A. Firm Information
Naviter Wealth, LLC (“Naviter” 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.
Naviter was founded in November 2020 and is a wholly-owned subsidiary of Naviter Holdings, LLC. Bentley E. Blackmon,
through various intermediate subsidiaries, is the majority owner of Naviter Holdings, LLC. The Disclosure Brochure provides
information regarding the qualifications, business practices, and advisory services provided by Naviter.
Naviter is operated by Bentley E. Blackmon (Chief Executive Officer), Lyndell (Phillip) Worthen (President), Daniel Russell
(Chief Compliance Officer), John Kornet (Chief Investment Officer), and Jordan Bauer (Chief Operating Officer).
B. Advisory Services Offered
Naviter offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, charitable
organizations, broker/dealers, 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 toward each Client and seeks to mitigate potential conflicts of interest. Naviter’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
Naviter provides customized investment advisory solutions for its Clients. This is achieved through frequent personal
Client contact and interaction while providing financial planning, discretionary investment management and related advisory
services. Naviter works closely with each Client to identify their investment goals and objectives as well as risk tolerance and
financial situation in order to design a portfolio strategy.
Financial Planning Services – Naviter will typically provide a variety of financial planning and consulting services to Clients, as
a component of its wealth management services. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. This planning or consulting may encompass one or more areas of need, including but
not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other
areas of a Client’s financial situation. Naviter may also refer Clients to an accountant, attorney or other specialists, as
appropriate for their unique situation.
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.
Investment Management Services – Naviter 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. Naviter works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy.
Naviter will then construct an investment portfolio utilizing various portfolio management tools (i) models through the
Unified Managed Account (“UMA”) Program offered through Envestnet Asset Management Inc’s (“Envestnet”) private wealth
management platform, (ii) models through the Advisor/TAMP (Turnkey Asset Management Provider) Traded Program offered
via Envestnet, (iii) trade execution via Charles Schwab & Co.’s trading platform/desk (iv) a combination thereof, based on each
Client’s needs and objectives.
(i) In the UMA program, the Client is offered a single portfolio that accesses multiple asset managers and investment
vehicles, representing various asset classes, and that is customized by the Advisor based on the Client’s profile and
investment goals. Once the Advisor has established the portfolio for each Client, the Advisor will utilize its
discretionary authority to instruct Envestnet to execute trade orders based on the investment strategies contained
in the UMA portfolio and provide additional overlay management services. Please see Item 12 – Brokerage
Practices for additional information.
(iv) For custom portfolios, the Advisor will primarily utilize low-cost, diversified exchange-traded funds (“ETFs”),
individual stocks, and mutual funds. The Advisor also uses bonds, independent managers, interval funds,
structured products, and private funds, including direct placement investments, to meet the needs of its Clients.
On limited instances, the Advisor may utilize margin, options contracts, and lines of credit.
If a Client decides to become a private fund investor, the amount of assets invested in the private fund[s] shall be included as
part of “assets under management” for purposes of the Advisor calculating its investment advisory fee. The Advisor’s Clients
are under no obligation to consider or make an investment in a private fund. Additionally, Naviter may also recommend that
Clients engage with various third parties with whom the Client will then enter into an agreement with to gain access to private
funds. Naviter will continue to provide oversight of the Clients investment and ongoing monitoring of the activities performed
by the third parties. Finally, the Advisor may retain certain types of investments based on a Client’s legacy investments based on
portfolio fit and/or tax considerations.
Naviter’s investment strategies are primarily long-term focused, but the Advisor may buy, sell, re-allocate or tax-loss harvest
positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Naviter
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.
Naviter evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process.
Naviter may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Naviter 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. Naviter 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.
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.
Use of Independent Managers – Naviter may also recommend that 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. In such
instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s]
that defines the terms in which the Independent Manager[s] will provide investment management and related
services. The Advisor may also assist in the development of the initial policy recommendations and managing the
ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected
Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned investment
objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s]
or investment platform[s], will be provided with the Independent Manager’s Form ADV 2A (or a brochure that makes the
appropriate disclosures).
Lines of Credit – Under certain circumstances, Clients of Naviter utilize a line(s) of credit. The capabilities of Charles Schwab
Banking & Trust Services, Tristate Capital Bank, and Advisor Credit Exchange, LLC ("ACE") are the typical avenues for access to
collateral at Naviter. In such instances, Client assets in their account[s] at the Custodian will be utilized as collateral for the
loan. Additionally, the Advisor is entitled to receive investment advisory fees for managing the collateralized assets in the
Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional information related
to the risks involved with loans and lines of credit, please see Item 8 – Methods of Analysis, Investment Strategies and Risk of
Loss.
Trust Fiduciary Services – When deemed to be in the Client’s best interest, Naviter may offer certain Clients access to custody
and trust administrative services through National Advisors Holdings, Inc. and its various subsidiaries (“NAH”) under the
business name of Naviter Trust. Clients will enter into a separate agreement with NAH. Naviter will serve as the investment
manager to any accounts established with NAH and earn an investment management fee as noted above. Naviter does not
serve as a trustee for any account relationships.
At no time will Naviter 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.
Financial Institution Consulting Services – Naviter provides investment consulting services to brokerage customers (herein
“Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the
Advisor’s consulting services pursuant to a written agreement with the Advisor. Please see Item 10 – Other Financial Industry
Activities and Affiliations for additional details.
Retirement Plan Advisory Services – Naviter 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 available include:
Vendor Analysis
Plan Participant Enrollment and Education Tracking
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Oversight and/or Management (ERISA 3(21) and 3(38))
Performance Reporting
Ongoing Investment Recommendation and Assistance
These services are provided by Naviter 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 Naviter’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 Naviter 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 – Naviter, in connection with the Client, will develop a strategy that seeks to
achieve the Client’s goals and objectives.
Asset Allocation – Naviter 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 – Naviter will develop a portfolio for the Client that is intended to meet the stated goals and
objectives of the Client.
Investment Management and Supervision – Naviter will provide investment management and ongoing oversight
of the Client’s investment portfolio.
D. Wrap Fee Programs
Naviter does not manage or place Client assets into a wrap fee program. Investment management services are provided
directly by Naviter.
E. Assets Under Management
As of April 24, 2024, the Advisor manages $1,310,303,000 in Client assets, all of which are managed on a discretionary basis.
Clients may request more current information at any time by contacting the Advisor.
These figures (rounded to the nearest $1,000) are based on the net asset values of our clients’ securities (including hedge funds
and private investments) as reported to us by the investment managers.
In addition to our Regulatory Assets under Management, we also maintain relationships with many of our clients where we
engage in proactive and ongoing leadership of the client’s asset management on a non-discretionary basis, however, these
assets are not considered Regulatory Assets under Management by the U.S. Securities and Exchange Commission.