This disclosure document is being offered by Signal Advisors Wealth, LLC (“us”, “we”, “our” or “Signal
Wealth”) about the investment advisory services we provide. It discloses information about our services
and the way those services are made available to our clients.
We became a registered investment adviser in January 2023, and we are owned by Signal Advisors USA,
Inc.
ASSET MANAGEMENT SERVICES PROVIDED TO INDEPENDENT REGISTERED INVESTMENT ADVISERS
Signal Wealth sponsors an investment management platform also known as Signal Wealth TAMP Services.
TAMP stands for “turnkey asset management program” and is referred to throughout this brochure as the
“Signal Platform.” The Signal Platform is available to independent registered investment advisory firms
and investment adviser representatives of Signal Wealth (referred to as the “RIA Advisers”).
Signal Wealth has and will enter into an investment management and services agreement (each a “RIA
Adviser Agreement”) with each RIA Adviser in order to provide each RIA Adviser with access to the Signal
Platform. The purpose of the RIA Adviser Agreement is to provide the RIA Advisers (each of whom are
investment adviser representatives) with investment management services, as well as other resources
and tools to enable the RIA Advisers to better serve their own investment management clients (referred
to herein as the “client” or “retail client”).
The Signal Platform provides RIA Advisers with access to custodians, model portfolios managed by Signal
Wealth, strategies managed by unaffiliated third party money managers, asset allocation services, and
additional programs and features aimed at providing a comprehensive investing environment for
investors. Additionally, through the Signal Platform, RIA Advisers can choose to invest their clients’ assets
in accordance with a number of model portfolios or third party strategies, in each case based on the
financial circumstances and investing goals of the RIA Adviser clients. The Signal Platform also provides
RIA Advisers’ with access to account monitoring and reporting tools. Signal Wealth executes trading
instructions as submitted by the RIA Adviser.
In providing investment advice and portfolio management services to retail clients, each RIA Adviser acts
as an investment adviser and fiduciary to and on behalf of each of its respective clients. RIA Advisers are
not agents of Signal Wealth. RIA Advisers maintain the direct, contractual relationship with retail clients.
In this capacity, RIA Advisers are responsible for assisting retail clients in completing administrative
paperwork, servicing the accounts, and providing account maintenance. Importantly, RIA Advisers
maintain responsibility for the initial and ongoing client relationship, including the initial and ongoing
suitability determination, and fiduciary duty of care. RIA Advisers retain the sole authority and
responsibility for providing customized investment advice and portfolio management services to their
clients and for implementing their clients’ investment recommendations in accordance with the client’s
financial circumstances and investment objectives. RIA Advisers operate pursuant to the discretionary
authority granted to them by the clients and exercise investment judgment accordingly. RIA Adviser is
responsible for obtaining and furnishing to Signal Wealth information pertaining to custodial paperwork,
account manager selection, model allocations, investing instructions, account guidelines and any
reasonable restriction requests by retail clients, which enables Signal Wealth to perform services through
the Signal Platform.
The RIA Adviser Agreement requires RIA Advisers to obtain retail clients’ authorization to appoint
discretionary authority to Signal Wealth to implement trades on retail clients’ behalf in specified accounts
on the Signal Platform. Signal Wealth will use this discretionary authority to implement model portfolio
selections or direct trading instructions provided by RIA Adviser. Custodians may require additional
paperwork from each client to grant trading discretion to Signal Wealth. Retail clients should therefore
consult the RIA Adviser’s Form ADV part 2A Disclosures Brochure for a full description of that investment
adviser’s investment advisory strategies and services.
Signal Wealth grants RIA Adviser access to performance software through the Signal Platform to enable
performance reporting. Signal Wealth facilitates the fee billing on behalf of the RIA Adviser. Through RIA
Adviser’s investment management agreement with retail clients, retail clients will authorize the custodian
to deduct fees directly from the client’s account for management of the Client’s Signal Platform accounts.
The investment management fees are deducted by the custodian and paid to Signal Wealth. Signal Wealth
then pays the RIA Adviser its portion of the fees from the total management fees deducted from client
accounts managed by RIA Adviser on the Signal Platform. The authorization for use of third-party asset
management services will be part of each RIA Adviser’s investment management agreement with clients.
As stated above, RIA Advisers outsource some or all of their portfolio management services through an
investment management agreement between RIA Adviser and its retail clients. Signal Wealth maintains
a limited power of attorney, granted by retail clients through the investment management agreement, to
direct trading in client accounts on the Signal Platform. As the sponsor of the Signal Platform, Signal
Wealth has discretionary authority to engage in the following:
• hire and terminate third-party money managers on the Signal Platform and reallocate assets
among them.
• Change portfolios and strategies offered on the Signal Platform, as Signal Wealth deems
appropriate, to meet the objectives of the portfolios offered through the Signal Platform.
• Tailor portfolio management services to meet the needs of the clients of RIA Advisers and seek to
ensure that portfolios are managed in a manner consistent with those needs and objectives.
Signal Wealth’s investment committee serves as the investment manager and makes recommendations
and selects investments for the investment portfolios/strategies that we make available to RIA Advisers.
In so doing, the committee may elect to make investment recommendations utilizing asset allocation
software and models. Asset allocation models are generally designed to attempt to achieve diversification
to reduce the risk of loss due to variation of investment returns of any particular asset class. Signal Wealth
will accept retail client accounts with restrictions, provided the restrictions are reasonable and agreed to
in writing. Signal Wealth primarily allocates retail client assets among various equities, exchanged traded
funds (“ETFs”), no-load or load-waived mutual funds, cash, or alternative investments in accordance with
the client’s stated investment objectives. All of which are considered asset allocation categories for the
investment strategies.
All retail client accounts will be held at an independent Custodian pursuant to an agreement between the
Custodian and the RIA Adviser client.
INVESTMENT AND WEALTH 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. We may accept
accounts with certain restrictions, if circumstances warrant. We primarily allocate client assets among
cash, individual stocks, bonds, exchange traded funds (“ETFs”), equities, corporate bonds, municipal
bonds, U.S. Government Treasuries and cash in accordance with their stated investment. When
appropriate, we recommend Private Fund investments to certain suitable clients. We generally invest
Client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial
paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on
our client’s cash balances through relatively low-risk and conservative investments. In most cases, at least
a partial cash balance will be maintained in a money market account so that our firm may debit advisory
fees for our services related to this service.
Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s
circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and
regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals
and objectives.
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.
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.
In all cases, clients have a direct and beneficial interest in their securities, rather than an undivided interest
in a pool of securities. We do
have limited authority to direct the Custodian to deduct our investment
advisory fees from your accounts, but only with the appropriate written authorization from clients.
Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically,
these are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to
advise on certain investment products that are not maintained at their primary custodian, such as variable
life insurance, annuity contracts, and assets held in employer sponsored retirement plans and qualified
tuition plans (i.e., 529 plans).
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
their 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 client in mind, our IARs and RIA Advisers
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 client legacy objectives. Our IARs and RIA
Advisers might partner with 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.
The 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, 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 adviser, 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 is provided to the client in the form of a financial plan.
A periodic review will be provided by the Adviser, if indicated by the Client and Adviser per the Agreement.
More frequent reviews occur but are not necessarily communicated to the client unless immediate
changes are recommended.
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 reviewed by our Firm’s Chief
Compliance Officer and remains available to address any questions that a client or prospective client has
regarding the oversight.
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 must act in your best interest and
not put our interests ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
CO-BRANDED INVESTMENT ADVISER REPRESENTATIVES
Our firm offers services through our network of investment adviser representatives (“IARs”). IARs may
have their own legal business entities whose trade names and logos are used for marketing purposes and
may appear on marketing materials and/or disclosure statements and client statements. The Client should
understand that the businesses are legal entities of the IAR and not of our firm. The IARs are under the
supervision of our firm and the investment advisory services of the IAR are provided through our firm. A
complete listing of the entities is listed on our ADV Part 1.
OTHER FINANCIAL 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.
ADMINISTRATIVE SERVICES
Signal Wealth has contracted with a third-party entity to utilize their technology platform which supports
data reconciliation, performance reporting, fee calculation, client relationship maintenance, at least
quarterly performance evaluations, and other functions related to the administrative tasks of managing
RIA Advisers’ accounts. Due to this arrangement, the third-party entity will have access to retail client
accounts but will not serve as an investment adviser. The third-party vendor bills Signal Wealth an annual
fee (paid quarterly) for each account administered by its software. This fee is paid from the portion of the
investment management fee retained by Signal Wealth. Periodic performance reporting is made available
by us and provides relevant portfolio information, including but not limited to, asset allocation, securities
positions, end-of-period fair market values, and investment performance for the period.
HELD AWAY ACCOUNT ASSET MANAGEMENT
We use a third-party platform (Pontera, formerly FeeX) to facilitate management of held away assets such
as defined contribution plan participant accounts, with discretion. 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 Client account(s) is connected to the platform, Adviser will review the current
account allocations. When deemed necessary, 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 and manage internal fees that harm
account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be
made as deemed necessary.
WRAP FEE PROGRAMS
Signal Wealth does sponsor and may recommend a Wrap Fee Program for the client’s account(s). A “wrap
fee program” for purposes of the SEC is a program under which investment advisory and brokerage
execution services are provided for a single “wrapped” fee that is not based on the transactions in a client
account. Clients with Wrap Fee Program accounts will be provided with Signal Wealth’s Wrap Fee
Brochure.
ASSETS
As of December 31, 2023, the firm had discretionary assets under management of $461,073,562 and
$4,192,136 in non-discretionary assets.