A. Salvus Wealth Management, LLC, (“Salvus”) is a New Jersey limited liability company formed on
June 5, 2014. Salvus was initially registered as an investment adviser with the New Jersey Bureau of
Securities and various other state agencies starting in 2014. Salvus then became registered as an
investment adviser with the United States Securities and Exchange Commission effective July 26,
2019. Salvus’ principal owners are Charles T. Woolston, Salvus’ Managing Member and Chief
Executive Officer; and Robert W. Joel, Salvus’ Chief Compliance Officer, and Chief Investment
Officer.
B. Salvus offers investment advisory services, financial planning and consulting services, and retirement
plan consulting services to its clients who currently include individuals, high net worth individuals,
pension & profit sharing plans, trusts, estates, corporations, or other businesses.
INVESTMENT ADVISORY SERVICES
Clients engage Salvus to provide discretionary and non-discretionary investment advisory services on
a fee basis. Salvus’ annual investment advisory fee is based upon a percentage of the market value of
the assets placed under its management. When engaging Salvus to provide investment advisory
services, clients enter into an Investment Advisory Agreement with Salvus setting forth the terms and
conditions of the engagement, describing the scope of the services to be provided, and the fee that is
due from the client. Salvus’ annual investment advisory fee compensates for investment advisory
services and general financial planning and consulting services that is ancillary to the investment
advisory process. If Salvus determines in its sole discretion that a client is seeking or requires
planning and consultation services that exceed the anticipated scope of the engagement, Salvus may
seek to provide those services to the client under the terms and conditions of a separate Financial
Planning Agreement.
Salvus tailors its investment advisory services to the specific needs of each client. To begin the
engagement, an investment adviser representative will coordinate with each client to develop their
investment objectives which are based upon an assessment of factors that typically include: capital
preservation; risk tolerance; income production; liquidity requirements; client preferences; asset and
liability levels; and investment restrictions. Then, Salvus will allocate and/or recommend that the
client allocate investment assets consistent with the designated investment objectives. Salvus
primarily allocates or recommends that clients allocate investment assets among individual equities
(stocks), debt (bonds), mutual funds, institutional and/or investor class funds, sub-advisers, and/or
exchange traded funds (“ETFs”), on a discretionary basis in accordance with the client’s designated
investment objectives. Salvus may also allocate the discretionary management of client investment
assets to sub-advisers or independent managers as described in Item 4.B. below. To a limited extent
when appropriate, Salvus may also recommend that clients consider allocations to private investment
funds on a non-discretionary basis.
Once client investment assets are allocated, Salvus provides ongoing monitoring and review of
account performance and asset allocation as compared to client-designated investment objectives and
may execute or recommend executing account transactions as a result of those reviews or upon other
triggering events.
Salvus generally allocates client investment assets in conformity with one or more of the following
investment strategies, which are subject to change at Salvus’ discretion based upon market
conditions:
Growth and Income: This strategy is appropriate for investors who primarily seek long term capital
appreciation with a secondary interest in the generation of current income for the appliable
account(s). Moderate annual fluctuation of principal is expected and acceptable. It will generally be
comprised of actively managed mutual funds and may at times contain passively managed mutual
funds and exchange traded funds.
Income and Growth: This strategy is appropriate for investors who primarily seek the generation of
current income with a secondary interest in long term capital appreciation for the appliable
account(s). Modest annual fluctuation of principal is expected and acceptable. It will generally be
comprised of actively managed mutual funds and may at times contain passively managed mutual
funds and exchange traded funds.
Capital Preservation: This strategy is appropriate for investors who primarily seek to preserve capital
and while maintaining a lower investment risk level and higher liquidity for the appliable account(s).
This strategy typically invests in shorter-term US treasury bills with approximately a one year
maturity or less, along with short-term bond funds, cash, and/or cash equivalents. Not all clients will
qualify for this strategy. Salvus does not recommend this strategy if it anticipates that funds should be
invested elsewhere within 12 months, or if a client is not seeking to invest sufficient capital in this
strategy under their unique financial circumstances.
The Growth and Income, and Income and Growth strategies may involve above-average portfolio
turnover, which could negatively impact upon the net after-tax gain experienced by an individual
client in a taxable account.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
Salvus may also provide financial planning and consulting services (including investment and non-
investment related matters, including estate planning, tax planning, insurance planning, etc.) on a
stand-alone separate fee basis. To engage Salvus for this service, clients enter into a Financial
Planning and Consulting Agreement with Salvus setting forth the terms and conditions of the
engagement, describing the scope of the services to be provided, and the portion of the fee that is due
from the client before Salvus begins to provide services.
RETIREMENT PLAN CONSULTING SERVICES
Salvus also provides retirement plan consulting services to sponsors of self-directed retirement plans
and defined benefit plans organized under the Employee Retirement Security Act of 1974 (“ERISA”).
Salvus performs these services in an ERISA Section 3(21) capacity, by assisting with the
development of investment policy statements, and then the selection and monitoring of investment
alternatives from which plan participants may choose in self-directing the investments for their
individual plan retirement accounts. Upon request by the plan sponsor, Salvus may also provide
participant education designed to assist participants in identifying the appropriate investment strategy
for their retirement plan accounts. The terms and conditions of the engagement between Salvus and
the plan sponsor will be set forth in a Retirement Plan Services Agreement.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Salvus
may recommend the services of other professionals for certain non-investment implementation
purposes (i.e., attorneys, accountants, insurance, etc.). Salvus does not serve as a law firm, accounting
firm, or insurance agency, and no portion of Salvus’ services should be construed as legal,
accounting, or insurance implementation services. Accordingly, Salvus does not prepare estate
planning documents, tax returns, or
sell insurance products. Unless specifically agreed in writing,
neither Salvus nor its representatives are responsible to implement any financial plans or financial
planning advice; provide ongoing financial planning services; or provide ongoing monitoring of
financial plans or financial planning advice. Salvus’ financial planning and consulting services are
completed upon communicating its recommendations to the client, upon delivery of the written
financial plan, or upon termination of the applicable agreement. To the extent requested by a client,
Salvus may recommend the services of other professionals for certain non-investment implementation
purposes (i.e., attorneys, accountants, insurance agents, etc.) including entities under common control
with Salvus to provide accounting services. Those recommendations present conflicts of interest,
because they could be made based on the commissions or revenues generated, rather than the client’s
particular need. Clients are under no obligation to engage the services of any recommended
professional who is responsible for the quality and competency of the services they provide. The
client retains absolute discretion over all financial planning and related implementation decisions and
is free to accept or reject any recommendation from Salvus and its representatives in that respect.
Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client
leaving an employer has four options regarding an existing retirement plan (and may engage in a
combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii)
roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll
over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). If Salvus recommends that a
client roll over their retirement plan assets into an account to be managed by Salvus, such a
recommendation creates a conflict of interest if Salvus 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 Salvus.
ERISA / IRC Fiduciary Acknowledgment. When Salvus provides investment advice to a client about
the client’s retirement plan account or individual retirement account, it does so as a fiduciary within
the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the
Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts.
Because the way Salvus makes money creates some conflicts with client interests, Salvus operates
under a special rule that requires it to act in the client’s best interest and not put its interests ahead of
the client’s. Under this special rule’s provisions, Salvus must: meet a professional standard of care
when making investment recommendations (give prudent advice); never put its financial interests
ahead of the client’s when making recommendations (give loyal advice); avoid misleading statements
about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure
that Salvus gives advice that is in the client’s best interest; charge no more than is reasonable for
Salvus’ services; and give the client basic information about conflicts of interest.
Asset Aggregation / Reporting Services. Salvus may provide access to reporting services through one
or more third-party aggregation / reporting platforms that can reflect all of the client’s investment
assets, including those investment assets that the client has not engaged Salvus to manage (the
“Excluded Assets”). Salvus’ service for the Excluded Assets is strictly limited to reporting, and
specifically excludes investment management or implementation. Because Salvus does not have
trading authority for the Excluded Assets, it cannot be responsible for the performance or related
activity (such as timing and trade errors) related to the Excluded Assets. The third-party aggregation /
reporting platforms may also provide access to financial planning information and applications, which
should not be construed as services, advice, or recommendations provided by Salvus. Accordingly,
Salvus will not be held responsible for any adverse results a client may experience if the client
engages in financial planning or other functions available on the third party reporting platforms
without Salvus’ participation or oversight.
Portfolio Trading Activity / Inactivity. Salvus will review client portfolios on an ongoing basis to
determine if any trades are necessary based upon various factors, including but not limited to
investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s
financial circumstances, and changes in the client’s investment objectives. Based upon these and
other factors, there may be extended periods when Salvus determines that upon review, trades within
a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees described in Item 5
during periods of portfolio trading inactivity.
Client Obligations. When performing services, Salvus is not required to verify any information it
receives from the client or their designated professionals, and Salvus is expressly authorized to rely
on that information. Clients are responsible to promptly notify Salvus if there is ever any change in
their financial situation or investment objectives for the purpose of reviewing or revising Salvus’
recommendations and services.
C. Salvus provides investment advisory services specifically tailored to the needs of each client. Before
providing investment advisory services, an investment adviser representative will ascertain each
client’s investment objectives. Then, Salvus allocates and/or recommend that the client allocate
investment assets consistent with the designated investment objectives. The client may, at any time,
impose reasonable restrictions, in writing, on Salvus’ services.
D. Salvus does not participate in a wrap fee program. However, Salvus may allocate or recommend that
the client allocate a portion of their investment assets among unaffiliated Independent Managers
through the Fidelity Managed Account Xchange℠ or similarly named/successor platform, which
operates on a wrap-fee basis. Under a wrap program, the wrap program sponsor arranges for the
investor participant to receive investment advisory services, the execution of securities brokerage
transactions, custody, and reporting services for a single specified fee. Participation in a wrap
program may cost the participant more or less than purchasing such services separately. Since the
custodian/broker-dealer is determined by the unaffiliated wrap program sponsor, Salvus will be
unable to negotiate commissions and/or transaction costs, and/or seek better execution. As a result,
clients may pay higher commissions or other transaction costs or greater spreads or receive less
favorable net prices on transactions for the account than would otherwise be the case through
alternative clearing arrangements recommended by Salvus. Higher transaction costs adversely impact
account performance.
E. As of December 31, 2023, Salvus had $260,514,229 in assets under management on a discretionary
basis.