This Disclosure document is being offered to you by Transce3nd LLC (“TE3” 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.
Transce3nd LLC (TE3” or the “Firm”) is a registered investment advisor. The Firm markets their advisory
services under the name e3 Wealth. TE3 was founded in November 2021 and became a registered
investment adviser in the State of Texas in May 2022. The Principal Owner of TE3 is Joseph Allen
Quartucci. The Chief Compliance Officer of TE3 is Bruce Wheadon.
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
TE3 execute an Investment Management Agreement.
INVESTMENT MANAGEMENT AND SUPERVISION SERVICES
We offer discretionary and non-discretionary investment management and investment supervisory
services for a fee based on a percentage of your assets under management. The discretionary
investment management services include investment analysis, allocation of investments, and ongoing
monitoring of client portfolios.
We determine your portfolio composition based on your needs, your portfolio restrictions, if any, your
financial goals and your risk tolerances. We will work with you to obtain necessary information
regarding your financial condition, investment objectives, liquidity requirements, risk tolerance, time
horizons, and any restrictions on investing. This information enables us to determine the portfolio best
suited for your investment objective and needs. We primarily allocate client assets among individual
stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds, cash and other public and
private securities or investments. All of which are considered asset allocation categories for the
client’s investment strategy.
We will rebalance the portfolio, as we deem appropriate, to meet your financial objectives. For
discretionary accounts, we will trade these portfolios and rebalance them on a discretionary basis
based on our market views and on your investment objectives, using our investment philosophy and
process as outlined in Item 8 in this Brochure. We tailor our advisory services to meet the needs of our
clients and seek to ensure that client portfolios are managed in a manner consistent with those
financial needs and investment objectives.
We do have limited authority to direct the Custodian to deduct our investment advisory fees from your
accounts, but only with the appropriate authorization by you of our Discretionary Investment
Management Agreement and the Custodian paperwork.
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 may adversely affect an account’s performance.
This could result in capital losses in your account.
There may be times a non-discretionary account relationship exists with our firm. In these
circumstances, the client may call in to facilitate a trade on their account. Our Advisors will assist in
facilitating the transaction on behalf of the client but we do not have continuous or supervisory
oversight on such accounts and do not bill advisory fees for such relationships. Under a non-
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discretionary relationship, the custodian may charge additional fees such as transaction costs,
custodial fees, redemption fees, retirement plan and administrative fees or commissions.
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.
In performing our services, we shall not be required to verify any information received from you or
from other professionals. We may recommend and/or engage the services of other professionals for
implementation purposes. You are under no obligation to engage the services of any such
recommended professional.
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 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 may be provided to the client.
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USE OF THIRD-PARTY MONEY MANAGERS
We provide investment advice, recommendations and utilize the investment strategies of Outside
Investment Managers (“Managers”) through a tri-party relationship. Selected Managers are evaluated
by us for use in a client’s account. Managers selected by us may offer multiple strategies. Our Firm will
monitor Managers to ensure that it adheres to the philosophy and investment style for which it was
selected and to ensure that its performance, portfolio strategies, and management remain aligned with
the client’s overall investment goals and objectives. Our ongoing review includes, but is not limited to,
assessment of the Manager’s disclosure brochure, performance information, materials, personnel
turnover, and regulatory events. Factors we will consider in recommending a particular Manager
include, but are not limited to, the client’s stated investment objectives, management style,
independence, stature of the custodian utilized by the Manager, performance, philosophy, financial
strength, continuation of management, client service, reporting, commitment to a particular
investment mandate, fees, trading efficiency, and research.
When the use of a Manager is recommended in a client portfolio, the account will be traded by outside
the Manager (externally traded). All research, investment selections and portfolio decisions are the
responsibility of the Manager, not by our Firm. Performance reporting may be provided by the
Manager. Our Firm will maintain discretion over the client account to move within strategies offered
by the Manager.
The client will enter into a tri-party agreement with the Manager and our Firm. All third-party Managers
to whom we will refer or engage for clients will be licensed as registered investment advisors by their
resident state and any applicable jurisdictions or registered investment advisors with the U.S. Securities
and Exchange Commission (“SEC”).
Our Firm receives no additional benefits from the Manager related to this arrangement outside of the
advisory fee billed by our Firm. Our Firm, in conjunction with the Manager, will continue to provide
advisory services to the Client for the ongoing monitoring, review, and reporting of the overall account
performance and maintain the appropriate strategy for the client portfolio in line with their risk profile.
Third-party managed programs generally have account minimum requirements that will vary from
investment advisor to investment advisor. A complete description of the Manager’s services, fee
schedules and account minimums will be disclosed in the Manager’s Form ADV or similar Disclosure
Brochure which will be provided to clients at the time an agreement for services is executed and
account is established.
USE OF MODEL MANAGERS AND PLATFORM PROVIDER
The determination to use a particular model or models is based on each client’s individual investment
goals, objectives and mandates. The Firm has entered into an agreement with AE Wealth Management,
LLC (“AEWM”), an SEC registered investment advisor, to provide asset management services that
include:
• model money managers
• portfolio managers
• strategists.
As part of the AEWM program, Clients provide the Firm and AEWM discretion to select third party,
non-affiliated investment managers (“Model Managers”) to design and manage model portfolios.
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Our Firm has access to AEWM’s reporting systems, client relationship management systems and
workflow systems to assist clients to establish an advisory account. Due to this arrangement, AEWM
will have access to client information, but AEWM will not serve as an investment advisor to the Firm’s
Clients. Our Firm and AEWM are non-affiliated companies. AEWM charges the Firm an annual fee for
each account administered by AEWM. The annual fee is paid from the portion of the management fee
retained by us. Clients receive continuous investment advice based on investment objective, risk
profile and time-horizon. While investment strategies and recommendations are tailored to the
individual needs of each client, they consist of an asset allocation consistent as outlined in Item 8 of
this Brochure.
We will not enter an investment advisor relationship with a prospective client whose investment
objectives are considered incompatible with the Firm’s investment philosophy or strategies or where
the prospective client seeks to impose unduly restrictive investment guidelines. However, Clients have
the ability to impose reasonable restrictions on the management of their accounts, including the ability
to instruct the Firm not to purchase certain securities.
We do have limited authority to direct the Custodian to deduct the Firm’s investment advisory fees
from accounts, but only with the appropriate written authorization from clients.
Clients may engage us to advise on certain investment products that are not maintained at the Firm’s
recommended custodian, such as life insurance, annuity contracts, 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.
Client’s are advised and are expected to understand that the Firm’s 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 Client accounts.
RETIREMENT PLAN ADVISORY SERVICES
Our Firm offers the following services under our employer-sponsored retirement plans and their
participants:
• Non-Discretionary Investment Advisory Services and/or
• Retirement Plan Consulting Services.
Depending on the type of Plan and the specific arrangement with the Sponsor, we may provide one or
more of these services. Prior to being engaged by the Sponsor, we will provide a copy of this Form ADV
Part 2A along with a copy of our Privacy Policy and Plan Sponsor Investment Management Agreement
("Agreement") that contains the information required under Sec. 408(b)(2) of the Employee
Retirement Income Security Act ("ERISA") as applicable.
Non-discretionary Investment Management Services
These services are designed to allow the Sponsor to retain full discretionary authority or control over
assets of the Plan. We will solely be making recommendations to the Sponsor. We will perform these
Non-Discretionary investment advisory services through our IARs and charge fees as described in this
Form ADV and the Agreement. If the Plan is covered by ERISA, we will perform these investment
advisory services to the Plan as a "fiduciary" defined under ERISA Section 3(21). The Sponsor may
engage us to perform one or more of the following Non-Discretionary investment advisory services:
MAY 2024 | PAGE 7
INVESTMENT POLICY STATEMENT ("IPS")
Our Firm will review with Sponsor the investment objectives, risk tolerance and goals of the
Plan. If the Plan does not have an IPS, we will provide recommendations to Sponsor to assist
with establishing an IPS. If the Plan has an existing IPS, our Firm will review it for consistency
with the Plan's objectives. If the IPS does not represent the objectives of the Plan, we will
recommend to Sponsor revisions to align the IPS with the Plan's objectives.
ADVICE REGARDING DESIGNATED INVESTMENT ALTERNATIVES ("DIAs")
Based on the Plan's IPS or other guidelines established by the Plan, our Firm will review the
investment options available to the Plan and will make recommendations to assist Sponsor
with selecting DIAs to be offered to Plan participants. Once Sponsor selects the DIAs, we will,
on a periodic basis and/or upon reasonable request, provide reports and information to assist
Sponsor with monitoring the DIAs. If a DIA is required to be removed, our Firm will provide
recommendations to assist Sponsor with replacing the DIA.
PARTICIPANT INVESTMENT ADVICE
Our Firm will meet with Plan participants, upon reasonable request, to collect information
necessary to identify the Plan participant's investment objectives, risk tolerance, time horizon,
etc. We will provide written recommendations to assist the Plan participant with creating a
portfolio using the Plan's DIAs or Models, if available. The Plan participant retains sole
discretion over the investment of his/her account.
Retirement Plan Consulting Services
Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor in meeting
his/her fiduciary duties to administer the Plan in the best interests of Plan participants and their
beneficiaries. Retirement Plan Consulting Services are performed so that they would not be considered
“investment advice” under ERISA. The Sponsor may elect for our IARs to assist with any of the following
services:
ADMINISTRATIVE SUPPORT
✓ Assist Sponsor in reviewing objectives and options available through the Plan
✓ Review Plan committee structure and administrative policies/procedures
✓ Recommend Plan participant education /communication policies under ERISA 404(c)
✓ Assist with development/maintenance of fiduciary audit file and document retention
policies
✓ Deliver fiduciary training and/or education periodically or upon reasonable request
✓ Recommend procedures for responding to Plan participant requests
SERVICE PROVIDER SUPPORT
✓ Assist fiduciaries with a process to select, monitor and replace service providers
✓ Assist fiduciaries with review of Covered Service Providers ("CSP") and fee
benchmarking
✓ Provide reports and/or information designed to assist fiduciaries with monitoring CSPs
✓ Coordinate and assist with CSP replacement and conversion
INVESTMENT MONITORING SUPPORT
✓ Periodic review of investment policy in the context of Plan objectives
MAY 2024 | PAGE 8
✓ Assist the Plan committee with monitoring investment performance
✓ Educate Plan committee members, as needed, regarding replacement of DIA(s) and/or
QDIA(s)
PARTICIPANT SERVICES
✓ Facilitate group enrollment meetings and coordinate investment education
✓ Assist Plan participants with financial wellness education, retirement planning and/or
gap analysis
POTENTIAL ADDITIONAL RETIREMENT SERVICES PROVIDED OUTSIDE OF THE
AGREEMENT
We and our IARs, in the course of providing Retirement Plan Services or otherwise, may establish a
client relationship with one or more plan participants or beneficiaries. Such client relationships develop
in various ways, including, without limitation:
• as a result of a decision by the plan participant or beneficiary to purchase services from us
not involving the use of plan assets;
• as part of an individual or family financial plan for which any specific recommendations
concerning the allocation of assets or investment recommendations relating to assets held
outside of a plan; or
• through a rollover of an Individual Retirement Account ("IRA Rollover").
In providing these optional services, we may offer employers and employees information on other
financial and retirement products or services offered by us and our IARs. If we are providing
Retirement Plan Services to a plan, IARs may, when requested by a participant or beneficiary, arrange
to provide services to that participant or beneficiary through a separate agreement.
When a participant requests assistance with an IRA Rollover from his/her plan to an account advised
or managed by us, we will have a conflict of interest if our fees are reasonably expected to be higher
than those we would otherwise receive in connection with the Retirement Plan Services. For
participants invested in plans which we do not advise, we also have a conflict of interest given that we
may not earn any compensation if they remain invested in their current plan. We will disclose relevant
information about the applicable fees charged by us prior to opening an IRA account. Any decision to
affect the rollover or about what to do with the rollover assets remain that of the plan participant or
beneficiary alone.
Participant one-on-ones
We can also be engaged to provide financial education to plan participants. The scope of education
provided to participants will not constitute “investment advice” within the meaning of ERISA and
participant education will relate to general principles for investing and information about the
investment options currently in the plan.
TAX PLANNING AND PREPARATION
Our Firm’s Investment Adviser Representatives, through separate entities, can provide tax planning
and preparation for individuals and business owners. These services are provided to the client for a
MAY 2024 | PAGE 9
separate fee. Accounting services performed by these tax professionals will be separate and distinct
from our advisory services.
SEMINARS AND WORKSHOPS
Our Firm holds seminars and workshops to educate the public on different types of investments and
the different services they offer. The seminars are educational in nature and no specific investment or
tax advice is given.
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. For business owners, our Firm does offer
consulting and specializes in generational transitions, sale preparation, and exit planning.
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 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
MAY 2024 | PAGE 10
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
TE3 is the sponsor and manager of Wrap Program (the “Program”), a wrap fee program (i.e., an
arrangement where brokerage commissions and transaction costs are absorbed by the Firm). The fee
covers transaction costs or commissions resulting from the management of your accounts, however,
most investments trade without transaction fees today, so our payment of these and other incidental
custodial related expenses should not be considered a significant factor in determining the relative
value of our wrap program. Participants in the Program may pay a higher aggregate fee than if
brokerage services are purchased separately. Additional information about the Program is available in
TE3’s Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV.
ASSETS
As of December 31, 2023, our Firm managed a total of $313,196,458 in regulatory assets under
management, all of which is managed under discretionary authority.