A. Firm Information
LEVATUS LLC (“LEVATUS” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws of
the Commonwealth of Massachusetts. LEVATUS was founded in March 2017 as The Nexus Partnership LLC. In
July 2017, The Advisor amended its name to LEVATUS. The Advisor is owned by the Nexus Group LLC and is
operated by Susan E. Dahl (Managing Member and Chief Compliance Officer). This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided by
LEVATUS.
B. Advisory Services Offered
LEVATUS offers advisory services to individuals, high net worth individuals, trusts, and estates (each referred to
as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. LEVATUS’ fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Wealth Advisory Services
LEVATUS provides Clients with wealth advisory services, which generally includes a broad range of
comprehensive financial planning and consulting services in connection with discretionary and non-discretionary
management of investment portfolios and related advisory services. Through these services the Advisor serves
as the point of contact for financial coordination, investment management and administrative support for Clients.
These services are described below.
Investment Management Services – LEVATUS provides investment advisory solutions for its Clients. LEVATUS
will make investment recommendations only after discussions with Clients on their investment goals and
objectives, personal priorities and values, as well as risk tolerance and financial situation. After a thorough
discussion with the Client, LEVATUS constructs a portfolio for each Client, which will consist of individual stocks,
bonds, or options contracts to achieve the Client’s investment goals. LEVATUS may also utilize low-cost,
diversified mutual funds and/or exchange-traded funds (“ETFs”) if it is in the Client’s best interest. For certain
Clients, the Advisor may utilize real estate investment trusts or alternative investments depending on the Client’s
risk profile. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
LEVATUS’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. The investment process is direct and specific, focusing on variables that give insight into each assets
ability to successfully meet the goals, objectives, circumstances, and risk tolerance agreed to by the Client.
LEVATUS will construct, implement and monitor the portfolio based on these insights and updates to the Client’s
financial condition. Each Client will have the opportunity to place reasonable restrictions on the types of
investments to be held in their respective portfolio, subject to acceptance by the Advisor.
LEVATUS evaluates and selects investments for inclusion in Client portfolios after discussing an investment
strategy with the Client. LEVATUS may recommend, on occasion, redistributing investment allocations to
diversify the portfolio or more directly target client priorities. LEVATUS may recommend specific positions to
increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible
hedge against market movement. LEVATUS may recommend selling positions for reasons that include, but are
not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of
securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client,
generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will LEVATUS accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within designated account[s]
at their
the Custodian(2), pursuant to the terms of the wealth advisory agreement. Please see Item 12 – Brokerage
Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Wealth Counsel – LEVATUS provides services that address wholistc finanical needs, with an approach that
formally connects client values and priorities with overalll strategy. As part of this holistic advisory service,
LEVATUS will typically provide comprehensive financial planning, as well as consulting services to Clients,
pursuant to the wealth advisory agreement. These services cover a broad range of topics and may vary
depending on the client’s goals, financial situation, and priorities. Generally, such financial planning will be
tailored to each Client’s needs, including, but not limited to investment planning, retirement planning, personal
savings, education savings, cash flow planning and philanthropic planning.
At the core of the financial plan is a rigorous, analytical risk tolerance assessment, with a thoughtful review of
existing holdings and a comprehensive assessment of tax and estate status. The specific costs associated with
existing holdings are analyzed in detail as to their quality and fit at the start of each relationship. The financial
plan developed for the Client will usually include general recommendations for a course of activity, specific
actions to be taken by the Client and Advisor, and draft Strategy Roadmap which formalizes the path forward.
For example, recommendations may be made that the Client start or revise their investment programs,
commence or alter retirement savings, establish education savings and/or charitable giving programs.
LEVATUS may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. The Advisor will coordinate with these specialists in order to provide a comprehensive approach to the
wealth advisory services. For certain engagements, the Advisor may also provide a written summary of the
Client’s financial situation, observations, and recommendations.
C. Client Account Management
Prior to engaging LEVATUS to provide advisory services, each Client is required to enter into a wealth advisory
agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
• Establishing an Investment Strategy – LEVATUS, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – LEVATUS will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk of each Client.
• Portfolio Construction – LEVATUS will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – LEVATUS will provide investment management and ongoing
oversight of the Client’s investment portfolio.
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D. Wrap Fee Programs
LEVATUS does not manage or place Client assets into a wrap fee program. Wealth advisory services are
provided directly by LEVATUS.
E. Assets Under Management
As of December 31, 2023, LEVATUS manages $137,548,749 in Client assets, $109,695,828 of which are
managed on a discretionary basis and $27,852,921 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.