A. Firm Information
Legado Wealth Management LLC (“LWM” or the “Advisor”) is a registered investment advisor located in the
State of New York. LWM is organized as a limited liability company (“LLC”) under the laws of New York. LWM
was founded in September 2019 and is owned and operated by Managing Director and Chief Compliance
Officer, Oscar D. Flores de Valgaz. This Disclosure Brochure provides information regarding the qualifications,
business practices, and the advisory services provided by LWM.
The Advisor serves as a fiduciary to Clients, as defined under 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 our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
B. Advisory Services Offered
LWM Clients may engage Legado to manage all or a portion of their assets on a discretionary or
nondiscretionary basis or to provide investment advice on a consulting non-binding basis. Legado and
its representatives provide advice that is tailored to the individual needs of the client based on the
financial information and the investment objective(s) communicated by the client. Clients may impose
restrictions on investing in certain securities or groups of securities by notifying the firm or
representative in writing (including in the Account Application).
LWM’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, due to market conditions or other
factors.
If LWM utilizes or recommends the services of sub-advisers or money managers for account/portfolio
management services, prior to referring clients to any such entity, LWM will conduct a due diligence review of the
adviser or money manager. The review will consist of a presentation by the sub-adviser to LWM, additional
gathering of material regarding the sub-adviser or money manager, including their Form ADV, registration status
of firm, etc. Once all information has been collected, LWM will review the materials, and determine if the sub-
adviser or manager should be utilized for account management services. Records of the review
and final
decision will be maintained in LWM’s compliance files.
LWM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. LWM may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. LWM 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. LWM 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 Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
At no time will LWM accept or maintain custody of a Client’s funds or securities. All Client assets will be managed
within their designated account[s] at the Custodian, pursuant to the Client investment management agreement.
For additional information, please see item 12 – Brokerage Practices and Item 15 – Custody.
C. Client Account Management
Prior to engaging LWM to provide investment management services, each Client is required to enter into an
investment management agreement with the Advisor that defines the terms, conditions, authority and
responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Policy Statement – LWM, in connection with the Client, will develop an
investment strategy for the Client that is targeted to achieve the Client’s objectives.
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• Portfolio Construction – LWM will implement a customized strategy for the Client. Clients may
impose reasonable restrictions on their account(s), subject to the review and approval by LWM.
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• Investment Management and Supervision – LWM will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
LWM does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of December 31, 2023, LWM manages $14,739,931 in Client assets, all of which are on a discretionary
basis, $1,637,126 on a non-discretionary basis. Clients may request more current information at any time by
contacting the Advisor.