About Our Firm
Genesis Private Wealth, LLC, doing business as The Lewis Financial Group (“LFG”) is a registered
investment adviser that provides investment management and financial advisory services to
individual and institutional investors to help them achieve their financial needs and goals. LFG has
been a registered investment adviser since 2021 and is owned by Andrew Lewis.
Our firm takes pride in providing personalized service to our clients and acknowledges that it is held
to a fiduciary standard of care.
Types of Advisory Services We Offer
LFG offers a variety of advisory services to individuals, high net worth individuals, foundations,
businesses, and corporations. These services include:
Investment and wealth management
Selection of Independent Managers
Financial planning and consulting
We work with our clients to determine their investment objectives and risk profile and develop a
customized investment plan based on their individual needs and goals. LFG will utilize the financial
information provided by the client to analyze and develop strategies and solutions to assist the client
in meeting their financial goals.
Prior to LFG rendering any of the foregoing services, clients are required to enter into one or more
written advisory agreements with LFG setting forth the relevant terms and conditions of the
advisory relationship.
Investment and Wealth Management Services
LFG manages our clients’ portfolios on a discretionary and non-discretionary basis. Our investment
and wealth management services are tailored to the needs of our clients and are based on a
comprehensive understanding of each client’s current situation, past experiences, and future goals.
With this acquired knowledge we create, analyze, strategize, and implement goal-oriented
investment solutions. These solutions become our clients’ investment policy. This policy and our
matched strategies are designed to be risk appropriate, cost effective and tax efficient.
Our wealth management services generally include a broad range of comprehensive financial
planning and/or consulting services, as well as discretionary and non-discretionary management of
investment portfolios.
Client assets are primarily allocated among individual equity and debt securities, mutual funds,
exchange-traded funds ("ETFs") and unit investment trusts (“UITs”) in accordance with the client's
stated investment objective and risk/volatility parameters. We may also recommend clients allocate
a certain portion of their assets to independent investment managers ("Independent Managers") or
alternative investments. Where appropriate, LFG may also provide advice about many types of
legacy positions or other investments held in client portfolios. Clients may also engage LFG to
manage and/or advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts and assets held in employer
sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
Our firm has entered into a service agreement with a third party service provider to provide asset
management services for accounts held away from our primary custodial affiliations. Through this,
we are able to create a portfolio consisting of the securities and/or investment opportunities
available depending on the type of held away account being managed by our firm. LFG is limited
by the universe of investments offered by the custodian(s) for these held-away accounts. The
independent 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, Adviser will review the current account allocations. We
seek to align the client’s held-away account(s) with their overall investment time horizon, risk
tolerance, and investment goals. When deemed necessary, LFG will rebalance the account
considering client’s investment profile, as well as changes in economic and market trends.
LFG consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their
portfolios. You should promptly notify us if there are changes in your financial situation or if you
wish to place any limitations on the management of your account. You may impose reasonable
restrictions or mandates on the management of your account if LFG determines, in our sole
discretion, the conditions will not materially impact the performance of a management strategy or
prove overly burdensome to the firm's management efforts.
To the extent a client’s assets are managed by an Independent Manager or are invested in a
particular fund, those managers and funds will have their own investment practices. Those
investment practices are described in each manager’s Form ADV or fund’s prospectus, or in its
offering or other disclosure documents. In addition, selected money managers or funds typically
have discretion to determine the type, and amount, of securities to be purchased or sold for the
portion of the assets managed by the money manager or fund.
Selection of Independent Managers
LFG selects, as appropriate, certain Independent Managers to actively manage all or a portion of its
clients' assets. Pursuant to the terms of the investment advisory agreement, LFG shall have the
discretion to appoint and terminate these third-party advisers. The specific terms and conditions
under which a client engages certain Independent Managers is set forth in a separate written
agreement with the designated Independent Manager. Certain Independent Managers require a
separate investment advisory agreement with the Independent Manager, while others do not.
Disclosure of the use of an Independent Manager and their additional fees will be provided to
clients. Independent Managers utilized by LFG include sub-advisors, Unified Managed Account
(UMA) platforms, and third-party advisors. In addition to this brochure, clients will also receive the
written disclosure documents of the respective Independent Managers engaged to manage their
assets.
LFG evaluates a variety of information about Independent Managers, which includes the
Independent Managers' public disclosure documents, materials supplied by the Independent
Managers themselves and other third-party analyses it believes are reputable. To the extent possible,
LFG seeks to assess the Independent Managers' investment strategies, past performance, and risk
results in relation to its clients' individual portfolio allocations and risk exposure. LFG also takes
into consideration each Independent Manager's management style, returns, reputation, financial
strength, reporting, pricing, and research capabilities, among other factors.
LFG currently partners with Adhesion to offer unified managed account and separately managed
account programs available through Adhesion Wealth Advisor Solutions (“Adhesion”). When
utilizing the Adhesion platform, investment strategy recommendations will be provided by the
Independent Manager(s) and communicated to Adhesion as the overlay manager of UMA platform.
Taking into consideration such things as tax-loss harvesting, avoiding high-penalty trades due to
wash-sales and other trading considerations, Adhesion will then provide trading instructions to
TradePMR for execution.
LFG also utilizes unified managed account managers, separate account managers and a mutual fund
advisory program available through Wells Fargo Advisors. When utilizing Wells Fargo Advisors as
the Independent Manager, or managers available through a program offered by Wells Fargo
Advisors, investment management services are
provided through the Personalized Unified Managed
Account Program, Private Advisor Network Program (a separately managed account program) or
FundSource® Program (a mutual fund advisory program). The Wells Fargo Advisors programs
require clients to sign an investment advisory agreement for access to their programs in addition to
our investment management agreement.
Use of Independent Managers can be a conflict of interest due to the division of advisory services
between two investment advisers. LFG views the use of Independent Managers as a significant benefit
to clients. Clients receive the benefit of the additional investment strategy, along with the continued
holistic overview of the portfolio(s) and additional planning services provided by LFG. As part of its
fiduciary duty to the client, LFG performs due diligence on Independent Managers and evaluates a
variety of information which may include the Independent Managers' public disclosure documents,
materials supplied by the Independent Managers themselves and other third-party analyses it believes
are reputable. To the extent possible, LFG seeks to assess the Independent Managers' investment
strategies, past performance and risk results in relation to its clients' individual portfolio allocations
and risk exposure. LFG also takes into consideration each Independent Manager's management style,
investment returns, reputation, financial strength, reporting, pricing, and research capabilities, among
other factors.
LFG continues to provide services relative to the discretionary or non-discretionary selection of the
Independent Managers. On an ongoing basis, LFG monitors the performance of those accounts
being managed by Independent Managers. LFG seeks to ensure the Independent Managers'
strategies and target allocations remain aligned with clients' investment objectives and overall best
interests.
Program Offered Through Adhesion
When utilizing third-party investment strategists available through Adhesion, LFG utilizes
separately managed account managers, model providers, mutual funds/ETF strategies and/or
individual equity and fixed income securities to construct a portfolio tailored to your needs. Through
the Adhesion program, Adhesion acts a sub-adviser to our firm and does not require clients sign a
separate investment advisory agreement for access to their program.
Programs Offered Through Wells Fargo Advisors
When utilizing Wells Fargo Advisors as the Independent Manager, or managers available through a
program offered by Wells Fargo Advisors, investment management services are provided through
the Personalized Unified Managed Account Program, Private Advisor Network Program (a
separately managed account program) or FundSource® Program (a mutual fund advisory program).
The Wells Fargo Advisors programs require clients to sign an investment advisory agreement for
access to their programs in addition to our investment management agreement.
Financial Planning and Consulting Services
LFG offers different levels of financial planning and consulting services to help our clients identify,
prioritize and work towards their goals and objectives. Our consulting services give our clients the
ability to receive a broad range of financial advice and services, including specific security
recommendations, for the duration of the advisory agreement.
Our process starts with an extensive review of a client's family situation, which includes assets and
liabilities as well as estate, tax, and insurance needs. We then employ a risk tolerance and risk
capacity-focused simulation to get a detailed cash flow analysis and proposed asset allocation.
Together, this information is analyzed to develop a proposed financial plan, which is designed to be
dynamic in nature, ever-evolving due to life changes, along with changes in cash flow needs, risk
tolerance, time horizon, or investment objectives.
LFG’s financial planning and consulting services include any of the following topics as contracted:
Cash Flow Analysis
Risk Management
Trust & Estate Planning
Charitable Giving
Education Planning
Business Planning
Retirement Planning
Cash Flow Forecasting
Death & Disability
Divorce Planning
Liability Management
Investment Consulting
Distribution Planning
Tax Planning
Insurance Review
Next Generation Family
Retirement Plan Consulting and
Employee Benefits Analysis
While each of these services is available on a stand-alone basis, certain services are also rendered in
conjunction with investment portfolio management services as part of a comprehensive wealth
management engagement. In performing these services, LFG is not required to verify any
information received from the client or from the client's other professionals (e.g., attorneys,
accountants, etc.), and is expressly authorized to rely on such information. LFG may recommend
clients engage the firm for additional related services, or we may recommend other professionals to
implement our recommendations. These additional services by LFG or another professional are
provided at an additional cost to you, which is based on the nature, extent, complexity, and other
characteristics of the services. This creates a conflict of interest because we will have an incentive to
recommend additional services based on the compensation to be received, rather than solely based
on your needs, and in some cases, based on the prospect of cross-referrals of advisory clients from
the other professional or his or her firm.
Implementation of financial planning recommendations is entirely at your discretion. You have
complete freedom in selecting a financial adviser to assist you with implementing the
recommendations made in your financial plan and are under no obligation to act on the advice of
LFG. Financial planning recommendations are of a generic nature and are not limited to any
specific product or service offered by a broker dealer or insurance company. Should you choose to
implement the recommendations contained in the plan, LFG suggests you work closely with your
attorney, accountant and/or insurance agent.
LFG will act solely in our capacity as a registered investment adviser and does not provide any legal,
accounting or tax advice. You should seek the counsel of a qualified accountant and/or attorney
when necessary. As part of our advisory services and as needed we assist clients with tax loss
harvesting, and will work with the client’s tax specialist to answer any questions related to the
client’s portfolio. Any incidental tax discussions on topics, such as required minimum distributions,
retirement plan contributions, etc. should be verified with your tax advisor.
Portfolio Management Services for Wrap Fee Program
LFG offers portfolio management services through a wrap fee program. A bundled or “wrap fee”
program is an advisory fee program under which you pay one bundled fee to compensate LFG for
portfolio management and trade execution. A wrap fee program may not be the lowest cost option if
you would like to restrict your investments to open-end mutual funds or other long-term investment
products.
Amount of Assets We Manage
As of December 31, 2023, LFG manages approximately $266,491,944 of assets on a discretionary
basis and $0 of assets on a non-discretionary basis. Discretionary assets under management are those
for which we have an ongoing responsibility to select and make securities recommendations that are
in line with your financial needs and objectives and then effect those securities transactions without
first consulting you. Non-discretionary assets under management are those for which we have an
ongoing responsibility to select and make securities recommendations that are in line with your
financial needs and objectives and then effect those securities transactions only after consulting with
you to inform you of the transaction(s) and obtaining your approval to move forward.