Item 5 – Additional Compensation ..................................................................................................................... 19
Item 6 – Supervision ............................................................................................................................................ 19
Item 2 – Educational Background and Business Experience .......................................................................... 21
Item 3 – Disciplinary Information ........................................................................................................................ 21
Item 5 – Additional Compensation ..................................................................................................................... 21
Item 6 – Supervision ............................................................................................................................................ 22
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 23
Item 2 – Educational Background and Business Experience .......................................................................... 24
Item 3 – Disciplinary Information ........................................................................................................................ 24
Item 5 – Additional Compensation ..................................................................................................................... 24
Item 6 – Supervision ............................................................................................................................................ 24
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 26
Item 2 – Educational Background and Business Experience .......................................................................... 27
Item 3 – Disciplinary Information ........................................................................................................................ 28
Item 5 – Additional Compensation ..................................................................................................................... 28
Item 6 – Supervision ............................................................................................................................................ 28
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 29
Item 2 – Educational Background and Business Experience .......................................................................... 30
Item 3 – Disciplinary Information ........................................................................................................................ 31
Item 5 – Additional Compensation ..................................................................................................................... 31
Item 6 – Supervision ............................................................................................................................................ 31
Privacy Policy ....................................................................................................................................................... 32
A. Firm Information
Caliber Wealth Management, LLC (“Caliber Wealth” or the “Adviser”) is a registered investment adviser with the
U.S. Securities and Exchange Commission (“SEC”). Caliber Wealth is organized as a Limited Liability Company
(LLC) under the laws of the State of Utah. Caliber Wealth was founded in September 2014, and is owned by 112
Ventures LLC and Nuttall Holdings, Inc and operated by David Gardner (Managing Partner) and Todd Nuttall
(Managing Partner and Chief Compliance Officer). Effective January 1, 2024, Falcon Park Capital (“FPC”)
purchased the assets of Caliber Wealth. During 2024, the Adviser will be moving Caliber Wealth’s clients and
their accounts into one of FPC’s affiliated registered investment advisers, Diversify Wealth Management. For
additional information on Diversify Wealth Management, clients are encouraged to review their Form ADV Part
2A.
B. Advisory Services Offered
Caliber Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates,
businesses, and retirement plans (each referred to as a “Client”).
The Adviser serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Adviser upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Caliber Wealth’s fiduciary commitment is further described in the Code of Ethics. For more
information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
Caliber Wealth 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. Caliber Wealth 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. Caliber Wealth
will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-
traded funds (“ETFs”) to achieve the Client’s investment goals. The Adviser may also utilize individual stocks,
bonds or margin to meet the needs of its Clients. The Adviser may retain certain types of investments based on a
Client’s legacy investments based on portfolio fit and/or tax considerations.
Caliber Wealth’s investment approach is primarily long-term focused, but the Adviser may buy, sell or re-allocate
positions that have been held less than one year to meet the objectives of the Client or due to market
conditions.
Caliber Wealth 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 Adviser.
Caliber Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Caliber Wealth may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Caliber Wealth may recommend specific positions to increase sector or asset class
weightings. The Adviser may recommend employing cash positions as a possible hedge against market
movement. Caliber Wealth 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.
At no time will Caliber Wealth 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 Adviser may recommend that a
Client rollover its retirement plan account into an account managed by the Adviser. In such instances, the
Adviser 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 if the Adviser 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 Adviser.
Use of Independent Managers – Caliber Wealth 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, based on the Client’s needs and objectives. In such instances, the Client will be
required to authorize and enter into an investment management agreement with an Independent Manager that
defines the terms in which the Independent Manager will provide its services. The Adviser will perform initial and
ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned
with Client’s investment objectives and overall best interests. The Adviser will also assist the Client in the
development of the initial policy recommendations and managing the ongoing Client relationship. The Client,
prior to entering into an agreement with an Independent Manager, will be provided with the Independent
Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning Services
Caliber Wealth will typically provide a variety of financial planning and consulting services to Clients as a
component of investment management services. 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.
Caliber Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their
unique situation. For certain financial planning engagements, the Adviser will provide a written summary of the
Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the
Adviser may not provide a written summary.
Financial planning and consulting recommendations pose a conflict between the interests of the Adviser and the
interests of the Client. For example, the Adviser has an incentive to recommend that Clients engage the Adviser
for investment management services or to increase the level of investment assets with the Adviser, as it would
increase the amount of advisory fees paid to the Adviser. Clients are not obligated to implement any
recommendations made by the Adviser or maintain an ongoing relationship with the Adviser. If the Client elects
to act on any of the recommendations made by the Adviser, the Client is under no obligation to implement the
transaction through the Adviser.
Retirement Plan Advisory Services
Caliber Wealth provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and
the company (the “Plan Sponsor”). The Adviser’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
● Investment Oversight (ERISA 3(21))
● Performance Reporting
● Ongoing Investment Recommendation and Assistance
● Benchmarking Services
These services are provided by Caliber Wealth 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 Caliber Wealth’s fiduciary status, the specific services
to be rendered and all direct and indirect compensation the Adviser reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Caliber Wealth to provide investment advisory services, each Client is required to enter into
one or more agreements with the Adviser that define the terms, conditions, authority and responsibilities of the
Adviser and the Client. These services may include:
● Establishing an Investment Strategy – Caliber Wealth, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
● Asset Allocation – Caliber Wealth 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 – Caliber Wealth will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
● Investment Management and Supervision – Caliber Wealth will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Caliber Wealth does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Caliber Wealth.
E. Assets Under Management
As of December 31, 2023, Caliber Wealth manages $503,230,120 in Client assets, $348,974,120 of which is
managed on a discretionary basis and $154,256,000 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Adviser.