This Disclosure document is being offered to you by Global Wealth Strategies &
Associates, LLC (“GWS&A” or “Firm”) about the investment advisory services we provide.
It discloses information about the services that we provide and the way those services are
made available to you, the client.
Global Wealth Strategies & Associates, LLC was registered as an Investment Advisor with
the SEC in November 2021. The owners of GWS&A are as follows: Way Holdings, LLC
(Adam Way), Clark Avenue Holdings, LLC (Eric M. Jacobs), Sara M. Erpestad FPQP, and
Bradley R. Scoular, AIF, CLU®, CLTC. Adam Way, AEP®, AIF®, CFP®, ChFC®, CLTC, CLU®, is
the Chief Compliance Officer of the Firm.
We are committed to helping clients build, manage, and preserve their wealth. Our Firm
provides services that help clients to achieve their stated financial goals. We will offer
initial complimentary meetings upon our discretion; however, investment advisory
services are initiated only after you and GWS&A execute an Investment Management
Agreement.
INVESTMENT MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary basis. For discretionary accounts, once
we have determined a profile and investment plan with a client, we will execute the day-
to-day transactions without seeking prior client consent but within the expected
investment guidelines. Account supervision is guided by the client’s written profile and
investment plan. We will accept accounts with certain trading restrictions if
circumstances warrant. We primarily allocate client assets among various equities,
Exchange Traded Funds (“ETFs”), no-load or load-waived mutual funds and cash in
accordance with their stated investment objectives. All of which are considered asset
allocation categories for the client’s investment strategy.
During personal discussions with clients, we determine the client’s objectives, time
horizons, risk tolerance, and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. Based on client needs,
we develop a client’s personal profile and investment plan. We then create and manage
the client’s investments based on that policy and plan. It is the client’s obligation to notify
us immediately if circumstances have changed with respect to their goals. Once we have
determined the types of investments to be included in a client’s portfolio and have
allocated the assets, we provide ongoing investment review and management services.
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With our discretionary relationship, we will make changes to the portfolio, as we deem
appropriate, to meet client financial objectives. We trade these portfolios based on the
combination of our market views and client objectives, using our investment process. We
tailor our advisory services to meet the needs of our clients and seek to ensure that your
portfolio is managed in a manner consistent with those needs and objectives. Clients have
the ability to leave standing instructions with us to refrain from investing in particular
industries or invest in limited amounts of securities.
Clients may engage us to advise on certain investment products that are not maintained
at our Firm’s recommended custodian, and assets held in employer sponsored retirement
plans. Where appropriate, we provide advice about any type of held away account that is
part of a client portfolio.
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that adversely affect
an account’s performance. This could result in capital losses in your account.
FINANCIAL PLANNING
Through the financial planning process, our team strives to engage our clients in
conversations around the family’s goals, objectives, priorities, vision, and legacy – both
for the near term as well as for future generations. With the unique goals and
circumstances of each family in mind, our team will offer financial planning ideas and
strategies to address the client’s holistic financial picture, including estate, income tax,
charitable, cash flow, wealth transfer, and family legacy objectives. Our team partners
with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance
Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s stated goals.
Such services include various reports on specific goals and objectives or general
investment and/or planning recommendations, guidance to outside assets, and periodic
updates.
Our specific services in preparing your plan may include:
● Review and clarification of your financial goals.
● Assessment of your overall financial position including cash flow, balance sheet,
investment strategy, risk management, and estate planning.
● Creation of a unique plan for each goal you have, including personal and business
real estate, education, retirement or financial independence, charitable giving,
estate planning, business succession, and other personal goals.
● Development of a goal-oriented investment plan, with input from various advisors
to our clients around tax suggestions, asset allocation, expenses, risk, and liquidity
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factors for each goal. This includes IRA and qualified plans, taxable, and trust
accounts that require special attention.
● Design of a risk management plan including risk tolerance, risk avoidance,
mitigation, and transfer, including liquidity as well as various insurance and
possible company benefits; and
● Crafting and implementation of, in conjunction with your estate and/or corporate
attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the
event of an incapacity or death.
A written evaluation of each client's initial situation or Financial Plan is provided to the
client.
CONSULTING SERVICES
We also provide clients investment advice on a more-limited basis on one or more
isolated areas of concern such as estate planning, real estate, retirement planning, or any
other specific topic. Additionally, we provide advice on non-securities matters about the
rendering of estate planning, insurance, real estate, and/or annuity advice or any other
business advisory / consulting services for equity or debt investments in privately held
businesses. In these cases, clients will be required to select their own investment
managers, custodian, and/or insurance companies for the implementation of consulting
recommendations. If client needs include brokerage and/or other financial services, we
will recommend the use of one of several investment managers, brokers, banks,
custodians, insurance companies, or other financial professionals ("Firms"). Consulting
clients must independently evaluate these Firms before opening an account or
transacting business and have the right to effect business through any firm they choose.
Clients have the right to choose whether or not to follow the consulting advice provided.
TRUSTEE ADMINISTRATIVE SERVICES
GWS&A and/or the Firm’s IARs occasionally act as trustee upon request by a client. If
agreed to, GWS&A will be named as either a Financial Director, Estate Plan
Distribution Trustee or Successor Trustee. Although every case is unique and different,
there are commonly the following main responsibilities when providing these services:
1. General administration of insurance policies:
Duties include but are not
limited to coordinating the payment on insurance policies, monitoring for
any lapses or issues, assistance with paperwork associated with establishing
the policy, annual in-force illustrations
2. Annual ongoing ILIT administration
3. Annual notification(s) of Crummy letters
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4. Assist with selection of 3rd Party CPA firm and coordination in completing
ILIT tax returns
5. Assist with the Distribution(s) of life insurance proceeds
6. Oversea Estate plan distribution(s) and payments under HEMS
These services are offered under separate engagement and Clients will need to enter into
separate agreements for these services. It should be noted GWS&A does not take on
physical custody of any assets. Due to the Firm’s indirect access and oversight of client
insurance accounts held with our affiliated insurance entity, Global Wealth Strategies
Insurance, LLC, the Firm does comply with the surprise annual audit to be conducted by
an independent CPA firm which is registered with and subject to regular inspection by the
Public Company Accounting Oversight Board (PCAOB). The Firm has complied with the
Custody Rule requirements concerning such surprise audits and will continue to do so in
the future.
RETIREMENT PLAN ADVISORY SERVICES
Retirement Plan Advisory Services consists of helping employer plan sponsors to
establish, monitor and review their company's retirement plan. As the needs of the plan
sponsor dictate, areas of advising could include investment selection and monitoring, plan
structure, and participant education.
Pursuant to Section 402(c)(3) of ERISA, the client may appoint us as the Plan’s “investment
manager” with respect to the Plan’s portfolio of investment options. We acknowledge
that we are registered as an investment adviser under the SEC. Our firm acts as a
“fiduciary” within the meaning of Section 3(21) of ERISA with respect to the Plan. We
offer advisory services to employer sponsored retirement plans such as 401(k), 457,
403(b), and ROBS Plans (Rollovers as Business Start-Ups). On the plan level, we manage
the investment line-up making changes as necessary as well as providing risk-based
investment models for the participants. On the individual participant level, we manage
risk-based models using the current investment lineup based on risk tolerance of the
individual investor. For employer-sponsored retirement plans with participant-directed
investments, our firm provides its advisory services as an investment advisor as defined
under Section 3(21) of the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”).
When serving as an ERISA 3(21) investment adviser, the Plan Sponsor and our Firm share
fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for
the investments and may accept or reject the recommendations in accordance with the
terms of a separate ERISA 3(21) Plan Sponsor Investment Management Agreement
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between our Firm and the Plan Sponsor. Under the 3(21) agreement, our Firm can
provide the following services to the Plan Sponsor:
● Review or Development of an Investment Policy Statement
● Perform Due Diligence on Money Managers
● Provide Initial Investment and Management Selection ‐ Our Firm typically
uses mutual funds/managed accounts/collective trusts/cash equivalents to
structure portfolios designed to meet client objectives and risk profiles.
● Provide ongoing Performance Evaluation and Monitoring of Money
Managers
● Make Investment Recommendations when necessary
● Retirement Plan Services Analysis ‐ Our Firm will conduct an analysis of a
client’s retirement plan to evaluate the services currently provided to the
client by third parties. The areas of analysis may include asset management
services, record keeping, administration, customer service, participant
education, etc. These services may also include a cost/benefit analysis,
recommendation of alternative vendors, facilitation of the RFP process for
solicitation of a new vendor, and/or assistance in fee negotiations with
proposed vendors.
● Provide Employee Education Services ‐ Our Firm will provide enrollment and
educational services the content of the program will be generic in nature.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect 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) rollover 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). Our Firm may recommend an
investor roll over plan assets to an IRA for which our Firm provides investment advisory
services. As a result, our Firm and its representatives may earn an asset-based fee. In
contrast, a recommendation that a client or prospective client leave their plan assets with
their previous employer or roll over the assets to a plan sponsored by a new employer
will generally result in no compensation to our Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
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IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of our Firm, (iv) protection of assets from creditors and legal judgments, (v)
required minimum distributions and age considerations, and (vi) employer stock tax
consequences, if any. All rollover recommendations are also reviewed by our Firm’s Chief
Compliance Officer in a best effort to determine that the recommendation to a client was
reasonable or that the client has determined to make the rollover after being provided
ample information about their options. No client is under any obligation to roll over plan
assets to an IRA advised by our Firm or to engage our Firm to monitor and/or advise on
the account while maintained with the client's employer. Our Firm’s Chief Compliance
Officer remains available to address any questions that a client or prospective client has
regarding this disclosure.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also 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. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
WRAP FEE PROGRAM
We do not offer a Wrap Fee Program.
ASSETS
As of December 31, 2022, our Firm manages $207,926,584 under total regulatory assets
under management. All assets are under our discretionary management.