A. Description of the Advisory Firm
Digital Wealth Partners LLC (hereinafter “DW Partners”) is a Limited Liability Company
organized in the State of Wyoming. The firm was formed in August 2023, and the
principal owners are Eric Butler and Digital Ascension Group.
B. Types of Advisory Services
Portfolio Management Services
DW Partners offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. DW Partners creates an
Investment Policy Statement for each client, which outlines the client’s current situation
(income, tax levels, and risk tolerance levels). 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
DW Partners evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. DW Partners will require 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.
DW Partners seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of DW Partners’
economic, investment or other financial interests. To meet its fiduciary obligations, DW
Partners attempts to avoid, among other things, investment or trading practices that
systematically advantage or disadvantage certain client portfolios, and accordingly, DW
Partners’ 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 DW Partners’ policy to allocate investment opportunities and transactions
it identifies as being appropriate and prudent, including initial public offerings ("IPOs")
and other investment opportunities that might have a limited supply, among its clients
on a fair and equitable basis over time.
DW Partners proposed strategy to offer margin and collateralized loans to clients for the
purpose of diversifying their investment portfolios into various verticals. DW Partners is
dedicated to providing our clients with innovative financial solutions that align with their
long-term financial objectives. DW Partners offers our clients the opportunity to access
margin and collateralized loans secured by the assets they hold within their investment
portfolios. These loans will provide clients with additional liquidity, which they can then
use to diversify their investments into various verticals such as equities, fixed income,
alternative assets, and other approved investment options. This approach will enhance
our clients' investment strategies and potential returns, fostering portfolio growth and
risk mitigation.
DW Partners believe that offering margin and collateralized loans for portfolio
diversification aligns with our commitment to delivering innovative financial solutions
while maintaining the highest standards of transparency and risk management.
DW Partners has discretion to choose third-party investment advisers to manage all or a
portion of the client's assets. Before selecting other advisers for clients, DW Partners will
always ensure those other advisers are properly licensed or registered as an investment
adviser. DW Partners conducts due diligence on any third-party investment adviser,
which may involve one or more of the following: phone calls, meetings and review of the
third-party adviser's performance and investment strategy. DW Partners then makes
investments with a third-party investment adviser by investing with the third-party
adviser. These investments may be allocated either through the third-party adviser's fund
or through a separately managed account managed by such third party adviser on behalf
of DW Partners' client. DW Partners may also allocate among one or more private equity
funds or private equity fund advisers. DW Partners will review the ongoing performance
of the third-party adviser as a portion of the client's portfolio.
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
DW Partners generally limits its investment advice to mutual funds, fixed income
securities, insurance products including annuities, equities, hedge funds, private equity
funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation
protected/inflation linked bonds, venture capital funds, digit assets, and private
placements. DW Partners 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. We also have a fiduciary
duty under the Investment Advisers Act of 1940 with respect to all client 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
DW Partners offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels). Clients may impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs. However, if the restrictions prevent
DW Partners from properly servicing the client account, or if the restrictions would
require DW Partners to deviate from its standard suite of services, DW Partners reserves
the right to end the relationship.
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. DW Partners does not participate in
wrap fee programs.
E. Assets Under Management
DW Partners has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$0 $0 December 2023