About Us
Moore Wealth, LLC (“Moore Wealth”) is a registered investment adviser, offering financial planning and
asset management services to clients. Moore Wealth has been in business since 2003, and its principal
owners are Shabri Moore, Erik Moore and Sean Moore. Moore Wealth is committed to delivering
exceptional service through one-on-one advising, collaboration with clients’ professional and personal
consultants, and the design and implementation of strategies tailored to meet unique goals and
aspirations.
This Brochure is designed to provide detailed and clear information relating to each item noted in the
table of contents. Certain disclosures are repeated in one or more items, and/or other items are referred
to in an effort to be as comprehensive as possible on the broad subject matters discussed. Within this
Brochure, certain terms in either upper- or lowercase are used as follows:
• “We,” “us,” and “our” refer to Moore Wealth.
• “Advisor” refers to persons who provide investment recommendations or advice on behalf of
Moore Wealth.
• “You,” “yours,” and “client” refer to clients of Moore Wealth and its advisors.
Description of Services Available
Moore Wealth offers a suite of investment advisory services and programs to its advisors for use with
their clients. Our investment advisory services and programs are designed to accommodate a wide range
of client investment philosophies, goals, needs, and investment objectives. Through these various
advisory programs and services, clients have access to a wide range of securities products, including, but
not limited to, common and preferred stocks; municipal, corporate, and government fixed income
securities; mutual funds; exchange-traded products (“ETPs”); options and derivatives; unit investment
trusts (“UITs”); and variable and fixed-indexed insurance products, as well as other products and services,
including a variety of asset allocation services, financial planning, and consulting services. Our advisors
may also offer advice related to direct participation programs, private placements, and other alternative
investments, such as alternative energy programs, research and development programs, leasing
programs, real estate programs, and pooled commodities futures programs.
Commonwealth Programs
Moore Wealth has entered into an agreement to offer clients access to certain investment advisory
programs sponsored by with Commonwealth Financial Network (“Commonwealth”) an SEC-registered
investment adviser. Specifically, Commonwealth’s Wealth Management Consulting Program,
Retirement Plan Consulting Program, PPS Custom Account Program and PPS Select Account Program are
available to our clients as appropriate for the client’s individual situation. This arrangement does not
create an advisory relationship between Commonwealth and Moore Wealth or Commonwealth and you.
It is our responsibility to comply with all laws, rules, and regulations governing the provision of
investment advice to you, including, but not limited to, the Investment Advisers Act of 1940 (“Advisers
Act”), as amended, and the rules promulgated thereunder, as well as all applicable state statutes, rules,
and regulations that apply to our business. Moore Wealth is responsible for the accuracy of all records
that reflect your financial condition, risk tolerance, and investment objectives of your account(s); that
the orders that we place with or through Commonwealth on your behalf are suitable for you and
consistent with our fiduciary duty to you; and that the investment advice and advisory services provided
to you in general are and remain appropriate for you. Commonwealth will provide, or cause to be
provided, to clients’ trade confirmations and custodial account statements. Commonwealth will provide
or will otherwise make available to the advisor duplicate trade confirmations and Client custodial
account statements.
Wealth Management Consulting: We provide advisory consulting services on a wide range of topics,
including, but not limited to, comprehensive financial planning, budgeting and cash flow analysis, major
purchases, education planning, retirement income/longevity planning, portfolio analysis, estate planning
analysis, investment analysis, business succession planning, and fringe benefit analysis. Clients may
engage our advisors for consulting services on a fixed-fee basis. Fees may be paid at the time of service or
in advance of the service being rendered. Clients may also elect to enter into consulting or financial
planning engagements with advisors separately from, in addition to, or as part of their managed account
program, as may be agreed between the client and advisor.
Retirement Plan Consulting: We provide a fee-for-service consulting program whereby our advisors offer
onetime or ongoing advisory services to qualified retirement plans. Qualified plan clients may engage our
advisors for Retirement Plan Consulting services on an asset-based fee basis. The maximum annual
consulting fee, when stated as a percentage of assets, is 0.50% and is negotiable. Hourly fees may not
exceed $500 per hour. It is the responsibility of the plan sponsor to ensure these fees are reasonable. Fees
may be paid at the time of service, in advance of service, or after service has been rendered. Through the
Retirement Plan Consulting Program, advisors assist plan sponsors with their fiduciary duties and provide
individualized advice based upon the needs of the plan and/or plan participants regarding investment
management matters, such as:
• Investment policy statement support
• Plan menu design and monitoring
• Service provider support
• Participant advice programs
Clients who participate in one or more of Commonwealth’s programs will receive Commonwealth’s Form
ADV Part 2 and/or Wrap Fee Brochure, in addition to Moore Wealth’s Form ADV Part 2. Clients should
refer to Commonwealth’s Form ADV Part 2 and/or Wrap Fee Brochure for detailed information about
Commonwealth and Commonwealth’s programs.
Asset Management Services
PPS Custom (Transactions): The PPS Custom Program enables an advisor to assist the client in developing
a personalized investment portfolio using one or more investment types, including, but not limited to,
stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), UITs, variable and fixed-indexed annuities,
and alternative investments. The advisor typically acts as portfolio manager, with full investment
discretion, although clients may elect to have the advisor manage the account on a nondiscretionary basis.
PPS Select: The PPS Select Program offers a variety of model portfolios from which investors may choose.
The PPS Select model portfolios are created and managed on a discretionary basis by Commonwealth’s
Investment Management and Research team. The client’s advisor will help the client determine which PPS
Select models are best suited for the client based on his or her risk profile, investment objectives, and
preferences, leaving the actual trading decisions to Commonwealth’s Investment Management and
Research team. PPS Select offers a variety of model portfolios with varying investment product types,
including mutual fund and ETF portfolios, equity portfolios, fixed income portfolios, and variable annuity
subaccount portfolios.
Wrap Fee Programs
The PPS Select program sponsored by Commonwealth and offered by Moore Wealth is considered a “wrap
fee” program in which the client pays a specified fee (known as a “wrap fee”) for portfolio management
services and trade execution. Wrap fee programs differ from other programs in that the asset-based fee
structure for wrap programs is intended to be largely all inclusive, whereas non-wrap fee programs
typically assess trade-by-trade execution costs that are in addition to the asset-based fees.
The PPS Select Program is managed in accordance with the investment methodology and philosophy of
Commonwealth’s own Investment Management and Research team.
For the investment advisory services provided to you by Commonwealth and your advisor,
Commonwealth and your advisor receive a portion of the wrap fees you pay when you participate in any
wrap fee program through Commonwealth. Commonwealth receives a higher portion of the wrap fees
you pay when you participate in Commonwealth’s PPS Select programs to compensate for investment
management and research services provided by the Commonwealth Investment Management and
Research team.
For more information relating to wrap fee programs, please refer to Appendix 1 of Commonwealth’s Form
ADV Part 2A brochure, titled “The Wrap Fee Program Brochure.”
Program Choices
The specific advisory program you select may cost you more or less than purchasing program services
separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the
same services purchased separately include, but may not be limited to, the type and size of the account;
the historical or expected size or number of trades for the account; the types of securities and strategies
involved; the amount of fees, commissions, and other charges that apply at the account or transaction
level; and the number and range of supplementary advisory and client-related services provided to the
account. Lower fees for comparable services may be available from other sources. You are under no
obligation to engage us for services and are free to use the firm of your choice.
No Legal or Tax Advice
Investment recommendations and advice offered by Moore Wealth and its advisors do not constitute
legal, tax, or accounting advice. Clients should coordinate and discuss the impact of the financial advice
they receive from their advisor with their attorney and accountant. Clients should also inform their advisor
promptly of any changes in their financial situation, investment goals, needs, or objectives. Failure to
notify the advisor of any material changes could result in investment advice not meeting the changing
needs of the client.
IRA Rollover Considerations
As part of our financial planning and advisory services, we may provide you with recommendations and
advice concerning your employer retirement plan or other qualified retirement account. When
appropriate, we may recommend that you withdraw the assets from your employer’s retirement plan or
other qualified retirement account and roll the assets over to an individual retirement account (“IRA”) to
be managed by our firm. If you elect to roll the assets to an IRA under our management, we will charge
you an asset-based fee as described in Item 5. This practice presents a conflict of interest because our
Advisory Representative has an incentive to recommend a rollover to you for the purpose of generating
fee-based compensation rather than solely based on your needs. You are under no obligation,
contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you
are under no obligation to have your IRA assets managed under our program or a Third-Party Managed
Program. You have the right to decide whether to complete the rollover and the right to consult with
other financial professionals.
Some employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, you should consider the costs and benefits of each.
An employee will typically have four options:
1. Leave the funds in your employer’s (former employer’s) plan.
2. Roll over the funds to a new employer’s
retirement plan.
3. Cash out and take a taxable distribution from the plan.
4. Roll the funds into an IRA rollover account.
Each of these options has advantages and disadvantages. Before making a change, we encourage you to
speak with your financial advisor, CPA and/or tax attorney.
Before rolling over your retirement funds to an IRA for us to manage or to a Third-Party Managed Program,
carefully consider the following. NOTE: This list is not exhaustive.
1. Determine whether the investment options in your employer’s retirement plan address your
needs or whether other types of investments are needed.
a. Employer retirement plans generally have a more limited investment menu than IRAs.
b. Employer retirement plans may have unique investment options not available to the
public, such as employer securities or previously closed funds.
2. Your current plan may have lower fees than our fee and/or the Third-Party Manager’s fee
combined.
a. If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer’s retirement plan and how the costs
of those share classes compare with those available in an IRA.
3. You should understand the various products and services available through an IRA provider and
their costs.
4. It is likely you will not be charged a management fee and will not receive ongoing asset
management services unless you elect to have such services. If your plan offers management
services, the fee associated with the service may be more or less than our fee and/or the Third-
Party Manager’s fee combined.
5. The Third-Party Manager’s or our management strategy may have higher risk than the options
provided to you in your plan.
6. Your current plan may offer financial advice, guidance, management and/or portfolio options at
no additional cost.
7. If you keep your assets titled in a 401(k) or retirement account, you could potentially delay your
required minimum distribution beyond age 73.
8. Your 401(k) may offer more liability protection than a rollover IRA; each state varies. Generally,
Federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been
generally protected from creditors in bankruptcies; however, there can be exceptions. Consult an
attorney if you are concerned about protecting your retirement plan assets from creditors.
9. You may be able to take out a loan on your 401(k), but not from an IRA.
10. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception
such as disability, higher education expenses or a home purchase.
11. If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
12. Your plan may allow you to hire us or another firm as the manager and keep the assets titled in
the plan name.
It is important that you understand your options, their features, and their differences, and decide whether
a rollover is best for you. If you have questions, contact us at our main number listed on the cover page
of this brochure.
In addition to complying with applicable SEC rules, Moore Wealth is subject to certain rules and
regulations adopted by the U.S. Department of Labor when we provide nondiscretionary investment
advice to retirement plan participants and IRA owners. When these DOL rules apply, our advisors and
Moore Wealth are “fiduciaries,” for purposes of the Employee Retirement Income Security Act of 1974
(“ERISA”), as amended, and the Internal Revenue Code of 1986 (“the Code”), as amended. Therefore,
Moore Wealth and our advisors may not receive payments that create conflicts of interest when providing
fiduciary investment advice to plan sponsors, plan participants, and IRA owners, unless we comply with a
prohibited transaction exemption (“PTE”). As of December 20, 2021 Moore Wealth and our advisors will
comply with ERISA and the Code by using PTE 2020-02. As fiduciaries under ERISA and the Code, we render
advice that is in plan participants’ and IRA customers’ best interest. Moore Wealth and our advisors’ status
as an ERISA/Code fiduciary is limited to ERISA/Code covered nondiscretionary advice and
recommendations regarding rolling over a retirement account and does not extend to all situations.
Individualized Services and Client-Imposed Restrictions
The investment advisory services provided by our advisors depend largely on the personal information
the client provides to the advisor. In order for our advisors to provide appropriate investment advice to,
or, in the case of discretionary accounts, make tailored investment decisions for, the client, it is very
important that clients provide accurate and complete responses to their advisor’s questions about their
financial condition, needs, goals, and objectives and notify the advisor of any reasonable restrictions they
wish to apply to the securities or types of securities to be bought, sold, or held in their managed account.
It is also important that clients promptly inform their advisor of any changes in their financial condition,
investment objectives, personal circumstances, or reasonable investment restrictions pertaining to the
management of their account, if any, that may affect their overall investment goals and strategies or the
investment advice provided or investment decisions made by their advisor.
In general, the client’s advisor is responsible for delivering investment advisory services to clients, and
clients generally deal with matters relating to their accounts by contacting their advisor directly. Of course,
clients may contact Moore Wealth directly with questions about the advisory services offered by our firm.
Assets Under Management
Moore Wealth currently manages $ 139,972,662 in assets, all on a discretionary basis.
Program Choice Conflicts of Interest
Clients should be aware that the compensation to Moore Wealth and your advisor will differ according to
the specific advisory programs or services provided. This compensation to Moore Wealth and your advisor
may be more than the amounts we would otherwise receive if you participated in another program or
paid for investment advice, brokerage, or other relevant services separately. Lower fees for comparable
services may be available through our firm or from other sources. Moore Wealth and your advisor have a
financial incentive to recommend advisory programs or services that provide us higher compensation over
other comparable programs or services available from our firm or elsewhere that may cost you less. For
example, the costs you will incur to have your account managed by our firm may be more than what other
similar firms may charge. It’s important to understand all the associated costs and benefits the program
and services you select so you can decide which programs and services are best suited for your unique
financial goals, investment objective, and time horizon. We encourage you to review our Form CRS and
to discuss your options with your advisor.
In addition, Commonwealth offers our firm and our advisors one or more forms of financial benefits based
on our total assets under management held at Commonwealth or in Commonwealth’s PPS Program
accounts, as well as financial assistance for transitioning from another firm to Commonwealth. The types
of financial benefits that your advisor may receive from Commonwealth include, but are not limited to,
forgivable or unforgivable loans, enhanced payouts, and discounts or waivers on transaction, platform,
and account fees; technology fees; research package fees; financial planning software fees; administrative
fees; brokerage account fees; account transfer fees; licensing and insurance costs; and the cost of
attending conferences and events. The enhanced payouts, discounts, and other forms of financial benefits
that your advisor may have the opportunity to receive from Commonwealth provide a financial incentive
for our firm and your advisor to select Commonwealth as broker/dealer for your accounts over other
broker/dealers from which they may not receive similar financial benefits. Please see items 12 and 14 of
this Brochure for more detailed information about these types of conflicts and our relationship with
Commonwealth.
Commonwealth charges our advisors an administrative fee at the same time clients are charged asset-
based fees for their managed accounts. The administrative fee is charged to and paid by the advisor rather
than the advisor’s clients and is calculated as a percentage of the total managed account assets, including
cash and money market positions, held by the advisor’s clients. The administrative fee is used to offset
Commonwealth’s maintenance costs associated with account reporting and reconciliation.
In the same manner as many advisors offer asset management fee discounts to their larger clients,
Commonwealth offers those advisors to whom it charges administrative fees discounts based on their
total assets under management. As these advisors grow their business, they are eligible for reduced
administrative fees. This potential reductions in administrative fees presents a conflict of interest because
it provides a financial incentive for advisors who receive the discounts to recommend Commonwealth’s
PPS programs over other available programs that do not offer such potential discounts to the advisors.
The PPS Custom Program (Transactions) assesses transaction charges for the purchase and sale of certain
securities in the account. In almost all cases, Moore Wealth has elected to pay the transaction charges on
a client’s behalf.
1 If the firm elects to pay transaction charges, clients should understand that the annual
management fee they pay may be higher than what they would otherwise pay if the firm did not elect to
pay transaction charges for their account. Depending on the frequency of trading activity, the types of
securities products bought and sold, and whether the advisor uses no-transaction-fee mutual funds that
do not assess transaction charges, the firms’ election to pay transaction charges may cost a client more
or cost the firm less, which is a conflict of interest. Further, the firm’s ability to choose whether to pay the
transaction charges for one client but not another presents a conflict of interest because the firm has a
financial incentive to trade less for the accounts of clients for whom the firm pays transaction charges
than for those clients who are responsible for paying their own transaction charges. Regardless of whether
the firm or client pays the transaction charges, clients should understand that the mere existence of
transaction charges could cause a firm to reduce, delay, or avoid executing certain transactions in an effort
to reduce, delay, or avoid trading costs.
Clients who choose to open a PPS Custom Program (Transactions) account should carefully consider these
factors and discuss the costs and benefits of whether they or their advisor should pay transaction charges,
as well as the extent to which the existence of transaction charges (regardless of who pays) impacts their
advisor’s investment decisions. PPS Custom Program (Transactions) clients should consider the annual
fees, administrative and other charges, revenue-sharing arrangements, and other compensation that
Commonwealth and the advisor receive in making a fair and reasonable assessment of the total costs
associated with their decision to open and maintain a PPS Custom Program (Transactions) account.