A. Description of the Advisory Firm
Alteri Wealth LLC (“Alteri” or the “Firm”) is a limited liability company organized in the State of
Delaware. Alteri is an investment advisory firm registered with the United States Securities and Exchange
Commission (“SEC”). Alteri is owned by Michelle Gruber and Alex Markowitz.
B. Types of Advisory Services
Alteri provides discretionary and non-discretionary investment management services to affluent individuals
and families, including, business owners, athletes, physicians, entrepenuers, and entertainment industry
executives, as well as entities, including, but not limited to, family offices, trusts, estates, private
foundations, and qualified retirement plans. Financial planning services also are provided as part of the
delivery of investment management services. Depending upon individual client requirements, the financial
planning will include recommendations for retirement planning, educational planning, estate planning, tax
planning and insurance needs and analysis.
All investment advice provided is customized to each client’s investment objectives and financial needs.
The information provided by the client, together with any other information relating to the client’s overall
financial circumstances, will be used by Alteri to determine the appropriate portfolio asset allocation and
investment strategy for the client.
The securities utilized by Alteri for investment in client accounts mainly consist of individual equity
securities, municipal and corporate bonds, but we will also invest in, exchange traded funds (ETFs),
registered mutual funds, REITS, variable annuities, private funds/alternative investments, and closed-end
funds, if we determine such investments fit within a client’s objectives and are in the best interest of our
clients.
Alteri may further recommend to clients that all or a portion of their investment portfolio be managed on a
discretionary basis by one or more unaffiliated money managers or investment platforms (“External
Managers”). The client may be required to enter into a separate agreement with the External Manager(s),
which will set forth the terms and conditions of the client’s engagement of the External Manager. Alteri
generally renders services to the client relative to the discretionary selection of External Managers. Alteri
also assists in establishing the client’s investment objectives for the assets managed by External Managers,
monitors and reviews the account performance and defines any restrictions on the account. Unless otherwise
provided in the agreement with a client, the investment advisory fees charged by any designated External
Managers are paid by Alteri and, therefore, are not in addition to the the annual advisory fee charged by
Alteri.
Investment Management Services to Retirement Plans
Alteri offers discretionary and non-discretionary advisory services to qualified plans, including 401k plans.
These services include, depending upon the needs of the plan client, recommending, or for discretionary
clients selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s
investment options, assisting plan fiduciaries in creating and/or updating the plan’s written investment
policy statements, working with plan service providers, and providing general investment education to plan
participants.
Note for IRA and Retirement Plan Clients: When Alteri provides investment advice to you regarding
your retirement plan account or individual retirement account, Alteri is a fiduciary 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. The way Alteri makes money creates some conflicts with
your interests, so Alteri operates under a special rule that requires Alteri to act in your best interest and not
put Alteri’s interest ahead of yours.
C. Client-Tailored Advisory Services
Clients may impose reasonable restrictions on the management of their accounts if Alteri determines, in its
sole discretion, that the conditions would not materially impact the performance of a management strategy
or prove overly burdensome for Alteri’s management efforts.
D. Information Received From Clients
Alteri will not assume any responsibility for the accuracy or the information provided by clients. Alteri is
not obligated to verify any information received from a client or other professionals (e.g., attorney,
accountant) designated by a client, and Alteri is expressly authorized by the client to rely on such
information provided. Under all circumstances, clients are responsible for promptly notifying Alteri in
writing of any material changes to the client’s financial situation, investment objectives, time horizon, or
risk tolerance.
E. Assets Under Management
Alteri is a newly registered adviser. Therefore, as of the date of filing this Brochure, Alteri did not have
assets under management.
Item 5 - Fees and Compensation
Alteri charges fees based on a percentage of assets under management. The specific fees charged by Alteri
for services provided will be set forth in each client’s agreement.
A. Investment Management Services
Alteri charges an annual advisory fee that is agreed upon with each client and set forth in an agreement
executed by Alteri and the client. The advisory fee for the initial month shall be paid, on a pro rata basis,
in arrears, based on the value of the net billable assets under management at the end of such initial month.
For subsequent months, the advisory fee shall be paid, in advance, based on the asset value of the client’s
accounts as of the last business day of the preceding month as provided by third-party sources, such as
pricing services, custodians, fund administrators, and client-provided sources For purposes of fee
calculation, assets under management include cash and cash equivalents. The annual advisory fee ranges
from 0.25% to 1.5% (per annum). As provided above in Item 4, unless otherwise provided in the agreement
with a client, the investment advisory fees charged by any
designated External Managers are paid by Alteri
and, therefore, are not in addition to the the annual advisory fee charged by Alteri.
Notwithstanding the foregoing, Alteri and the client may choose to negotiate an annual advisory fee that
varies from the range set forth above. Factors upon which a different annual advisory fee may be based
include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and
complexity of the products and investments involved, time commitments, and travel requirements. The
advisory fee charged by the Firm will apply to all of the client’s assets under management, unless
specifically excluded in the client agreement. The advisory fee includes the financial planning services
described above. Although Alteri believes that its fees are competitive, clients should understand that lower
fees for comparable services may be available from other sources and firms.
The investment advisory agreement between Alteri and the client may be terminated at will by either Alteri
or the client upon written notice. Alteri does not impose termination fees when the client terminates the
investment advisory relationship, except when agreed upon in advance.
B. Payment of Fees
Alteri generally deducts its advisory fee from a client’s investment account(s) held at his/her custodian.
Upon engaging Alteri to manage such account(s), a client grants Alteri this limited authority through a
written instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy
of the calculation of the advisory fee; the custodian will not determine whether the fee is accurate or
properly calculated.
Although clients generally are required to have their investment advisory fees deducted from their accounts,
in some cases, Alteri will directly bill a client for investment advisory fees if it determines that such billing
arrangement is appropriate given the circumstances.
The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating
separate line items for all amounts disbursed from the client's account(s), including any fees paid directly
to Alteri.
Clients may make additions to and withdrawals from their account at any time, subject to Alteri’s right to
terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to
liquidate transferred securities or decline to accept particular securities into a client’s account. Clients may
withdraw account assets at any time on notice to Alteri, 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. Alteri 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.
C. Clients Responsible for Fees Charged by Financial Institutions and External Money
Managers
In connection with Alteri’s management of an account, a client will incur fees and/or expenses separate
from and in addition to Alteri’s advisory fee. These additional fees may include transaction charges and the
fees/expenses charged by any custodian, mutual fund, ETF, limited partnership, transfer taxes, odd lot
differentials, exchange fees, interest charges, ADR processing fees, and any charges, taxes or other fees
mandated by any federal, state or other applicable law, retirement plan account fees (where applicable),
margin interest, brokerage commissions, mark-ups or mark-downs and other transaction-related costs,
electronic fund and wire fees, and any other fees that reasonably may be borne by a brokerage account.
As referenced above, unless otherwise provided in the agreement with a client, the investment advisory fees
charged by any designated External Managers are paid by Alteri and, therefore, are not in addition to the
the annual advisory fee charged by Alteri. If provided for in the agreement with a client, the client will be
responsible for the fees and expenses charged by any External Manager, and the External Manager’s
platform manager, if any. For External Managers, clients should review each External Manager’s Form
ADV 2A disclosure brochure and any contract they sign with the External Manager (in a dual contract
relationship). The client is responsible for all such fees and expenses if provided in the client’s agreement
that Alteri is not paying the External Managers fees and expenses.
Please see Item 12 of this brochure regarding brokerage practices.
D. Prepayment of Fees
As noted in Item 5(B) above, Alteri’s advisory fees generally are paid in advance. Upon the termination of
a client’s advisory relationship, Alteri will issue a refund equal to any unearned management fee for the
remainder of the month. The client may specify how he/she would like such refund issued (i.e., a check
sent directly to the client or a check sent to the client’s custodian for deposit into his/her account).
E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients
Alteri does not buy or sell securities and does not receive any compensation for securities transactions in
any client account, other than the investment advisory fees noted above. However, as further described in
Item 10, certain personnel of Alteri, in their individual capacities, are registered representatives of Purshe
Kaplan Sterling Investments, Inc. (“PKS”). In this capacity these individuals will engage in various types
of securities or investment products transactions and will receive separate and typical compensation for
doing so. In addition, certain representatives of Alteri, in their individual capacities, may also be licensed
as insurance professionals. Such persons earn commission-based compensation for selling insurance
products to clients.