A. Description of the Advisory Firm
This firm has been in business since March 1, 2011. Sal Kargodorian, the principal
owner, has been providing personalized investment management, analysis and
consulting services for over 20 years to 401(k), Pension and Profit Sharing Plans and
their plan sponsors and to individuals, trusts, estates, charitable organizations,
corporations and other business entities.
B. Types of Advisory Services
Golden K Wealth Management, LLC (hereinafter “Golden K”) offers two investment
advisory services – Retirement Plans Services and Investment Management Services:
Retirement Plans Services
Golden K utilizes a strategic approach to help Qualified Plan sponsors manage all
aspects of their retirement plans:
Golden K can be an ERISA 3(38) fiduciary to the plan and therefore plan
sponsors can delegate the fiduciary responsibility.
We can help plan sponsors decide whether to delegate Fiduciary Responsibility
or not. Differentiate ERISA 3(21) fiduciary vs. ERISA 3(38) fiduciary.
Assist employers in the implementation and maintenance of a program
structured to promote fiduciary excellence and ERISA compliance.
Fiduciary Education to Employers, Investment Committees, and Employees
Benchmark the current retirement plan to determine its competitiveness from an
administrative, investment and cost effective standpoint.
Establish a process to plan and document fiduciary control activities and
responsibilities.
Investment Due Diligence: Determine and select the appropriate investment
selection(s) to optimize asset allocation utilizing various software tools.
Monitor current investment selections and work with the retirement plan
committee to develop and maintain the plan's investment strategy, through an
investment policy statement. This investment policy statement is used as a guide
to evaluate current investment offerings, measuring them against applicable
indices, existing provider's complete menu and the broader universe of
investment options.
Develop an on-going investment education program for plan participants
Investment Management Services
Golden K offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. Golden K 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 (the Investment Policy
Statement) to aid in the selection of a portfolio that matches each client’s specific situation.
Investment Management Services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
Golden K evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. Risk tolerance levels are documented in the Investment
Policy Statement, which is given to each client.
Services Limited to Specific Types of Investments
Golden K limits its money management to mutual funds, equities, bonds, fixed income,
debt securities, ETFs, REITs, government securities and interests in partnerships and
limited liability companies investing in real estate. Golden K may use other securities
as
well to help diversify a portfolio when applicable.
Golden K Real Estate Partners II, LLC
Sal Kargodorian is the managing member of and the investment adviser to Golden K Real
Estate Partners II, LLC (“Vehicle”) representing discretionary private equity real estate
funds and separately managed accounts formed for the purpose of investing in other
private equity real estate ventures. The Vehicle targets real estate investments in which
risk-adjusted returns may potentially be achieved through investing with small and mid-
size local operators and sector specialists. The Vehicle provides scale for investors in this
segment of the market by establishing programmatic and/or long-standing relationships
with the real estate operators.
Sal Kargodorian has executed this strategy since Golden K Real Estate Partners II, LLC’s
formation over two years ago investing in real estate equity and debt investments, core-
plus, value-add and opportunistic strategies across property types and markets within the
United States. The Vehicle does this by applying its thesis-driven investment approach to
identify the specific real estate strategies and asset classes that provide risk-adjusted
returns within a given market, and then collaborates with local operating partners and
sector specialists to source, underwrite, and asset manage the investments.
ERISA Plan Services
Golden K Plans & Wealth Management is a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (ERISA) with respect to investment management
services and investment advice provided to ERISA plan clients, including ERISA plan
participants. Golden K Plans & Wealth Management is also a fiduciary under the Internal
Revenue Code (IRC) with respect to investment management services and investment
advice provided to ERISA plans, ERISA plan participants, IRAs and IRA owners
(collectively, “Retirement Account Clients”). As such, Golden K Plans & Wealth
Management is subject to specific duties and obligations under ERISA and the IRC that
include, among other things, prohibited transaction rules which are intended to prohibit
fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it
has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely
upon a prohibited transaction exemption (PTE).
C. Client Tailored Services and Client Imposed Restrictions
Golden K offers the same suite of services to all of its clients. However, specific client
financial plans and their implementation are dependent upon the client Investment Policy
Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels) and is used to construct a client specific plan to aid in the selection of a
portfolio that matches restrictions, needs, and targets.
Clients may not impose restrictions in investing in certain securities or types of securities
in accordance with their values or beliefs.
D. Wrap Fee Programs
Golden K does not participate in any wrap fee program.
E. Amounts Under Management
As of December 2023, Golden K has the following assets under management:
Type of Account Amount
Discretionary Accounts $77,609,764
Non-Discretionary Accounts $55,117,487
TOTAL $132,727,251