A. Firm Information
Ouellette Wealth Advisory, LLC (“Ouellette” or the “Advisor” and also doing business as “Ouellette Wealth
Management Group”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
All advisory services are engaged exclusively through Ouellette. The Advisor is organized as a limited liability company
(“LLC”) under the laws of Massachusetts. Ouellette Wealth Advisory, LLC was founded in 2017 and is owned and
operated by, Thomas J. Ouellette. This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by Ouellette.
B. Advisory Services Offered
Ouellette Wealth Advisory, LLC offers investment advisory services to individuals, high net worth individuals,
charitable organizations, trusts, and estates (each referred to as a “Client”). Clients may receive services with respect to
investment accounts including IRAs which may be considered retirement assets.
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. Our fiduciary commitment is further described in our Code of Ethics. For more information
regarding 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.
Account Portfolio Management
Ouellette provides customized investment advisory solutions for its Clients. This is achieved through personal Client
contact and interaction while providing non-discretionary investment management and consulting services. Ouellette
works 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. Ouellette will then construct a portfolio, consisting of low‐cost, diversified mutual
funds and/or exchange‐traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize
individual stocks and bonds to meet the needs of its Clients. The Advisor does not recommend inverse or leveraged
ETFs. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
Ouellette’s investment approach is primarily long‐term focused, but the Advisor may buy, sell or re‐allocate positions
that have been held less than one year to meet the objectives of the Client or due to market conditions. Ouellette 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.
Ouellette may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Ouellette 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, which may adversely affect the portfolio. Ouellette 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.
Client’s placed in the same or similar asset allocation percentage as other Client’s may have their securities traded
simultaneously, depending on each instance, which may allow for operational efficiencies not available to Ouellette if
Client securities were traded individually. If the securities are not traded simultaneously, some accounts may be
modified before others. This may result in accounts being traded earlier inadvertently have an advantage over accounts
traded later.
Participant Account Management – As part of the Advisor’s Investment Management Services, when appropriate, the
Advisor will use a third party platform to facilitate management of held away assets such as defined contribution
plan participant accounts. The platform allows us to avoid being considered to have custody of Client funds since we
do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any
way and receive no compensation from them for using their platform. A link will be provided to the Client allowing
them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Advisor will
review the current account allocations. When deemed necessary, Advisor will rebalance the account considering client
investment goals and risk tolerance, and any change in allocations will consider current economic and market trends.
The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal
fees that harm account performance. Client account(s) will be reviewed at least annually and allocation changes will
be made as deemed necessary.
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.
At no time will Ouellette 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 their designated account[s] at the Custodian,
pursuant to the Client’s Investment Advisory Agreement, please see Item 12 – Brokerage Practices.
Cash Management Services
Ouellette offers Cash Management Services through the use of Cash and Cash Equivalents (CDs, Treasury Bills, Money
Market Mutual Funds). Typically, Ouellette will recommend a Cash Management Account for a portion of Client assets
outside of a Managed Account Program. The Advisor offers Cash Management Services through multiple online banks
utilizing MaxMyInterest (“Max”), an online banking platform. Clients participating in this service will arrange for
checks, transfers, or other sources of income to be deposited to an account held in their name at the banks utilized
through Max. Through Max, Client funds are distributed to banks on the platform with the goal of achieving higher
interest than they would otherwise obtain through traditional checking account[s].
Financial Planning and Consulting Services
Ouellette provides a variety of financial planning and consulting services to Clients, either as a component of investment
management services, or pursuant to a written financial planning and consulting agreement. Services are offered in
several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation
for Clients based on the Client’s financial 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.
The Advisor may provide guidance on any type of security, depending on the needs, goals, financial situation and
current positions held by a Client. The Advisor may also provide guidance on non‐securities investment products, as
appropriate. Financial planning and consulting recommendations poses a conflict between the interests of the Advisor
and the interests of the Client. For example, the Advisor has an incentive to recommend that to 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.
C. Client Account Management
Prior to engaging Ouellette Wealth Advisory, LLC to provide advisory services, each Client is required to enter into
one or more agreements with the Advisor that defines the terms, conditions, authority and responsibilities of the
Advisor and the Client.
• Establishing an Investment Policy Guideline – Ouellette, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Ouellette 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 – Ouellette will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Ouellette will provide investment management and
ongoing oversight of the Client’s investment portfolio.
If you request, Ouellette may recommend the services of other professionals for implementation purposes. You are
under no obligation to engage the services of any such recommended professional. You retain absolute discretion over
all such implementation decisions and are free to accept or reject any recommendation from Ouellette. If you engage
any professional recommended by Ouellette, and a dispute arises thereafter relative to such engagement, you agree to
seek recourse exclusively from and against the engaged professional.
D. Wrap Fee Programs
Ouellette does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by Ouellette.
E. Assets Under Management
As of December 31, 2022, Ouellette manages $148,741,359 in Client assets, all of which are managed on a non-
discretionary basis. Clients may request more current information at any time by contacting the Advisor.