A. Firm Information
The Wealth Alliance, LLC (“WA” 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 (“LLC”) under the laws of
the State of Delaware in December 2018 and became a registered investment advisor in August 2019. WA is
owned by Wealth Alliance Holdings, LLC which is owned equally by RJC Financial LLC and E-Ditty Financial
LLC. Robert Conzo is the primary owner of RJC Financial LLC. Eric Diton is the primary owner of E-Ditty
Financial LLC. This Disclosure Brochure provides information regarding the qualifications, business practices,
and the advisory services provided by WA.
B. Advisory Services Offered
WA offers investment advisory services designed to meet the needs of individuals, high net worth individuals and
families as well as trusts, estates, 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. WA’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
WA 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. WA works with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create an investment strategy. WA will then design an investment
strategy that may include the Advisor’s internal investment management and/or the use of unaffiliated investment
managers and investment platforms (herein collectively referred to as “Independent Managers”).
Internal Management – WA will construct Client portfolios utilizing mutual funds, exchange-traded funds (“ETFs”),
individual equities, individual bonds and alternative investments. The Advisor may also utilize other types of
investments, as appropriate, to meet the needs of the Client. WA may retain certain legacy investments based on
portfolio fit and/or tax considerations.
WA’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
investments that have been held for less than one year to meet the objectives of the Client or due to market
conditions. WA 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.
WA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. WA may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. WA 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. WA 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 Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
At no time will WA accept or maintain custody of a Client’s funds or securities, except for the limited authority as
detailed 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.
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Use of Independent Managers – WA will regularly recommend a Client utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment portfolio. The use of an Independent Manager is based on the Client’s needs, objectives, financial
situation and other factors. WA often recommends Adhesion Wealth Advisor Solutions (“Adhesion”) and its
related entities (herein Adhesion), 55I, LLC d/b/a 55ip (“55ip”). The Client is typically required to authorize and
enter into a platform services and investment management agreement with the Independent Manager that
defines the terms of services, level of authority granted to the Independent Manager and the fees to be charged
to the Client. The Advisor will perform initial and ongoing oversight and due diligence over each Independent
Manager to ensure the platform and selected investment strategies remain aligned with Clients investment
objectives and overall best interests. The Advisor will also assist the Client in developing and maintaining the
investment allocations and managing the ongoing Client relationship. The Client will be provided with the
Independent Manager's Form ADV Part 2A – Disclosure Brochure (or a brochure that makes the appropriate
disclosures).
Participant Account Management – As part of the Advisor’s Investment Management Services, when
appropriate, the Advisor will use a third-party platform to facilitate management of held away assets such as
defined contribution plan participant accounts, with discretion. The platform allows the Advisor to avoid being
considered to have custody of Client funds since the Advisor does not have direct access to Client log-in
credentials to affect trades. The Advisor is not affiliated with the platform in any way and do not receive
compensation from them for using their platform. A link will be provided to the Client allowing them to connect an
account(s) to the platform. Once Client account(s) is connected to the platform, the Advisor will review the
current account allocations. When deemed necessary, the Advisor will rebalance the account considering client
investment goals and risk tolerance, and changes in allocations will take into account current economic and
market trends. Client account(s) will be reviewed at least quarterly and allocation changes will be made as
deemed necessary.
Retirement
Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is 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. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Financial Planning Services
WA will typically provide a variety of financial planning and consulting services to Clients, either as a component
of investment management services or for a separate engagement and fee. The Advisor, at its sole discretion,
may waive its financial planning fee for investment management Clients. Services are offered in several areas of
a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services
will involve preparing a financial plan or rendering a 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, estate 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. WA may also refer Clients to
an accountant, attorney or other specialist, as appropriate for their unique situation. For consulting or ad-hoc
engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed
within six months of contract date, assuming all information and documents requested are provided promptly.
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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.
Retirement Plan Advisory Services
WA provides retirement plan advisory services on behalf of the 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 Assistance
• Investment Policy Statement (“IPS”) Design and Monitoring and Review
• Investment Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
These services are provided by WA 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 WA’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 WA 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 – WA, in connection with the Client, will develop a strategy targeted
to achieve the Client’s investment goals and objectives.
• Asset Allocation – WA 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 – WA will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
• Investment Management and Supervision – WA will provide investment management and ongoing
oversight of the Client’s portfolio.
D. Wrap Fee Programs
WA includes, in addition to securities transaction fees for certain mutual funds, custodial costs, independent
managers fees, administrative fees (herein “Covered Costs”) together with its investment advisory fees. Including
these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its
investment management services for its Clients. The Advisor sponsors the WA Wrap Fee Program solely as a
supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the
Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own
transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is always included as a
supplement to this Disclosure Brochure.
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E. Assets Under Management
As of December 31, 2023 WA manages $1,703,650,906 in Client assets, all of which are managed on a
discretionary basis. Client’s may request more current information at any time by contacting the Advisor.