk: 34 - 45
This model is allocated based on a computer calculated algorithm to rank momentum of
stock sectors/style boxes each month or quarter. A diversified portfolio is built from the
positions ranked at or better than the average momentum for the last month. In an up
market determined by a proprietary algorithm, the maximum allocation to stock funds is
75%. If the algorithm determines that the market has weak momentum, then the
maximum allocation to stock is 25% and the excess is allocated to bond or cash funds
based on a similar ranking to stocks.
STAR 30/90: Riskalyze risk: 39 - 50
This model is allocated based on a computer calculated algorithm to rank momentum of
stock sectors/style boxes each month or quarter. A diversified portfolio is built from the
positions ranked at or better than the average momentum for the last month. In an up
market determined by a proprietary algorithm, the maximum allocation to stock funds is
90%. If the algorithm determines that the market has weak momentum, then the
maximum allocation to stock is 30% and the excess is allocated to bond or cash funds
based on a similar ranking to stocks.
Blend: Riskalyze risk: 32 - 50
Blend/Dual Defense is an investment strategy that adapts to market trends by focusing
on areas of the market showing positive momentum each month. It compares different
segments of the market and identifies those with the strongest recent performance. If a
blended model consisting of 60% stocks and 40% bonds performs better than a chosen
position, a blended fund is utilized instead. In times of market uncertainty, the strategy
may shift positions to cash as a defensive measure, relying on a proprietary indicator
Stormguard. The model can allocate up to 100% in stocks or cash and invests in both
mutual funds and exchange-traded funds.
AlphaDPM: Riskalyze risk 29 – 36
This is a monthly reviewed focused momentum model of ETF (exchanged traded funds).
The model maintains 4 positions: top monthly momentum in countries, sectors of the S&P,
sectors of the I-Shares funds, and a “global mix” basket of funds. The model uses
Stormguard to determine if market risk is too high and rotates to defensive positions in
an attempt to protect against market loss. Stormguard uses price trend, market sentiment,
and position momentum charts to determine if Stormguard should be triggered.
Merlyn’s Magic: Riskalyze risk 29 – 45
This model is an aggressive Aritifical intelligence (AI) run model similar to Alpha Droid,
but heavily skewed to SSR @ 45%. Other exposures are 25% Global, 15% Style box
(large/small and value/growth), and 15% factor based rotation. This model is a computer
based model that we just implement. It’s a possible successor to Alpha Droid model also
using Stormguard to determine if market risk
is too high and rotates to defensive positions
in an attempt to protect against market loss. Stormguard uses price trend, market
sentiment, and position momentum charts to determine if Stormguard should be
triggered.
ESG Blend: Riskalyze risk: 30 - 40
ESG Blend/Dual Defense is an investment strategy that adapts to market trends by
focusing on areas of the market showing positive momentum each month, however it
starts with a filter for specific ESG categories. Those categories are: Clean Green, ESG
International, ESG Social, Sustainable Future, Clean Water, Clean Energy, Electric
Vehicles. It sorts these different catagories and identifies those with the strongest recent
performance. If a blended model consisting of 60% stocks and 40% bonds performs better
than a chosen position, a blended fund is utilized instead. In times of market uncertainty,
the strategy may shift positions to cash as a defensive measure, relying on a proprietary
indicator. The model can allocate up to 100% in stocks or cash and invests in both mutual
funds and exchange-traded funds.
SSR (Single Sector Rotation): Riskalyze risk: 54-70
This model is an aggressive Artificial intelligence (AI) run model similar to Alpha Droid,
but focuses on one position at a time, not 4. This is a monthly reviewed focused
momentum model of ETF (exchanged traded funds). The model maintains 1 position: top
monthly momentum in countries, sectors of the S&P, sectors of the I-Shares funds, an
aggressive mix of ETFs and a “global mix” basket of funds. The model uses Stormguard
to determine if market risk is too high and rotates to defensive positions in an attempt to
protect against market loss. Stormguard uses price trend, market sentiment, and position
momentum charts to determine if Stormguard should be triggered.
Core/Satellite: Riskalyze risk: 19 – 55
This a series of models combining 2/3 of a static core stock position to 1/3 sector monthly
rotation and movement to cash. The sector rotation portion also uses Stormguard to
determine if market risk is too high and rotates to defensive positions in an attempt to
protect against market loss. It is available ranging from a pure stock exposure to 25%,
50% and 75% Hiker bond.
Canvas Custom Indexing:
This model offers sophisticated Environmental, Social and Governance (ESG) investment
options, as well as custom indexing solutions. Our personalized approach allows clients
to choose their preferred level of ESG exposure. Customizable options include specific
stock restrictions and value-based investing, which help align clients’ portfolios with their
personal beliefs or tax transition or harvesting needs.
PPA models: Pre-blended models:
o PPA Conservative (Riskalyze risk: 25 – 35)
25% APM, 25% Dividend, 50%Core bond
o PPA Income (Riskalyze risk: 30 - 40)
50% APM, 50% Dividend
o PPA Moderate (Riskalyze risk: 34 - 44)
40%Blend, 40%CorSat, 20% Core bond
o PPA Growth (Riskalyze risk: 40 - 50)
33%EWG Grth, 33%Merlyn, 34% Core Equity
o PPA Aggressive Growth (Riskalyze risk: 55 – 70)
30% US AlphaDPM, 20% Core Equity, 10% Satellite, and 40% from
an Innovation category.
Selection of Other Advisers
EEI may direct clients to third-party investment advisers. Before selecting other advisers
for clients, EEI will verify that all recommended advisers are properly licensed, notice
filed, or exempt in the states where EEI is recommending the adviser to clients.
Private Placement Offerings
We may also recommend to appropriate advisory clients:
• Investments in private placement offerings and/or limited investment
partnerships (i.e., hedge funds and venture capital funds)
Investments in these types of private investment vehicles:
• Are not registered with or regulated by the SEC.
• Are available only to clients that are deemed to be an “accredited investor” in
accordance with the requirements set forth in applicable laws, rules and regulations.
• Typically require investors to lock-up their assets for a period of time.
• Can have limited or no liquidity.
• Involve different risks than investing in registered funds and other publicly offered
and traded securities.
• Are only recommended when consistent with the client’s stated investment objectives,
tolerance for risk, liquidity and suitability.
• Additional information about the fees related to such investments is included in the
private offering documents provided to prospective investors.
• We rely on the evaluation and performance data provided directly from the private
investment vehicles. Private investment vehicles are often delayed in providing us
with this information, which will delay us in reporting this information to clients.
Investments in the PPA Co-Living Fund I, LLC is now closed and no new subscribers are
being accepted.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning. Advice, recommendations and the plan may be delivered verbally
if requested by the client.
401-k services
EEI provides non-discretionary 3(21) services to 401-k plans. Services may include but are
not limited to; Assisting in the education and enrollment of plan participants, periodic fee
and service reviews of plan service providers, provide periodic electronic market updates
and newsletters for plan participants, plan design and monitoring of industry vendors
and trends.
Services Not Limited to Specific Types of Investments
EEI does not limit its investment advice. Generally EEI invests in mutual funds, fixed
income securities, insurance products including annuities, equities, ETFs (including ETFs
in the gold and precious metal sectors), treasury inflation protected/inflation linked
bonds and options. EEI may use other securities as well to help diversify a portfolio when
applicable.
C. Client Tailored Services and Client Imposed Restrictions
EEI will tailor a program for each individual client. This will include an interview session
to get to know the client’s specific needs and requirements as well as a plan that will be
executed by EEI on behalf of the client. EEI may use model allocations together with a
specific set of recommendations for each client based on their personal restrictions, needs,
and targets. Clients may impose restrictions in investing in certain securities or types of
securities in accordance with their values or beliefs. However, if the restrictions prevent
EEI from properly servicing the client account, or if the restrictions would require EEI to
deviate from its standard suite of services, EEI reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. EEI does not participate in any wrap fee programs.
E. Assets Under Management
EEI has the following assets under management:
Discretionary
Amounts:
Non-discretionary
Amounts:
Date Calculated:
$ 528,908,946.00 $ 19,395,177.00 December 2023