A. Firm Information
Salus Financial Advisors, LLC (“SFA” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”). SFA was organized as a Limited Liability Company (“LLC”) under the laws of
the State of Colorado in December 2023. SFA is owned and operated b
y Richard Schultenover (Managing Member
and Chief Compliance Officer) and Jesse Karich (Managing Member). This Disclosure Brochure provides
information regarding the qualifications, business practices, and the advisory services provided by SFA.
B. Advisory Services Offered
SFA offers investment advisory services to individuals, high net worth individuals, families, trusts, estates,
charitable organizations, 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 towards each Client and seeks to mitigate potential
conflicts of interest. SFA’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.
Wealth Management Services
SFA provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management, financial planning
and related advisory services. SFA works closely with each Client on an ongoing basis. SFA works closely with
each Client to identify their investment goals, objectives, risk tolerance and financial situation in order to design
and implement an investment strategy. SFA will construct investment portfolios through the Advisor’s internal
investment management and/or the use of unaffiliated investment managers or investment platforms.
Investment Management Services – SFA will construct a portfolio consisting primarily of exchange-traded funds
(“ETFs”), individual equity securities, and fixed income securities. The Advisor may also utilize options, alternative
investments, and other types of investments, as appropriate, to meet the needs of each Client. Evaluation of legacy
investments will include a review of portfolio fit, tax situation and other considerations.
The Advisor’s investment strategies are 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.
SFA 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.
SFA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. SFA may recommend, on occasion, redistributing investment allocations to diversify the portfolio. SFA
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.
SFA 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 SFA 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 Client investment 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,
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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.
Use of Independent Managers – SFA in certain situations will recommend that a Client utilize one or more
unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion
of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an
advisory agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s]
will provide investment management and related services. The
Advisor may also assist in the development of the
initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and
ongoing oversight and due diligence over the selected Independent Managers to ensure the Independent
Manager’s strategies and target allocations remain aligned with the Client’s investment objectives and overall best
interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment
platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the
appropriate disclosures).
Financial Planning Services - Financial planning services are offered as part of its overall wealth management
services. Financial planning services may also be offered as a stand-alone service pursuant to a financial planning
agreement. Financial planning services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or
rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, insurance analysis, estate planning and other areas of a Client’s
financial situation.
Financial planning and consulting 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. Implementation of financial planning recommendations
is entirely at the Client’s discretion. 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, its Advisory Persons or its
affiliated entities. SFA will work with Clients to implement recommendations and referrals to other professionals
may be made where appropriate to meet the Client’s needs. Clients are under no obligation to implement SFA’s
recommendations through the Advisor.
Retirement Plan Advisory Services
SFA provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company
(the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in
meeting its fiduciary obligations to the Plan and its Plan Participants. Due to the differences in size, complexity and
overall needs of the Plan, each engagement is customized based on the requirements set forth by the Plan
Sponsor. The Advisor’s services may include:
• Analysis of Retirement Platforms and Vendors
• Investment Policy Statement (“IPS”) Monitoring
• Plan Participant Education
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
These services are provided by SFA serving in the capacity as a fiduciary under the Employee Retirement Income
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Security Act of 1974, as amended (“ERISA”) pursuant to ERISA Rule 3(21). In accordance with ERISA Section
408(b)(2), the Plan Sponsor is provided with a written description of SFA’s fiduciary status, the specific services to
be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Participant Account Management
As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third-party
platform, Pontera Solutions, Inc., to facilitate management of held away assets such as defined contribution plan
participant accounts, with investment discretion. The platform enables the Advisor to gain access to Client account
without having access through the Client’s credentials. This independent advisor access ensures that the Advisor
will not have custody of Client funds or securities when implementing trades for the Client. The Advisor is not
affiliated with the platform in any way and receives no compensation from the platform. A link will be provided to
the Client allowing them to connect their account[s] to the platform for the Advisor’s secure access.
C. Client Account Management
Prior to engaging SFA 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 – SFA, in connection with the Client, will develop an investment
strategy that seeks to achieve the Client’s goals and destinations.
• Portfolio Construction – SFA will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
• Investment Management and Supervision – SFA will provide investment management and ongoing
oversight of the Client’s investment portfolio. SFA will review Client portfolios at least annually.
• Financial Planning – SFA provides initial and ongoing planning services to assist Clients in meeting the
financial goals.
D. Wrap Fee Programs
SFA does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by SFA.
E. Assets Under Management
SFA is a newly established advisor. Assets under management shall be reported with the Advisor’s next filing of
this Disclosure Brochure. Clients may request more current information at any time by contacting the Advisor.