Description of Firm
Twin Peaks Wealth Advisors, LLC is a registered investment adviser based in Burlingame, CA. We are organized
as a limited liability company under the laws of the State of California, and became a registered investment
adviser in November 2022. Tushar Kumar and Vishal Kumar are the owners of our firm.
The following paragraphs describe our services and fees. Please refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual needs. As
used in this Brochure, the words "we," "our," and "us" refer to Twin Peaks Wealth Advisors, LLC and the words
"you," "your," and "client" refer to you as either a client or prospective client of our firm.
Wealth Management Services
Wealth management services consist of ongoing financial planning and discretionary investment management
services where we manage our clients’ investments within the larger context of the client’s overall wealth
management and planning process. These services are tailored to clients (individuals or families) with
$2,000,000 or more of investable assets.
These services include an initial consultation along with follow up consultations, as may be agreed, to discuss
your unique investment objectives, time horizon, risk tolerance, tax circumstances, and various other financial
factors. Based on our evaluation of the foregoing factors, we will use the information we gather to develop a
strategy that enables our firm to give you continuous and focused investment advice and/or to make
investments on your behalf. As part of our wealth management services, we will customize an investment
portfolio for you in accordance with your risk tolerance and investing objectives. Once we construct an
investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will
periodically rebalance the portfolio as required by, among other things, changes in market conditions and in
your financial circumstances. Clients are required to notify our firm immediately if their financial circumstances
and/or investment objectives change from what has already been disclosed to our firm.
If you engage our firm for wealth management services, you must grant our firm discretion over the selection
and number of securities to be purchased or sold for your account(s). Discretionary authority enables our firm
to execute transactions within your account without obtaining your consent or approval prior to each
transaction. In limited circumstances and in our sole discretion, we may accept instructions from you that limit
our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your
account). Such requests must be presented to our firm in writing. This discretionary authority will also provide
our firm with authorization to delegate discretionary investment management services to other unaffiliated
Sub-Advisors selected by our firm based on your investment objectives and portfolio strategy. Please refer to
Item 16 of this Brochure for more information on how we manage your account(s) with discretion.
For clients with less than $2,000,000 in assets under management, our wealth management services consist
solely of investment management services and do not include complimentary ongoing financial planning and
consulting services. In these instances, clients have the option to engage our firm for stand-alone financial
planning and consulting services for a separate and stand-alone fee.
Management of Held Away Assets
As part of our wealth management services, we provide asset allocation review, rebalancing and management
services for accounts that are not held in custody of the qualified custodian(s) recommended by our firm. These
services are provided through an account aggregation service called Pontera. The service primarily applies to
ERISA and non-ERISA plan assets such as 401(k)s and 403(b)s, and other assets that must be held in custody of
the plan custodian(s). We regularly review the available investment options in these accounts, monitor them,
and periodically rebalance and implement our strategies using different tools,
as necessary. If you elect to allow
our firm to manage your assets through Pontera, you will be notified via email when we place trades through
Pontera. Under no circumstances will we possess privileges that would impute custody to our firm under
applicable rules and regulations, including, but not limited to: maintaining your account log-in credentials on
file; having the ability to change your address on record or ability to authorize distributions from your accounts;
or authorization to open any new accounts on your behalf through the web-based platform.
LPL Financial Sponsored Advisory Programs
We may provide advisory services through certain programs sponsored by LPL Financial LLC (“LPL”), a registered
investment advisor and broker-dealer. For more information regarding the LPL programs, including more
information on the advisory services and fees that apply, the types of investments available in the programs and
the potential conflicts of interest presented by the programs, please see the program account packet (which
includes the account agreement and LPL Form ADV program brochure that we provide you). Below is a brief
description of the LPL program(s) that we generally use:
Model Wealth Portfolios Program (MWP) - MWP offers clients a professionally managed mutual fund
asset allocation program. We will obtain the necessary financial data from the client, assist the client in
determining the suitability of the MWP program and assist the client in setting an appropriate
investment objective. We will initiate the steps necessary to open an MWP account and have discretion
to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated
investment objective. LPL’s Research Department, a third-party portfolio strategist and/or Advisor,
through its IAR, may act as a portfolio strategist responsible for selecting the mutual funds or ETFs
within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will
authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to
liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for
MWP accounts. MWP requires a minimum asset value for a program account to be managed. The
minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios.
The lowest minimum for a portfolio is $10,000. In certain instances, a lower minimum for a portfolio is
permitted.
Financial Planning and Consulting Services
We offer financial planning and consulting services where we provide a variety of advisory services to clients
regarding the management of their financial assets based upon an analysis of their individual needs. These
services can range from broad-based financial planning with investment recommendations to consultative or
single subject planning.
Financial planning and consulting services are based on your financial situation at the time we present our
recommendations to you, and on the financial information you provide to us. You must promptly notify our firm
if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial
recommendations. Should you choose to act on any of our recommendations you are not obligated to
implement such recommendations through any of our other investment advisory services, and you may act on
our recommendations by placing securities transactions with any brokerage firm.
Types of Investments
We may advise you on any type of investment that we deem appropriate based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our
advisory relationship. Since our investment strategies and advice are based on each client’s specific financial
situation, the investment advice we provide to you may be different or conflicting with the advice we give to
other clients regarding the same security or investment. We do not participate in a wrap fee program.
Assets Under Management
As of January 30, 2024, we manage approximately $318,501,282 in client assets on a discretionary basis.