INTRODUCTION
FullCircle Wealth LLC (“FullCircle,” the “Firm,” “We,” or “Us”) is a registered investment adviser with the
US Securities and Exchange Commission. We became registered on March 22, 2013, and have been
operating as an investment adviser since then. Our registration as a Registered Investment Adviser does
not imply any level of skill or training. The oral and written communications We provide you, including this
Brochure, are information you can use to evaluate Us and other advisers, which are factors in your decision
to hire Us or to continue maintaining a relationship with Us. This Brochure provides information about our
qualifications and business practices. If you would like a free copy of our most recent brochure, please
contact us at:
FullCircle Wealth LLC
15660 North Dallas Parkway, Suite 910
Dallas, Texas 75248
972-480-6200
www.fullcircle-wealth.com
DESCRIPTION & OWNERSHIP
FullCircle was formed as a limited liability company in December 2012 and is headquartered in Dallas,
Texas. FullCircle’s two equal members and owners are Brent Sikes and Wesley Pingelton.
PORTFOLIO MANAGEMENT SERVICES
We provide financial planning, portfolio management, and pension consulting services, and We assist with
selecting other advisers. Our client base consists of individuals, high-net-worth individuals, estates,
partnerships, charitable organizations, retirement plans, and their participants.
We are a professional investment advisory firm committed to managing assets on a discretionary or non-
discretionary basis. On a discretionary basis, We design, revise, and reallocate custom portfolios for you.
Clients may impose reasonable restrictions on investing in specific securities by notifying Us in writing.
On a non-discretionary basis, We provide periodic recommendations to you, and if such recommendations
are approved, We will ensure that the authorized recommendations are carried out. Clients must approve
all securities transactions prior to implementation.
Our portfolio management program is designed to provide the appropriate asset allocation, diversification,
and risk characteristics consistent with prudent portfolio management. We manage equity, fixed income,
and balanced portfolios using clearly defined investment objectives and guidelines established in private
consultation with each Client. We construct, manage, execute, and monitor portfolios that meet each
Client's unique set of needs. The investments are determined based on your investment objectives, risk
tolerance, net worth, income, age, investment time horizon, tax situation, and other relevant factors.
We primarily allocate client assets among cash and cash equivalents, individual stocks, bonds, mutual
funds, exchange-traded funds (“ETFs”), municipal bonds, corporate bonds, futures and options, alternative
investments, and limited partnerships, all of which are considered asset allocation categories for the
client’s investment strategy. Clients may impose reasonable restrictions on investing in certain securities
by notifying Us through written notification.
Our Firm may recommend that certain clients utilize margin in the client’s investment portfolio or other
borrowing. We only recommend such borrowing for non-investment needs, such as bridge loans and other
financing. The Firm’s fees are determined based on the value of the assets being managed gross of any
margin or borrowing.
ADMINISTRATIVE SERVICES PROVIDED BY ORION ADVISOR SERVICES, LLC
Our Firm has contracted with Orion Advisor Services, LLC (referred to as “Orion”) to utilize its
technology platforms to support data reconciliation, performance reporting, fee calculation and
billing, research, client database maintenance, quarterly performance evaluations, payable reports,
web site administration, models, trading platforms, and other functions related to the administrative
tasks of managing client accounts. Due to this arrangement, Orion will have access to client
accounts, but Orion will not serve as an investment advisor to our clients. Modern Wealth
Management and Orion are non-affiliated companies. Orion charges our Firm an annual fee for
each account administered by Orion. Please note that the advisory fee charged to the client will
not increase due to the annual fee our Firm pays to Orion. The annual fee is paid from the portion
of the management fee retained by our Firm.
NITROGEN (FORMERLY RISKALYZE)
To further fine-tune our understanding of a client’s risk tolerance, We utilize Nitrogen, a third-party vendor
tool, to assist in identifying the client’s risk tolerance.
Nitrogen technology assists financial planners in two critical tasks: (1) measuring the risk preferences of
investors and (2) applying these preference measurements to portfolio selection. Nitrogen summarizes
an investor’s mean-variance risk aversion on a 99-point scale. In connection with this output, the Nitrogen
tool “quantifies” the client’s indicated investment risk tolerance through the illustration of expected return
(plus/minus) and investment volatility (investment variance), which uses past data to calculate expected
variance.
FINANCIAL INSTITUTION INVESTMENT SERVICES – MUTUAL SECURITES, INC.
Our Firm has an agreement(s) with brokers/dealers to provide investment advisory services to Annuity
Brokerage Customers. This advisory arrangement does not include assuming discretionary authority over
Brokerage Customers’ brokerage accounts or monitoring securities. These advisory services are offered
to Brokerage Customers and include a general review of investment holdings, which may or may not result
in our investment adviser representatives making specific sub-account recommendations or offering
general investment advice. Brokerage Customers will execute a written non-discretionary investment
services agreement directly with FullCircle. This relationship presents conflicts of interest. Potential
conflicts are mitigated by Brokerage Customers consenting to receive investment services from FullCircle;
by FullCircle not accepting or billing for additional compensation on broker dealer assets outside of our
non-discretionary services we provide Mutual Securities, Inc. clients; and by FullCircle not engaging as,
or holding itself out to the public as, a securities broker/dealer. Our firm is not affiliated, nor are our advisors
registered, with any broker/dealer.
ERISA ACCOUNTS, PROFIT SHARING 401(K), SEP’S & DISCLOSURE
We may also have other retirement accounts subject to ERISA rules and regulations. In all cases, an
“eligible investment advice arrangement” or advisory agreement will be executed with the Client.
When We provide investment advice to clients regarding their retirement plan account or individual
retirement account, We are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way We make money creates some conflicts with our Client’s interests, so We operate
under a special rule that requires us to act in our Client’s best interest and not put our interests ahead of
our Clients.
FullCircle may recommend that a Client roll over their retirement plan assets into an account to be
managed by FullCircle. A Client or prospective client leaving an employer typically has four options
regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the
money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if
one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or
(iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax
consequences). If A client or potential client asks us to make a recommendation from among these
choices, We have a conflict of interest in that We have an incentive to recommend that a Client roll over
their retirement plan assets into an account to be managed by FullCircle, such a recommendation creates
a conflict of interest as We will earn a new (or increase our current) Advisory Fee as a result of the rollover.
We address this conflict of interest by reviewing any such recommendation
to ensure it is in the best
interest of the Client. No Client is under any obligation to roll over retirement plan assets to an account
We manage.
FINANCIAL PLANNING AND CONSULTING SERVICES
We also offer financial planning analysis, consulting, and comprehensive written financial plans. Our
financial planning analysis services may include an analysis of only isolated area(s) of your financial
affairs, such as estate planning, retirement planning, any other specific topic, or any other investment and
financial concerns you may have.
We also offer comprehensive Financial Planning services. If you purchase this service, you will receive a
written report with a detailed financial plan designed to achieve your stated goals and objectives. The
financial plan, as directed by you, may include asset protection, tax planning, business succession,
strategies for exercising stock options, cash flows, education planning, estate planning and wealth transfer,
charitable gifting, long-term care and disability planning, retirement planning, insurance planning, asset
allocation comparisons, and risk management.
We gather the required information through in-depth personal interviews. Information gathered includes a
Client’s current financial status, future goals, and attitudes towards risk. Related documents supplied by
you and a completed Client questionnaire are carefully reviewed, and a written report is prepared.
Implementation of the prepared plan or recommendations is solely at your discretion, and you will also
determine how you want to implement the plan or recommendations. For plans requiring tax or legal
expertise, We encourage you to utilize any desired tax or legal professional or group of professionals to
assist in the implementation.
EMONEY ADVISOR PLATFORM
We make available to our Clients the “eMoney Advisor” platforms to provide periodic
comprehensive reporting services that can incorporate all the Client’s investment assets, including
those investment assets that are not part of the assets managed by the Firm (“Excluded Assets”).
The Client and their other advisors who maintain trading authority, not the Firm, shall be exclusively
responsible for the investment performance of the excluded assets.
Unless otherwise expressly agreed to in writing, the Firm’s service relative to the excluded assets
is limited to reporting only. Therefore, We shall not be responsible for the investment performance
of the excluded assets. Instead, the Client and the Client’s designated outside investment
professional(s) maintain supervision, monitoring, and trading authority for the excluded assets. If
our Client prefers, the Firm will provide recommendations on any excluded assets. The Client has
no obligation to accept the recommendation, and We shall not be responsible for any
implementation error (timing, trading, etc.) relative to the excluded assets. The Client may engage
us under the terms and conditions of a Consulting or Investment Advisory Agreement between the
Firm and the Client.
eMoney Advisor Platform may also provide access to other types of information, including financial
planning concepts, which should not be construed as the Firm’s personalized investment advice or
recommendations. We shall not be held responsible for any adverse results a Client may
experience if the Client engages in financial planning or other functions available on the eMoney
Advisor Platform without our assistance or oversight.
FINANCIAL PLANNING REVIEWS/MAINTENANCE AND SPECIALIZED ANALYSIS SERVICES
Over time, as the economic climate and personal circumstances change, you may wish to adjust your
goals, resulting in a change in planning strategy. You can engage Us to prepare a review or update of
your plan. This reappraisal can include updates and projections regarding cash flow, net worth,
tax liabilities and retirement projections, etc.
We provide special services, including participation in the analysis, development, and implementation of
budgeting and cash flow management, coordination and oversight of banking and investment advisory
relationships, negotiations of certain real or personal property purchases, and other requested projects or
services.
THIRD-PARTY INVESTMENT MANAGER SELECTION SERVICES
FullCircle recommends the services of third-party managers.
ENVESTNET ASSET MANAGEMENT
Generally, FullCircle will use third-party managers through the Unified Managed Accounts
Exchange platform (“UMAX”). We may recommend that you utilize the services of Envestnet Asset
Management (“Envestnet” or “Overlay Manager”), an investment advisor registered with the SEC.
Envestnet is a subadvisor offering Unified Managed Account (“UMA”) programs and services.
UMAs are fee-based investment solutions that allow advisers to combine multiple professionally
managed investment products into a single account with automated services such as rebalancing,
performance reporting, billing, and advanced functionality such as managing securities restrictions.
The third-party-managed investment products are managed by advisors to model portfolios (“Model
Portfolio Advisors”) selected for the Client by FullCircle. Envestnet also acts as an Overlay Manager
for your portfolio under this program. Under this program, We recommend one or more unaffiliated,
third-party investment managers whose investment style is believed to be consistent with your
financial needs, investment goals, tolerance for risk, and stated investment objectives. Upon
selection and after the initial allocation of your portfolio, We will monitor the performance of the
models to ensure their performance and investment style remain aligned with the investment goals
and objectives. You grant the Overlay Manager discretionary authority to manage and invest your
assets. We retain the ultimate discretionary authority to terminate the Overlay Manager relationship
and will do so if it is in the best interest of the Client.
By signing the Unified Managed Account Exchange Application and Agreement (“UMA
Agreement”), the Client appoints Envestnet to provide overlay management services to FullCircle
Clients. Envestnet is responsible for ongoing management and supervision of accounts;
implementation and coordination of model portfolios and related recommendations received from
Model Portfolio Advisors; periodic rebalancing of accounts; cash management; loss harvesting for
taxable accounts (but without tax management); initial investment of accounts and tradition of
legacy assets; incorporating Client-requested restrictions for specific securities and social and
industry categories; and providing tax overlay management on accounts for which the Advisor has
selected tax management on behalf of Clients. The Overlay Manager will have authority and
discretion to select brokers and dealers to execute portfolio transactions initiated by the Overlay
Manager and to select the markets in which the transactions will be executed.
Clients offered Envestnet will receive all required disclosure documents, including the Firm’s ADV
Part 2A and Privacy Policy. Envestnet may impose a minimum dollar amount of initial Client assets
for the investment advisory services as disclosed in the management agreement. These minimums
may be waived at their discretion.
ASSETMARK INC.
From time to time, FullCircle will enter into agreements with individuals and organizations where
FullCircle refers clients to third-party managers, such as AssetMark, Inc. All such agreements will
be in writing. If a client is introduced to a third-party manager by FullCircle, FullCircle may receive
promoter fee(s) in accordance with the requirements of state and/or federal securities law, as
applicable. The specific terms of each agreement may differ but will be delivered to each referred
client. Any such fee shall be paid solely from the third-party manager’s management fees and shall
not result in any additional charge to the client. For more information, please see Item 14 – Client
Referrals and Other Compensation.
WRAP FEE PROGRAMS
We do not manage, sponsor, or participate in wrap fee programs.
ASSETS UNDER MANAGEMENT
We currently have $310,551,631 in discretionary assets under management as of December 31, 2023.