Complete Advisors is a new investment advisor firm formed in 2019 and is registered with the
U.S. Securities and Exchange Commission since March 2020. The principal owners of the firm
are Evan M. Levine, Co-Owner and Chief Compliance Officer, and Nainesh A. Shah, Co-Owner.
Advisory Services
Complete Advisors’ (“Advisor”) principal service is providing fee-based investment advisory
services. The Advisor practices custom management of portfolios, on a discretionary basis,
according to the client’s objectives. The advisor’s primary approach is to design portfolios that
provide investors with sufficient confidence in reaching their stated goals. A strategic, not
tactical, approached is employed. Generally, changes are made to the portfolio if an investment
vehicle is discovered that better represents a broad asset class - or offers the same representation
at a lower cost. Changes also may occur if an investors overall financial situation and/or goals &
objectives change. Rebalancing occurs when there is significant drift from the original allocation
targets. Changes are rarely based on anticipating the short-term direction of the markets or
economy. The Advisor 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, or any risk deemed unacceptable for the client’s risk tolerance.
The Advisor may use exchange listed securities, over-the-counter securities, foreign securities,
warrants, corporate debt securities, CDs, variable life insurance, variable annuities, municipal
securities, mutual funds, United States government securities, and options on securities to
accomplish this objective. Advisor measures and selects mutual funds, ETF’s and separate
accounts based on tracking error relative to the index and expenses.
Qualified Retirement Plan Consulting Services
Complete Advisors provides services to qualified retirement plans either as a 3(21) limited scope
fiduciary or 3(38) full scope fiduciary, including employee communication and education
programs, and the investment selection and monitoring process, including its investment policy
statement, hereinafter referred to as the “IPS”. With regard to the IPS, the Advisor will assist the
Plan Sponsor in adopting a suitable IPS, amending it from time to time, and will provide
information and recommendations, consistent with the IPS, to aid the Plan Sponsor in selecting
and monitoring investments offered to Participants in the Plan.
The Advisor's roles and actions in fulfilling all responsibilities pertaining to qualified plan
services shall not include those of the Plan's Trustee, and will be performed solely at the
direction of the Plan Sponsor, its authorized officers, employees and/or agents. At no time will
the Advisor accept, maintain possession of, or have custodial responsibility for, the Plan's assets.
The Advisor will not conduct or effect the purchase or sale of any assets of the Plan on behalf of
the Plan Sponsor or Plan Participants. As part of its services to the Plan, the Advisor will
provide investment education to Plan Participants, but will not provide specific investment
advice to any Participant, person or entity related to the Plan other than the Plan Sponsor, except
where
the Participant, person or entity is separately an advisory client of the Advisor.
Communicational and educational activities in which the Advisor engages related to Participants
in the Plan shall be solely at the direction of the Plan Sponsor, and shall not be represented by the
Advisor or Plan Sponsor as investment, tax or legal advice. The Advisor is not licensed to
provide, shall not provide, nor be construed to provide, the services of an attorney or accountant.
Selection of Other Advisors
Complete Advisors may recommend and refer clients to unaffiliated strategists and money
managers or investment advisors through Managed Account programs sponsored by a third-party
provider. In these arrangements, the Client will then enter into a program and investment
advisory agreement with the program sponsor and sub-advisors. Complete Advisors will assist
and advise the Client in establishing investment objectives for the sub-advisors and continue to
provide oversight of the Client account and ongoing monitoring of the activities of the sub-
advisors. The sub-advisors will develop an investment strategy to meet those objectives by
identifying appropriate investments and monitoring such investments. In consideration for such
services, the program sponsor will charge a program fee that includes the investment advisory
fee of the sub-advisors, the administration of the program and trading, clearance and settlement
costs. The program sponsor will add Complete Advisors’ investment advisory fee (described
below in the answer to Item 5) and will deduct the overall fee from the Client account quarterly
in advance based on the fair market value at the end of the preceding quarter.
The Client, prior to entering into an agreement with a Managed Account program sponsored by a
third-party provider, will be provided with the program sponsor's Brochure that makes the
appropriate disclosures. In addition, Complete Advisors and its Client will agree in writing that
the selected program sponsor will manage the Client's account on a discretionary basis.
Financial Planning
Complete Advisors provides Financial Planning services. The Advisor's Financial Planning
services may include recommendations for portfolio customization based on their client's
investment objectives, goals and financial situation. Financial planning services will also
include: Preparation of family balance sheet and income statement, Monte Carlo style analysis,
Overall asset allocation assessment, Insurance and estate planning review as well as Social
security and Medicare consulting with 3rd party specialists.
Business Consulting Services
The Advisor also provides non-investment related business consulting services to small
businesses on topics including business valuations, strategy, and operational effectiveness.
Complete Advisors will tailor its advisory services to its client’s individual needs based on
meetings and conversations with the client. If clients wish to impose certain restrictions on
investing in certain securities or types of securities, the Advisor will address those restrictions
with the client to have a clear understanding of the client’s requirements.
Complete Advisors does not provide portfolio management services to wrap fee programs.
As of December 31, 2023, Complete Advisors had $54,527,000 in discretionary and $20,954,000
in non-discretionary client assets under management.