A. Firm Information
S Capital Wealth Advisors, LLC d/b/a Yes Wealth Management (“Yes Wealth Management” 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 State of Delaware. Yes Wealth
Management was founded in July 2014 and is owned and operated by Robert E. Schneeweis (Chief Executive
Officer), Thomas R. Schneeweis (Chief Investment Officer), Sarah L. Johnson (President), and Robert J.
Schneeweis (Chief Operating Officer and Chief Compliance Officer). This Disclosure Brochure provides
information regarding the qualifications, business practices, and the advisory services provided by Yes Wealth
Management.
B. Advisory Services Offered
Yes Wealth Management offers investment advisory services to individuals, high net worth individuals, trusts,
estates, businesses, and retirement plans (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 toward each Client and seeks to mitigate potential
conflicts of interest. Yes Wealth Management’s 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.
Investment Management Services
Yes Wealth Management provides customized investment advisory solutions for its Clients. This is achieved
through continuous personal Client contact and interaction while providing discretionary investment management
and related advisory services. Yes Wealth Management works closely with each Client to identify their investment
goals and objectives, as well as their risk tolerance, and to analyze their financial situation in order to create a
portfolio strategy. Yes Wealth Management will then construct a portfolio consisting primarily of exchange-traded
funds (“ETFs”) and low-cost, diversified mutual funds to achieve the Client’s investment goals. The Advisor may
also utilize individual stocks, individual bonds, and other types of investments, as appropriate, to meet the needs
of certain Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax
considerations.
Yes Wealth Management’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. Yes Wealth Management will construct, implement and monitor the portfolio to ensure it meets
the goals, objectives, circumstances, and risk tolerance agreed to by the Client. 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.
Yes Wealth Management evaluates and selects investments for inclusion in Client portfolios only after applying
its internal due diligence process. Yes Wealth Management may recommend, on occasion, redistributing
investment allocations to diversify the portfolio. Yes Wealth Management 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. Yes Wealth Management 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, changes 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 Yes Wealth Management 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 their designated
account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage
Practices.
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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 the 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.
Financial Planning Services – In certain instances, Yes Wealth Management will provide a variety of financial
planning and consulting services to Clients as a component of investment management services. Services are
offered in several areas of a Client’s financial situation, depending on their goals and objectives. This planning
may encompass one or more areas of need, including but not limited to investment planning, retirement planning,
personal savings, education savings, and other areas of a Client’s financial situation.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the
amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the
Advisor.
Retirement Plan Advisory Services
Yes Wealth Management provides retirement plan advisory services to various retirement plans (each a “Plan”)
and the sponsor of the Plan (the “Plan Sponsor”). A Plan Sponsor may engage Yes Wealth Management to serve
as a 3(38) Fiduciary (discretionary) to the Plan in support of the Plan Sponsor’s fiduciary role. As a 3(38) Fiduciary,
the Plan Sponsor shall authorize Yes Wealth Management to serve as a discretionary investment advisor to select
and implement the investment options for the Plan and Plan Participants. Retirement plan advisory services
generally include:
• Assist with the development and monitoring of an Investment Policy Statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan.
• Assist the Plan Sponsor with the selection and the broad range of investments for the Plan.
• 3(38) Discretionary Services. The Advisor will have the discretionary authority and will make the final
decision regarding the initial selection, retention, removal, and additions to the investments in the
Plan.
• Provide discretionary investment advice to the Plan and Plan Sponsor with respect to the Plan’s
qualified default investment alternative (“QDIA”) for Plan Participants who are automatically enrolled
in the Plan or have failed to make investment elections. The Plan Sponsor retains the sole
responsibility to provide notices to the Plan Participants as required under ERISA 404(c).
In addition, Yes Wealth Management may provide the following non-fiduciary services:
• Assist with Plan Participant education regarding general investment topics and investment options in
the Plan.
• Assist in group enrollment meetings designed to increase retirement plan participation among
employees.
• Assist in the monitoring of investment options by preparing periodic investment reports regarding
investment performance, consistency of fund management, and conformance to guidelines set forth
in the IPS. Make recommendations to maintain, remove or replace investment options.
• Meet with the Plan Sponsor on a periodic basis to discuss reports and investment recommendations
for the Plan.
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The Advisor is not obligated to advise the Plan, Plan Sponsor, or Plan Participant on other types of
investments. The Advisor may be engaged under a separate agreement to provide additional services.
C. Client Account Management
Prior to engaging Yes Wealth Management to provide investment advisory services, each Client is required to
enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities
of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Yes Wealth Management, in connection with the Client, will develop
a strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – Yes Wealth Management 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 – Yes Wealth Management will develop a portfolio for the Client that is intended to
meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Yes Wealth Management will provide investment
management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Yes Wealth Management does not manage or place Client assets into a wrap fee program. Investment advisory
services are provided directly by Yes Wealth Management.
E. Assets Under Management
As of June 30, 2023, Yes Wealth Management manages $105,759,296 in Client assets, all of which are managed
on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.