A. Description of the Advisory Firm
Varra Wealth Management LLC d/b/a Varra Financial (hereinafter “VWML”) is a Limited
Liability Company organized in the State of Colorado. The firm was formed in October
2022, and the principal owner is Gina Varra.
B. Types of Advisory Services
Portfolio Management Services
VWML offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. VWML creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
VWML evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. VWML will request discretionary authority from clients in order
to select securities and execute transactions without permission from the client prior to
each transaction. Risk tolerance levels are documented in the Investment Policy
Statement, which is given to each client.
VWML seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of VWML’s economic,
investment or other financial interests. To meet its fiduciary obligations, VWML attempts
to avoid, among other things, investment or trading practices that systematically
advantage or disadvantage certain client portfolios, and accordingly, VWML’s policy is to
seek fair and equitable allocation of investment opportunities/transactions among its
clients to avoid favoring one client over another over time. It is VWML’s policy to allocate
investment opportunities and transactions it identifies as being appropriate and prudent
among its clients on a fair and equitable basis over time.
Pension Consulting Services
VWML offers consulting services to pension or other employee benefit plans (including
but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed
to achieve objectives
• monitoring performance of money managers and investment options and
making recommendations for changes
• recommending other service providers, such as custodians, administrators
and broker-dealers
• creating a written pension consulting plan
These services are based on the goals, objectives,
demographics, time horizon, and/or risk
tolerance of the plan and its participants.
Financial Planning
Financial plans and financial planning may include but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
VWML generally limits its investment advice to mutual funds, fixed income securities,
equities and ETFs. VWML may use other securities as well to help diversify a portfolio
when applicable.
Written Acknowledgement of Fiduciary Status
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 interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• 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.
C. Client Tailored Services and Client Imposed Restrictions
VWML will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by VWML on behalf of the client. VWML will review the client’s financial
plan, including tax planning, retirement planning, asset allocation overview, cash flow
analysis, and investment selection. VWML may use model allocations together with a
specific set of recommendations for each client based on their personal restrictions, needs,
and targets. Clients may not impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. VWML does not participate in wrap fee
programs.
E. Assets Under Management
VWML has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 0.00 $ 106,881,022.00 April 2023