Our firm manages assets for many different types of clients to help meet their financial goals while
remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in
the client’s best interest. This is accomplished in part by knowing the client. Our firm has established
a service-oriented advisory practice with open lines of communication. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Our firm sponsors and manages a wrap fee program where clients pay a single fee for investment
advisory services and associated custodial transaction costs. Transaction fees will be paid by our firm
based on a percentage of the dollar amount of assets in the account(s) or via individual transaction
charges. Because our firm absorbs client transaction fees, an incentive exists to limit trading activities
in client accounts. The overall cost you will incur if you participate in our wrap fee program may be
higher or lower than you might incur by separately purchasing the types of securities available.
Our recommended custodian, Raymond James, does not charge transaction fees for U.S. listed
equities and exchange traded funds. Since we pay the transaction fees charged by the custodian to
clients participating in our wrap fee program, this presents a conflict of interest because we are
incentivized to recommend equities and exchange traded funds over other types of securities in order
to reduce our costs.
As a fiduciary, we have adopted written policies and procedures designed to help mitigate such
conflicts of interests. As a fiduciary, we will always act in our client’s best interests.
Our Wrap Advisory Services
As part of our Wrap Fee Program and management services, a portfolio is created consisting of
individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and
private securities or investments. The client’s individual investment strategy is tailored to their specific
needs and may include some or all of the previously mentioned securities. 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 as
necessary, rebalanced based upon the client’s individual needs, stated goals and objectives.
If you participate in the Wrap Fee Program, we require you to grant our firm discretionary authority to
manage your account. Discretionary authorization will allow us to determine the specific securities, and
the amount of securities, to be purchased or sold for your account without your approval prior to each
transaction. Discretionary authority is typically granted by the investment advisory agreement you sign
with our firm. In our sole discretion, you may limit our discretionary authority (for example, limiting the
types of securities that can be purchased or sold for your account) by providing our firm with your
restrictions and guidelines in writing. Restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the account.
The maximum annual fee charged for this service will not exceed 2.00% of assets under management.
Fees to be assessed will be outlined in the advisory agreement to be signed by the Client. Our firm
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 The Salvetti Group
bills on cash unless indicated otherwise in writing. Our firm may, in its sole discretion, directly
invoice clients and in such instances, advisory fees are due upon 15 days of the invoice date.
The annualized fee is billed monthly in arrears based on the average daily balance of the client’s
account(s). Fees are negotiable and will be deducted from client account(s). As part of this process,
Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the
market values for each security included in the Assets and all account disbursements,
including the amount of the advisory fees paid to our firm; and
b) Clients will provide authorization permitting our firm to be directly paid by these terms.
Our firm will send an invoice (or fee debiting instructions) directly to the custodian.
Brokerage Practices
If you participate in the Program, you will be required to establish an account with Raymond James
& Associates (RJA) as the qualified custodian. If you do not direct our firm to execute transactions
through RJA, we reserve the right to not accept your account. Not all advisers require their clients to
direct brokerage. Since you are required to use RJA, we may be unable to achieve the most favorable
execution of your transactions. We believe that RJA provides quality execution services based on
several factors, including, but not limited to, the ability to provide professional services, reputation,
experience and financial stability.
Evaluation of custodial relationships is
based on many factors, including the level of services
provided, the custodian's financial stability, and the cost of services provided by the custodian to our
clients, which includes the yield on cash sweep choices, commissions, custody fees and other fees or
expenses.
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research. Also, we do not have any soft dollar arrangements.
As a registered investment adviser, we may have access to research products and services from your
account custodian (RJA). These products may include financial publications, information about
particular companies and industries, research software, and other products or services that provide
lawful and appropriate assistance to our firm in the performance of our investment decision-making
responsibilities. Such research products and services are provided to all investment advisers that
utilize the service platforms of these firms, and are not to paid for with soft dollars; however, the
receipt of such research and services benefits our firm. To the extent our firm receives any research
products and/or services from your acting custodian/broker-dealer, a conflict of interest arises in
that such research and/or services might not directly benefit client accounts. In effort to mitigate this
conflict of interest it is our firm's policy to use such research or services to assist in making
investment decisions on behalf of client accounts or to assist with our overall responsibility for
servicing client accounts, respectively. As a registered investment adviser our firm and
representatives of our firm have a fiduciary duty to act in our client's best interest.
Aggregated Trades
We combine multiple orders for shares of the same securities purchased for discretionary advisory
accounts we manage (this practice is commonly referred to as "aggregated trading"). We will then
distribute a portion of the shares to participating accounts in a fair and equitable manner.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 The Salvetti Group
Generally, participating accounts will pay a fixed transaction cost regardless of the number of
shares transacted. In certain cases, each participating account pays an average price per share for
all transactions and pays a proportionate share of all transaction costs on any given day. In the
event an order is only partially filled, the shares will be allocated to participating accounts in a fair
and equitable manner, typically in proportion to the size of each client’s order. Accounts owned by
our firm or persons associated with our firm may participate in aggregated trading with your
accounts; however, they will not be given preferential treatment.
General Wrap Fee Program Disclosures
The benefits under a wrap fee program depend, in part, upon the size of the Account, the management
fee charged, and the number of transactions likely to be generated in the Account. For example, a
wrap fee program may not be suitable for Accounts with little trading activity. In order to evaluate
whether a wrap fee program is suitable for you, you should compare the Program Fee and any other
costs of the Program with the amounts that would be charged by other advisers, broker-dealers, and
custodians, for advisory fees, brokerage and other execution costs, and custodial services comparable
to those provided under the Program.
In considering the investment programs described in this Brochure, you should be aware that
participating in a wrap fee program may cost more or less than the cost of purchasing advisory,
brokerage, and custodial services separately from other advisers or broker-dealers.
Similar advisory services may be available from other registered investment advisers for lower fees.
Other Types of Fees & Expenses:
In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen
custodian for certain investments, charges imposed directly by a mutual fund, index fund, or
exchange traded fund, which shall be disclosed in the fund’s prospectus (e.g., fund management fees
and other fund expenses), distribution fees, surrender charges, variable annuity fees, IRA and
qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market makers, fees for
trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage
accounts and securities transactions. Our firm does not receive a portion of these fees.
Termination and Refunds:
Either party may terminate the advisory agreement in writing at any time. Since fees are billed
monthly in arrears there are no refunds upon termination.
Wrap Fee Program Recommendations:
Our firm does not recommend or offer the wrap program services of other providers.
Assets Under Management
As of December 31, 2023, we manage approximately $474,524,728 in client assets under
management on a discretionary basis, and approximately $12,691,989 on a non-discretionary basis.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 7 The Salvetti Group