A. Firm Information
Snowwater Investment Partners, LLC (“Snowwater” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). The Advisor was organized as a Limited Liability Company
(“LLC”) under the laws of the State of Delaware in November 2020 and became a registered investment advisor
in January 2021. Snowwater is primarily owned by Bradford R. Orben (Founder, Managing Partner and Chief
Compliance Officer), Victor M. Flores (Managing Partner) and Snowwater Holdings, LLC (Member). Certain
underlying owners of Snowwater Holdings are also Clients of the Advisor. Please see Item 11 for additional
information.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Snowwater. For information regarding this Disclosure Brochure, please contact Bradford R.
Orben at (203) 997-6670.
B. Advisory Services Offered
Snowwater offers wealth management services which include investment management, financial consulting
and/or other advisory services to high-net-worth individuals, families and their related entities (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. Snowwater'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.
Wealth Management Services
Snowwater provides customized wealth management solutions for its Client’s. This is achieved through
continuous personal Client contact and interaction while providing discretionary investment management and
related financial planning services. Snowwater works closely with each Client to identify their investment goals
and objectives as well as risk tolerance and financial situation in order to create one or more portfolio strategies.
Snowwater constructs customized investment portfolios, consisting of diversified equity and fixed income
investments, hedge funds, private equity and structured notes. The Advisor may at times also utilize certain
exchange-traded funds (“ETFs”), open-end mutual funds, and/or other types of investments. The Advisor may
retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax
considerations.
Snowwater’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. Snowwater 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.
Snowwater evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Snowwater may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Snowwater 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. Snowwater
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 Snowwater 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 advisory agreement. Please see Item 12 – Brokerage Practices.
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 Consulting Services – Snowwater will typically provide a variety of financial consulting services to
Clients, pursuant to a written financial consulting agreement. Services are offered in several areas of a Client’s
financial situation, depending on their goals and objectives. Generally, such financial consulting services involve
preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial
goals and objectives. This consulting may encompass one or more areas of need, including but not limited to,
investment consulting, retirement consulting, personal savings, education savings, insurance needs, and/or 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.
Snowwater may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial consulting engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract
date, assuming all information and documents requested are provided promptly.
C. Client Account Management
Prior to engaging Snowwater 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 – Snowwater, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Snowwater 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 – Snowwater will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Snowwater will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Snowwater does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by Snowwater.
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E. Assets Under Management
As of December 31, 2023, Snowwater manages approximately $750,029,000 in assets under management, all of
which are on a discretionary basis. Clients may request more current information at any time by contacting the
Advisor.