A. Firm Information
Concord Asset Management, LLC (“CAM” 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 Commonwealth of Virginia. CAM was founded in October 2020. Concord Wealth Holdings,
LLC is the primary owner of CAM. Strategic Services, LLC is also an owner of CAM. The controlling shareholder of
Concord Wealth Holdings, LLC is Jonathan Wade Lopez.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by CAM. If you have any questions about this Disclosure Brochure, please contact Jonathan R.
Weatherly, Chief Compliance Officer by phone at 276-628-5910 or 800-838-4370, or by email at
[email protected].
B. Advisory Services Offered
CAM offers investment advisory services to other registered investment advisors (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. CAM'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.
CAM provides customized investment sub-advisory solutions for its Clients, per the terms and conditions of a
written Sub-Advisory Agreement. This is achieved through continuous personal Client contact and interaction while
providing discretionary investment management services. CAM works closely with each Client to identify the
investment sub-advisory mandates that it shall employ. The Client and the Advisor work closely to define the
investment policy and related portfolio requirements. CAM will then construct one or more investment portfolios,
consisting of exchange-traded funds (“ETFs”), individual stocks, individual bonds, mutual funds, options and/or
alternative investments that seeks to achieve the results of the sub-advisory mandates. For certain Clients, these
investment mandates can be customized further to the needs of the Client’s underlying investor relationships. The
Client [other Registered Investment Advisor], who is CAM’s sole Client for these services, is responsible for
determining whether a particular investment strategy is appropriate for each underlying investor client. The Advisor
may retain certain types of investments based on the Client’s instructions.
CAM’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. CAM will
construct, implement and monitor the portfolio to ensure it meets the stated investment objectives. The Client is
responsible to confirm suitability with each underlying investor’s goals, objectives, circumstances, and risk
tolerance agreed to by the Client. CAM will allow the Client to place reasonable restrictions on the types of
investments to be held in their respective portfolio, subject to acceptance by the Advisor.
CAM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. CAM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. CAM
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. CAM 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.
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At no time will CAM 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 management agreement. Please see Item 12 – Brokerage Practices.
The unaffiliated investment advisers that engage CAM’s sub-advisory services shall maintain both the initial and
ongoing day-to-day relationship with the underlying client, including initial and ongoing determination of client
suitability for CAM’s designated investment strategies. If the custodian/broker-dealer is determined by the
unaffiliated investment adviser, CAM will be unable to negotiate commissions and/or transaction costs, and/or seek
better execution. As a result, client 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 CAM. Higher transaction costs adversely impact account
performance.
Unaffiliated Exchange Traded Fund: CAM recommends the Nationwide Risk-Managed income Exchange Traded
Fund (ETF) (Symbol: NUSI”) in connection with several of its model portfolios. A complete description of this ETF,
its strategy, objectives, and costs is set forth in the ETF’s then-current prospectus, a copy of which is available from
CAM. As the investment manager to the model portfolios, and pursuant to a sub-advisory agreement with CAM’s
affiliate, Concord Wealth Partners, LLC (“CWP”), CAM has discretionary authority to place client assets in various
models containing NUSI and recommended to CWP clients. Neither CAM, nor any of its supervised persons,
receive any economic benefit in connection with recommending NUSI in model portfolios. A potential conflict of
interest is presented where a member of Harvest Volatility Management, LLC (“Harvest”), a sub-advisor to NUSI,
serves as a business consultant to Edge Strategic Services, LLC, an owner of CAM. In connection with the
member’s consulting engagement with Edge Strategic Services, LLC, the member may also provide general advice
to CAM. The advice provided to either organization is generally limited to industry analyses and best practices,
manager investment strategies and use
of various product types. The member has no direct involvement with CAM
investment or portfolio allocation decisions. Thus, the member may receive an indirect economic benefit in their
role as a portfolio manager to Harvest, while also serving in a business consulting capacity on behalf of Edge
Strategic Services, LLC and providing guidance to CAM. The Member is not a supervised person of Concord Asset
Management and is not directly compensated by CAM for any services provided, however, the Member is indirectly
compensated based upon Harvest’s subadvisory fee to NUSI. Any potential conflict of interest is mitigated by
ensuring that CAM maintains an independent process for determining the assets to be recommended in its
portfolios. CAM is under no obligation to include the ETF in any portfolio.
Independent Managers. CAM may allocate (and/or recommend that the client allocate) a portion of a client’s
investment assets among unaffiliated independent investment managers (“Independent Manager(s)”) in
accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) will
5 have day-to- day responsibility for the active discretionary management of the allocated assets. CAM will
continue to render investment supervisory services to the client relative to the ongoing monitoring and review of
account performance, asset allocation and client investment objectives. CAM generally considers the following
factors when recommending Independent Manager(s): the client’s designated investment objective(s),
management style, performance, reputation, financial strength, reporting, pricing, and research. The investment
management fees charged by the designated Independent Manager(s) are exclusive of, and in addition to, CAM’s
ongoing investment advisory fee, which will be disclosed to the client before entering into the Independent Manager
engagement and/or subject to the terms and conditions of a separate agreement between the client and the
Independent Manager(s).
Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available directly to
the public. Therefore, a prospective client can obtain many of the funds that may be utilized by CAM independent of
engaging CAM as an investment advisor. However, if a prospective client determines to do so, he/she will not
receive CAM’s initial and ongoing investment advisory services. In addition to CAM’s investment advisory fee
described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual
fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other
fund expenses).
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Portfolio Activity. CAM has a fiduciary duty to provide services consistent with the client’s best interest. As part of
its investment advisory services, CAM will review client portfolios on an ongoing basis to determine if any changes
are necessary based 6 upon various factors, including, but not limited to, investment performance, fund manager
tenure, market conditions, style drift, account additions/withdrawals, and/or a change in the client’s investment
objective. Based upon these factors, there may be extended periods of time when CAM determines that changes to
a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in
Item 5 below during periods of account inactivity.
Trustee Directed Plans. CAM may be engaged to provide discretionary investment sub-advisory services to
ERISA retirement plans, whereby CAM shall manage Plan assets consistent with the investment objective
designated by the Plan trustees. In such engagements, CAM will serve as an investment fiduciary as that term is
defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). CAM will generally provide
services on an “assets under management” fee basis per the terms and conditions of an Investment Advisory
Agreement between CAM and the primary investment advisor Client.
Cash Positions. CAM continues to treat cash as an asset class. As such, unless determined to the contrary by
CAM, all cash positions (money markets, etc.) shall continue to be included as part of assets under management
for purposes of calculating CAM’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will
occur), CAM may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash,
such amounts could miss market advances. Depending upon current yields, at any point in time, CAM’s advisory
fee could exceed the interest paid by the client’s money market fund.
Client Obligations. In performing its services, CAM shall not be required to verify any information received from
the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client
is advised that it remains their responsibility to promptly notify the CAM if there is ever any change in their 7
financial situation or investment objectives for the purpose of reviewing, evaluating or revising CAM’s previous
recommendations and/or services.
Disclosure Statement. A copy of CAM’s written Brochure and Client Relationship Summary, as set forth on Part 2
of Form ADV, shall be provided to each client prior to the execution of any advisory agreement.
C. Client Account Management
Prior to engaging CAM to provide investment advisory services, each Client is required to enter into an investment
sub-advisory agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the
Advisor and the Client.
These services may include:
• Establishing an Investment Strategy – CAM, in connection with the Client, will develop investment
strategies that seeks to achieve the Client’s goals and objectives for its underlying investor[s].
• Portfolio Construction – CAM will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
• Investment Management and Supervision – CAM will provide investment management and ongoing
oversight of the Client’s investment portfolio.
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D. Wrap Fee Programs
CAM does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by CAM.
E. Assets Under Management
As of March 19, 2024, the Advisor had $ 406,040,358 in assets under management on a discretionary basis.