Promethium Advisors, LLC (“Promethium,” the “Firm,” “we,” “our,” or “us”) is a privately owned limited liability
company headquartered in Bethesda, MD.
Promethium is registered as an investment adviser with the U.S. Securities and Exchange Commission. The Firm
was formed in 2023 and is owned by Christopher F. Poch.
The Promethium Advisors, LLC Wrap Program (the “Program”) is an investment advisory program sponsored by
the Firm. Before the Firm renders any of the foregoing advisory services, clients are required to enter into one or
more written agreements with the Firm setting forth the relevant terms and conditions of the advisory relationship
(the “Advisory Agreement”).
As a registered investment adviser, the Firm is a fiduciary to the firm’s investment advisory clients and has an
obligation to act in good faith, and in the best interest of the client and to place the client's interests first and
foremost. This would include a duty of care, which requires among other things for advisers to ensure that their
investment advice is suitable based on the client’s investment profile or mandate. As part of a duty of loyalty to
clients’ advisers must also attempt to eliminate or make full and fair disclosure of all material facts of any conflicts
of interest so a client, or prospective client, can make an informed decision in each particular circumstance. The
structure of the Program and other internal controls described in this brochure are designed to support the Firm’s
ongoing efforts to fulfill its fiduciary duties. This includes actions to either avoid or mitigate material conflicts of
interest that may exist between the Firm and its clients and to provide clients with the required disclosure of these
conflicts of interest. Clients and prospective clients should carefully consider the information outlined in this
Brochure in evaluating the Program. The Firm’s Financial Advisors (each, a “Financial Advisor,” and collectively,
“Financial Advisors”) serve as the primary point of contact for Program clients. Clients are encouraged to carefully
read this Brochure in its entirety and contact their Financial Advisor with any questions.
While this brochure generally describes the business of the Firm, certain sections also discuss the activities of its
Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar
status or performing similar functions), employees, or any other person who provides investment advice on the
Firm’s behalf and is subject to the Firm’s supervision or control.
The information included in this Brochure is current as of the date of this Brochure and is subject to change at the
Firm’s discretion. Please retain this Brochure for your records.
Assets Under Management
As of May 15, 2024, Promethium Advisors, LLC managed approximately $281,941,841 in total assets, all of which
are managed on a discretionary basis, all of which are Wrap accounts.
Advisory Services Offered
The Firm offers discretionary and non-discretionary investment management, investment advisory services, and
financial planning. Prior to the Firm rendering any of the foregoing advisory services, clients are required to enter
into one or more written agreements with the Firm setting forth the relevant terms and conditions of the advisory
relationship (the “Advisory Agreement”).
Investment Management Services
The Firm offers continuous and regular investment supervisory services on a discretionary basis. We work with
clients and have the ongoing responsibility to select and/or make recommendations based upon the objectives of
the client, as to specific securities or other investments that he/she recommends or purchases/sells in clients’
accounts. We utilize a variety of investment types when making investment recommendations/purchases in client
accounts which include, but are not limited to equity securities, fixed-income securities, alternatives, and mutual
funds. The investments recommended/purchased are based on the client’s individual needs, goals, and objectives.
The Firm offers investment advice on any investment held by the client at the start of the advisory relationship.
Financial Planning may be provided to clients as a part of the Investment Management Services. When being
provided as a separate service it is described in this section under Financial Consulting Services below.
Clients are advised to promptly notify the Firm if there are changes in their financial situation or if they wish to
place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or
mandates on the management if the Firm determines, in its sole discretion, that the conditions will not materially
impact the performance of a management strategy or prove overly burdensome to the Firm’s management
efforts.
As stated, investment management is provided on a discretionary basis, in which a client appoints and authorizes
the Firm or a third party to make investment decisions with respect to the assets in the client’s account (including
authority to buy, sell, or hold securities).
Financial Planning Services
Our Financial Planning Services Service offers clients the ability to have their investment portfolio allocated among
different financial institutions and reviewed by an Investment Adviser Representative for a negotiated fee. This
consultation offers the client a detailed look at their financial condition in relation to their investment objectives,
risk tolerance, time horizon, and any financial goals that they may be seeking to achieve. This Financial
Consultation Service offered by us may or may not be in conjunction with one of our other fee-based programs.
The Firm provides a variety of financial consulting services to individuals, families, and other clients regarding the
management of their financial resources based upon an analysis of client’s current situation, goals, and objectives.
Consulting encompasses one or more of the following areas: Investment Planning, Retirement Planning, Estate
Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Business and Personal Financial Planning.
In performing these services, the Firm is not required to verify any information received from the client or the
client’s other professionals (e.g. attorneys, accounts, etc.) and is expressly authorized to rely on such information.
The Firm may recommend clients engage the Firm for additional related services, its Supervised Persons in their
individual capacities as insurance agents or register representatives of a broker-dealer and/or other professionals
to implement its recommendations. Clients are advised that a conflict of interest exists if the client engages the
Firm or its affiliates to provide additional services for compensation. Clients retain
absolute discretion over all
decisions regarding implementation and are under no obligation to act upon any of the recommendations made
by the Firm under a financial planning or consulting engagement. Clients are advised that it remains their
responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for
the purpose of reviewing, evaluating, or ACn
clients receive investment advisory services (which may include portfolio management or advice concerning
the selection of other investment advisers) and the execution of client transactions for a specified fee or fees not
based upon transactions in their accounts where the total costs will generally increase or decrease as a result of
the frequency of transactions in the account and the type of securities purchased.
At the onset of the Program, clients complete an investor profile describing their individual investment
objectives, liquidity and cash flow needs, time horizon, and risk tolerance, as well as any other factors
pertinent to their specific financial situations. After an analysis of the relevant information, the Firm assists its
clients in developing an appropriate strategy for managing their assets.
Fees for Participating in the Wrap Fee Program
The Program is offered on an asset-based fee basis, meaning participants pay a single annualized fee based upon
assets under management (“Program Fee”) established as a percentage of the market value of assets in the
account as of a particular date rather than on the transactions in the account as in a commission account where
total costs will generally increase or decrease as a result of the frequency of transactions in the account and they
type of securities purchased.
The Wrap Fee covers advisory services related to the program, portfolio management services provided by third
parties, the execution of transactions, custody services, account servicing, reporting, and other services. The
specific fee a client will pay is outlined in their Client Agreement.
In establishing the fee applicable to a client’s account, the Advisor will take into consideration the value of the
assets, the types of assets, being deposited in the account participating in the relevant Program, other assets the
client or the client’s household may have invested with the Firm, and the nature of the client relationship. In
general, not all clients with the same amount of assets will be charged the same fee in the same Program.
This management fee generally ranges up to 1%, depending on the size and composition of a client’s portfolio and
the type of services rendered. The annual fee is prorated and charged monthly, in advance, based upon the market
value of the assets being managed by the Firm on the last day of the previous billing period.
If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable
with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial period of an
engagement, the fee is calculated on a pro-rata basis. In the event the advisory agreement is terminated, the fee
for the final billing period is prorated through the effective date of the termination and the outstanding or
unearned portion of the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-
away assets, accommodation accounts, alternative investments, etc.), the Firm may negotiate a fee rate that
differs from the range set forth above.
Additional Fee Information
As referenced above, a portion of the fees paid to the Firm is used to cover the securities brokerage
commissions and transactional costs attributed to the management of its client’s portfolios.
The Firm has no internal arrangements in place whereby persons recommending the Program are entitled to
receive additional compensation as a result of clients’ participation. A person recommending the Program will
not earn more compensation than he or she would otherwise receive if a client elected another investment
management program.
Services provided through the Program may cost clients more or less than purchasing these services
separately. The number of transactions made in clients’ accounts, as well as the commissions charged for each
transaction, determines the relative cost of the Program versus paying for execution on a per-transaction basis
and paying a separate fee for advisory services. Therefore, the Firm has an incentive to place fewer trades for
clients in the Program since the Firm incurs transaction expenses. Fees paid for the Program may also be higher
or lower than fees charged by other sponsors of comparable investment advisory programs.
The fees not included in the advisory fee for our wrap services are charges imposed directly by a mutual fund, index
fund, or exchange-traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and
other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees for trades executed at a
broker-dealer, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions.
Payments to Independent Managers
The Firm pays a portion of the total fee received from the client to the Independent Manager, if applicable, for
services provided to the client through the relevant Program. Although the amounts paid to third parties
participating in the Program may be changed from time to time without notice to clients, such changes will not
impact the amount of the fees paid by clients without prior notifie3(i)13(o)-5(n)14( )-66(od)3( )-66(th)12(e )-58iclien.r g of fs paid od
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Clients may make additions to and withdrawals from their account at any time, subject to the Firm’s right to
terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate
any transferred securities or declines to accept particular securities into a client’s account. Clients may withdraw
account assets on notice to the Firm, subject to the usual and customary securities settlement procedures.
However, the Firm generally designs its portfolios as long-term investments, and the withdrawal of assets may
impair the achievement of a client’s investment objectives. The Firm may consult with its clients about the options
and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they
may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g.,
contingent deferred sales charges) and/or tax ramifications.