Savvy Advisors, Inc. (“Savvy” or “the Firm”) was founded in 2022 by its parent company, Savvy Wealth, Inc.,
and Ritik Malhotra, Savvy’s Chief Executive Officer. In April 2022, the Firm completed registration with the SEC
as an investment adviser. The Firm’s principal office is in New York, NY with an additional office in Bellingham,
WA.
Separately Managed Accounts
Savvy is an adviser to separately managed accounts (the “Separately Managed Accounts”), (together, the
“Clients” or “Client Accounts”). The Firm provides customized discretionary and non- discretionary
investment and wealth management services to high net worth individuals and associated trusts, estates,
pension and profit sharing plans, and other legal entities. Savvy generally invests client discretionary assets
in domestic and international stocks, bonds, mutual funds, exchange traded funds (“ETFs”), private funds,
and real estate. The Firm works with each client to establish an appropriate investment profile outlining the
client’s objectives, risk tolerance, liquidity needs, and investment time horizon. Savvy considers the client’s
specific goals and risk tolerance and its capital markets outlook when directing assets to specific investments.
Savvy also provides investment advice to clients with held away assets such as 401ks and shares in private
companies. In providing these services, Savvy may or may not have the ability to transact in the client’s
account, depending on the platform. Provision of these services is subject to the client’s investment advisory
agreement with Savvy.
Savvy’s investment advisory services are provided pursuant to the agreed upon investment guideline terms
set forth in the investment policy statement. Clients may impose reasonable mandates, guidelines, or
restrictions relating to investments. For example, clients may impose limits on concentration, risk, exposure,
and liquidity. Savvy’s clients own the positions in their separately managed account; therefore, the Client will
typically have full, real-time transparency to all transactions and holdings in such accounts.
Savvy currently provides advice to Separately Managed Account clients, but reserves the right to provide
advice to other types of clients. The Firm does not participate in or offer wrap fee programs to Clients.
As part of our portfolio management services, we may use one or more sub-advisers to manage a portion of
your account on a discretionary basis. The sub-adviser(s) may use one or more of their model portfolios to
manage your account. We will regularly monitor the performance of your accounts managed by sub adviser(s),
and may hire and fire any sub-adviser without your prior approval. You may pay a higher advisory fee as a
result of our use of sub-advisers.
Held Away Assets
Savvy uses a third-party platform to facilitate the discretionary management of held away assets such as
defined contribution plan participant accounts, and 529 plans. 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 a Client account(s) is connected to the platform, the adviser will review the current account
allocations. When deemed necessary, the adviser 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 if not more
frequently based on client needs and market events etc. and allocation changes will be made as deemed
necessary.
ERISA Plan Services
Savvy provides advisory services to retirement plans subject to the Employee Retirement Income Security Act
of 1974, as amended (“ERISA”), including participant-directed defined contribution plans, such as 401(k) plans
(“ERISA Plan Clients”). Each ERISA Plan Client is required to enter into an investment advisory agreement with
Savvy describing the services that Savvy will perform for the ERISA plan and its participants. Savvy may provide
both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients. Services will not begin until the
applicable agreement is accepted by Savvy.
For participant-directed defined contribution plans, with respect to a plan’s investment menu, Savvy provides
non-discretionary investment advisory services under Section 3(21)(A)(ii) of ERISA and discretionary
investment management services under Section 3(21)(A)(i) of ERISA.
Non-Discretionary Recommendations: On a non-discretionary basis, the ERISA Plan Client retains and exercises
final decision-making authority and responsibility for the implementation (or rejection) of Savvy’s
recommendations or advice. Savvy Advisor’s ERISA fiduciary investment advisory services may include
assisting the ERISA Plan Client in developing an investment policy statement (IPS), assisting the ERISA Plan
client in selecting a broad range of plan investment options consistent with ERISA Section 404(c), assisting the
ERISA Plan Client in making decisions about the selection, retention, removal and/or replacement of plan
investment options, and if the ERISA Plan Client has determined that the plan should have a qualified default
investment alternative (a “QDIA”) for participants who fail to make an investment election, assisting in the
selection of the investment
that will serve as a QDIA. In addition to non-discretionary investment advisory
services, the ERISA Plan Client may receive plan program support services or plan consulting services, as
described herein.
Discretionary Investment Selection and Monitoring: With respect to discretionary investment management
services, the ERISA Plan Client does not retain or exercise final decision-making authority or responsibility for
the implementation (or rejection) of Savvy’s recommendations. Rather, when providing discretionary
investment management services, Savvy Advisor has and exercises final decision-making authority and
responsibility for the implementation of recommendations. Savvy will be a “fiduciary” and serve as
“investment manager” (as defined in Section 3(38) of ERISA) when providing discretionary investment
management services. Savvy Advisor will assist the ERISA Plan Client in the development of an IPS, which
establishes the investment policies and objectives for the Plan and sets forth the number of general
investment options and sets class categories to be offered under the Plan. When offering 3(38) discretionary
services, the Savvy Advisor retains sole discretion for the ongoing and continuous selection, monitoring, and
replacement of investment options in accordance with the designated IPS without the ERISA Plan Client’s prior
approval. Once the Plan is receiving services under the discretionary investment management services
agreement, the ERISA Plan Client can no longer make changes to the plan investment menu. In addition to
discretionary investment management services, the ERISA Plan Client may receive plan program support
services or plan consulting services, as described herein.
In addition to fiduciary services described above, ERISA Plan Clients may also select from a number of non-
fiduciary consulting services. Savvy’s non-fiduciary services to participant directed defined contribution plans
may include assisting the ERISA Plan Client in monitoring, selecting and supervising plan service vendors,
assisting in group enrollment meetings and educating plan participants about general investment principles
and the investment options available under the plan. These consulting services do not include any
individualized investment advice to ERISA Plan Clients with respect to Plan assets. Savvy Advisor does not act
as fiduciaries under ERISA in providing such consulting services.
When we provide investment advice to you regarding your 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 your interests, so we operate under a special rule that requires us to
act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations;
• Never put our financial interests ahead of yours when making recommendations;
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
•
Give you basic information about conflicts of interest.
Direct Indexing
Savvy provides discretionary investment advisory services to managed account clients based on direct
indexing models created through client input and the client’s securities holdings. Savvy constructs these
securities portfolios with the objective of tracking a particular index, within a reasonable degree of similarity,
without holding each security in the index. Benchmarks include broad market equity indexes representing
domestic and/or foreign companies. Each client’s account is customized to include the client’s existing
positions and/or to reflect specific securities or sector exclusions, which differ from account to account based
on the account size and the index against which the client’s portfolio is benchmarked. Savvy also constructs
certain portfolios that intentionally tilt towards single factor exposures or multiple factors. When providing
direct indexing services, Savvy also provides proactive tax harvesting services if agreed to by the client. In
these situations, Savvy uses quantitative tools to consider the tax benefit generated for clients as well as the
impact on the tracking error of the portfolio.
ESG (Environmental, Social, Governance)
Savvy may invest on behalf of interested clients in ESG-oriented funds and/or portfolios constructed of
individual securities. For individual securities portfolios, Savvy uses a third party portfolio and model
construction tool to create a portfolio customized to the clients’ ESG focuses. Through a questionnaire, Clients
can identify areas of ESG focus that they are interested in and can indicate desired areas of exclusion. The
platform analyzes ESG data to provide impact scoring across 45 causes that align with the United Nations
Sustainable Development Goals and excludes funds or securities that do not match the clients’ focus areas.
Savvy will review the output and invest in the funds or securities deemed appropriate for the client.
Assets Under Management
As of March 31, 2024, Savvy has approximately $401,296,753 in assets under management (“AUM”), of which
$372,157,980 is managed on a discretionary basis and $29,138,773 is managed on a non-discretionary basis.
In addition, Savvy has $18,592,170 in assets under advisement (“AUA”).