Wealth Enhancement Advisory Services, LLC (also referred to as “WEAS,” the “firm,” “we” or “our” throughout this
document), is an investment adviser registered with the U.S. Securities and Exchange Commission and has been
operating as an investment adviser since December 21, 2001.
WEAS is a Minnesota limited liability company and wholly owned subsidiary of Wealth Enhancement Group, LLC
(“WEG”). As of October 2021, private investment vehicles affiliated with TA Associates Management, L.P. (“TA
Associates”) and Onex Partners each indirectly hold a controlling interest in WEG. Further information about TA
Associates and Onex Partners Manager LP (each of which is also a registered investment adviser) is set forth in
their respective Forms ADV filed with the U.S. Securities and Exchange Commission, available at
www.adviserinfo.sec.gov.
We offer personalized investment advisory services including financial planning and consulting, asset management,
referrals to separate managed account investment managers, and seminars.
General Description of Primary Advisory Services
The following are brief descriptions of our primary services. A detailed description of our services is provided in Item
5 – Fees and Compensation so that clients and prospective clients can review the services and description of fees
in a side-by-side manner.
Financial Planning
WEAS offers advisory services in the form of financial planning services. Financial planning services do not involve
the active management of client accounts, but instead focus on a client’s overall financial situation. Financial
planning can be described as helping
individuals determine and set their
long-term financial goals, through
investments, tax planning, asset allocation, risk management (i.e., insurance),
retirement planning, and
other areas.
The
role of a financial planner and/or the WEAS financial advisor is to find ways to help the client understand their
overall financial situation and help the
client set and work toward their financial
objectives.
Asset Management
WEAS offers advisory services in the form of asset management services. Asset management services involve
providing clients with ongoing monitoring of client accounts. This means we will make trades in client accounts when
necessary. WEAS generally manages client investments on a discretionary basis although the firm may provide
non-discretionary investment management on a case- by-case basis.
Use of Separate Managed Account Investment Managers
WEAS offers advisory services by referring clients to outside, or unaffiliated, investment managers that are
registered or exempt from registration as investment advisers. Separately managed account investment managers
are responsible for continually monitoring client accounts and making trades in client accounts when necessary.
NorthCrest Asset Management, LLC, an affiliate of WEAS, provides investment advisory services to WEAS through
the creation and management of investment strategies. Detailed information about NorthCrest Asset Management,
LLC can be found in Item 10 - Other Financial Industry Activities and Affiliations.
Investment Management Services
WEAS provides investment management services that focus on long-term and short-term strategies which include
quantitative, momentum, and fundamental analysis. Portfolios and the allocation of assets within are constructed
using various types of securities such as mutual funds, exchange-traded funds, equity and fixed income, options,
and other general securities. WEAS also provides investment advice on both publicly traded as well as privately
listed securities and investments.
Portfolio Rebalancing
The WEAS Investment Management Department manages and periodically rebalances the portfolios. Clients may
change the portfolio type if their financial or life circumstances change. WEAS requests that clients provide such
notification to their WEAS financial advisor following any such changes. WEAS retains the discretionary authority
to buy, hold, and sell investments in the client’s portfolio, which may include modifying portfolio allocations, and
rebalancing client accounts back to their original client-authorized allocation. Rebalancing may also occur when a
WEAS financial advisor and/or the client gives instructions to WEAS Investment Management Department to
change the client’s target allocations or when a client makes additions to or withdrawals from their account(s).
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Arrangement with LPL Financial and Recommendation of LPL Financial Programs
WEAS financial advisors may also be Registered Representatives of LPL Financial, LLC, which is both a broker-
dealer and investment adviser registered with the U.S. Securities and Exchange Commission. We refer to these
advisors as ‘hybrid’ advisors.
WEAS has an agreement with LPL Financial that enables WEAS hybrid financial advisors to offer LPL Financial
advisory Platform to WEAS clients. All accounts and advisory services described in this brochure are through
WEAS.
Advisory Services Tailored to Individual Needs of Clients
WEAS provides services based on the individual needs of the individual client. Therefore, you are given the ability
to impose restrictions on your accounts, including specific investment selections and sectors.
Wrap-Fee Program Versus Portfolio Management Program
WEAS provides asset management services through a wrap-fee program in addition to the traditional management
programs it offers. Under a wrap-fee program, advisory services and transaction services are provided for one fee.
This is different from traditional management programs whereby advisory services from WEAS are provided for a
fee, but transaction services are billed separately on a per-transaction basis. From a management perspective,
there is not a fundamental difference in the way WEAS would manage wrap-fee accounts versus traditional
management accounts. The only significant difference is the way in which transaction and advisory services are
paid.
Management of Held-Away Assets
WEAS uses a third-party platform, Pontera, to facilitate management of held away assets, such as 401(k) plan
participant accounts, with discretion. Pontera provides WEAS financial advisors with their own log-in credentials,
pursuant to request and authorization by WEAS client(s), of which WEAS client’s, through their own log-in
credentials, will connect their held-away account(s) to the Pontera platform. WEAS financial advisors are provided
view and trading access, to provide advice and manage the assets. WEAS financial advisors do not have the
authority to withdraw assets or make changes to WEAS’ client’s profile, like address changes.
Wealth Enhancement Advisory Services, LLC (WEAS) Programs
WEAS Select Program
The WEAS Select Program provides investors an actively managed account using index mutual fund strategies,
exchange-traded funds (ETFs), and active mutual fund managers. The account is a transaction fee- based account
for individual stock or bond securities, mutual funds and ETFs held at the custodian.
WEAS primarily utilizes mutual funds that are part of the custodian’s No-Transaction Fee (NTF) platform. This
platform allows WEAS to buy mutual funds without transaction fees being charged to the account. The client may
still pay fees associated with mutual fund family fees that are described in their prospectus and the custodian’s fee
disclosure.
WEAS Select accounts are managed on a discretionary basis by the WEAS Investment Management Department,
which develops the portfolio allocation, selects the underlying investments, implements the respective model
strategy, and rebalances when deemed necessary.
The WEAS Investment Management Department decisions are overseen by the firm’s Investment Committee. The
Investment Committee’s decisions will be driven by the WEAS Investment Management Department’s market
research and due diligence. The WEAS Investment Management Department continually monitors the investments
in all Select Model Portfolios.
WEAS uses a combination of qualitative and quantitative factors in the management of the Select Model Portfolios.
WEAS will allocate to asset classes and managers based on its evaluation of macroeconomic trends and market
dynamics.
The Select strategies available in the program have defined allocations to equities, bonds, and alternatives. The appropriate
strategy is selected by you and your WEAS financial advisor based on, but not limited to, your investment goals, risk
tolerance and tax status.
Wealth Enhancement Advisory Services, LLC 8
WEAS Managed ETF Program (MEP)
The Managed ETF Program (MEP) provides discretionary investment advisory services to clients wanting to own
exchange-traded funds (ETFs). You will work with your WEAS financial advisor to select portfolio strategies
consisting of exchange-traded funds that meet your financial needs or goals.
MEP accounts are managed on a discretionary basis by the WEAS Investment Management Department, which
develops the portfolio allocation, selects the underlying funds, implements the respective model strategy, and
rebalances when necessary.
Clients should know that ETFs have unique distinguishing characteristics and cost structures. There are passive
indexes, active strategies, and equity and bond ETFs. The underlying management fees for International ETFs
generally have higher expenses than domestic ETFs. Passive equity index ETFs have traditionally had expenses in
the range of 0.03% to 0.35% versus 0.40% to 1.20% for actively managed ETFs.
MEP is most appropriate for those clients that are willing to achieve market-like returns, less management fees and
operating expenses, with little potential for the individual ETFs outperforming their respective indices they track.
Please refer to the WEAS Advisory Fee Schedule contained in the Investment Management Services section to
read about the WEAS advisory fees charged through MEP. WEAS implements the same fee range and billing
structure for MEP as in the Select Program. In addition, clients are assessed a transaction fee by the custodian to
cover the costs associated with the execution of trades in MEP. All transaction fees are paid to the custodian and
are collected directly from the client’s account. The WEAS advisory fees are for investment management advisory
services and may be more expensive for the client than if the assets were held in a traditional brokerage account
where a client is charged a commission for each transaction yet does not receive ongoing advice. A brokerage
account should be considered if the client has a buy and hold strategy or does not want ongoing investment
management advice.
All accounts through MEP must be opened at Charles Schwab, Fidelity, or Raymond James & Associates, LPL
Financial, and Pershing. Please refer to Item 12 of this brochure for information about our arrangements with Charles
Schwab, Fidelity, and Raymond James Associates, LPL Financial, and Pershing.
The MEP account may cost the client more or less than purchasing the program services separately because of
type and size of account, historical and/or expected size or number of trades, number, and range of supplementary
advisory and client related services.
WEAS may aggregate transactions for a client with other clients to improve the quality of the execution. When
transactions are aggregated the actual prices will be averaged. The purchase or sell of a client’s share of the
securities is at the average price. For client orders that are only partially filled, WEAS works with the custodian firm
to determine an appropriate breakdown. Securities transactions for MEP accounts are affected without
commissions being paid to WEAS. While the custodian makes every effort to obtain the best execution possible,
there is no assurance that it will be obtained.
WEAS Access Program
The WEAS Access Program provides the investor with access to actively managed strategies that will use a broad
array of investment types consisting of, but not limited to, actively managed mutual funds, index mutual funds,
exchange-traded funds (ETFs), exchange-listed securities, interval funds, securities traded over the counter,
municipal securities, and separately managed accounts (SMAs).
The WEAS Access Program accounts may be charged an Asset-Based Fee (ABF), which is a percentage charge
on the dollar amount of assets in the account in lieu of individual transaction fees on trades executed in the
account. The ABF is in addition to the advisory fee charged by the WEAS financial advisor. The asset-based fees
applicable to your account are negotiated based on the total amount of assets collectively maintained with the
custodian of the assets. The ABF is calculated and paid to the custodian directly each month and is used to cover
the transaction expenses to implement and trade the individual investment positions in the account.
Clients can choose to pay individual transaction fees in lieu of the asset-based fee. Based on historic and
anticipated level of trading volumes, clients with larger account values would most likely have lower overall
transaction costs by choosing to pay the individual transaction fees from their account instead of an asset-based
fee. You can discuss your specific situation and preference with your WEAS financial advisor.
Wealth Enhancement Advisory Services, LLC 9
Asset Location
Certain accounts are eligible for
an asset location service. Under an asset location service, all of the client’s
accounts will be managed together under a single investment objective, reflected in the client’s investment policy
statement. The objective of asset location is to maximize the tax benefits of different account types, such as
Individual Retirement Accounts (IRAs). Underlying investments are selected to make an allocation consistent with
the client’s investment objective. The investments will be placed in the accounts, depending upon the tax
characteristics of each investment and the tax benefits of each account type. If the client is participating in the
service, it is important to consider the total allocation and performance of all accounts in the program.
WEAS Managed Variable Annuities (MVA)
WEAS Investment Management Services may include the management of Variable Annuity (VA) sub- accounts.
WEAS has approved various VA carrier products for this service. WEAS manages various model portfolios for each
VA carrier product. Model portfolio objectives may range from aggressive to conservative. Once the client has
completed a Services Agreement, the various model portfolios are actively managed for the client on a discretionary
basis. Sub-account asset allocations are limited by the VA carrier product fund options. Asset allocations may also
be restricted by the VA carrier. WEAS hybrid financial advisors may receive commissions and/or 12b-1 fees related
to the VA contracts.
Fee-Based Insurance
WEAS has partnered with DPL Financial Partners, LLC (“DPL”), a third-party provider of insurance consultancy
services to SEC-registered investment advisers to help clients who have a need for insurance products, based on
their financial situation. WEAS pays a fixed annual fee to DPL for membership to DPL’s insurance platform.
Through DPL’s licensed insurance agents, who are also registered representatives of The Leaders Group, Inc.,
and Johnstone Brokerage Services unaffiliated SEC-registered broker-dealers and FINRA members, DPL offers
WEAS a variety of services related to fee-based insurance products. DPL’s services include, among other things:
(i) providing WEAS with analyses of its current methodology for evaluating client insurance needs; (ii) educating
and acting as a resource to WEAS regarding insurance products generally, and specific insurance products owned
by WEAS clients or that clients are considering purchasing; and (iii) providing WEAS access to and product
marketing support regarding fee-based products that insurers have agreed to offer to WEAS’ clients through DPL’s
platform.
For providing services to WEAS and other advisers, DPL is compensated by the insurance carriers for their service
as a distributor, on behalf of the insurance carriers. The cash value of any insurance product placed with a client
under this arrangement shall be included in WEAS’ assets under management for the purposes of calculating
WEAS’ management fees. As such, WEAS’ recommendation that a client utilize DPL for insurance services
presents a conflict of interest if WEAS will earn a new (or increase its current) advisory fee, as WEAS’
recommendation to use DPL could be made on the basis of compensation to be received, rather than on a client’s
need.
SWM / SWM II Program
WEAS may provide advisory services through the SWM and SWM II programs through LPL Financial (LPL), a
registered investment adviser and broker-dealer. The SWM and SWM II programs allow WEAS to customize and
manage portfolios and to address the client’s unique financial needs. These programs allow WEAS to choose
investment products from over 8,000 funds from more than 470 fund families; individual stocks/bonds; options; unit
investment (UITs); alternative investments; fee-based variable annuities with 138 subaccounts.
Through the SWM account, the client will bear transaction charges for purchases, sales, and exchanges in their
account, including for mutual funds, equities, fixed income securities and options. (For SWM II accounts, the
transaction costs are borne by WEAS and are transaction based or asset based. Clients should discuss the
differences between SWM and SWM II accounts with WEAS advisor.) Clients authorize LPL to deduct from their
account the transaction charges and other fees applicable to the account. The transaction charges are paid to LPL
to defray costs associated with trade execution; however, they are not directly related to transaction-related
expenses of LPL and are a source of revenue to LPL. The transaction charges vary depending on the type of
security being purchased or sold (e.g., currently $7 for equities, $0 to $9 for ETF’s, $35 for unit investment trusts).
In the case of mutual funds, the transaction charges vary depending on whether LPL retains compensation from
the mutual fund for services it provides to the fund, such as recordkeeping fees and asset-based service fees or
sales charges.
LPL uses that compensation from mutual funds to reduce its trading costs, and therefore, assesses a lower transaction
charge to clients. Mutual fund transaction charges are currently either $0 or $26.50. LPL does not charge a transaction
charge for fixed income securities (e.g., bonds or structured products); however, LPL acts as principal on fixed income
Wealth Enhancement Advisory Services, LLC 10
security transactions and receives a mark up/down on the transaction.
The standard transaction charges applicable to a SWM account will be notified to the client in connection with their
account opening. These charges are subject to change at the discretion of LPL. Client will be notified of any
changes, including through information provided with periodic statements.
Client understands that LPL and WEAS may agree to transaction charges for all or certain clients of WEAS or
certain associated person of WEAS that are different (and may be less) than the standard transaction charges
based on the nature and scope of the WEAS business or current and expected future business a particular
associated person of WEAS does with LPL. Therefore, the transaction charges for a client account may be more or
less than those applicable to other clients of WEAS or clients of other Advisors. LPL may change the amount of the
transaction charges if the nature or scope of WEAS business changes or does not reach certain levels. In this case,
the transaction charges the client pays would revert to LPL’s standard transaction charges.
Although clients do not pay a transaction charge for transactions in a SWM II account, clients should be aware that
WEAS pays LPL transaction charges for those transactions. The transaction charges paid by WEAS vary based on
the type of transaction (e.g., mutual fund, equity, or ETF) and for mutual funds based on whether or not the mutual
fund pays 12b-1 fees and/or recordkeeping fees to LPL. Transaction charges paid by WEAS for equities and ETFs
are $9. For mutual funds, the transaction charges range from $0 to $26.50. Because WEAS pays the transaction
charges in SWM II accounts, there is a conflict of interest in cases where the mutual fund is offered at both $0 and
$26.50. Clients should understand that the cost to WEAS of transaction charges may be a factor that WEAS
considers when deciding which securities to select and how frequently to place transactions in a SWM II account.
In many instances, LPL makes available mutual funds in a SWM II account that offer various classes of shares,
including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for
example, as “Class I,” ‘institutional,” “retail,” “service,” “administrative” or “platform” share classes (“Platform
Shares”). The Platform Share class offered for a particular mutual fund in SWM II in many cases will not be the
least expensive share class that the mutual fund makes available and was selected by LPL in certain cases
because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to
the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a
lower overall cost to the investor than is available through SWM II. In other instances, a mutual fund may offer only
Class A shares, but another similar mutual fund may be available that offers Platform Shares. Class A Shares
typically pay LPL a 12b-1 fee for providing brokerage related services to the mutual funds. Platform Shares are
generally not subject to 12b-1 fees. As a result of the different expenses of the mutual fund shares classes, it is
generally more expensive for a client to own Class A Shares than Platform Shares. An investor in Platform Shares
will pay lower fees over time and keep more of his or her own investment returns than an investor who holds Class
A Shares of the same fund.
WEAS has a financial incentive to recommend Class A Shares in cases where both Class A and Platform Shares
are available. Although the client will not be charged a transaction charge for transactions, Advisor pays LPL a per
transaction charge for mutual fund purchases and sales in the account. WEAS generally does not pay transaction
charges for Class A Share mutual fund transaction accounts, but generally pay transaction charges for Platform
Share mutual fund transactions. The cost to WEAS of transaction charges generally may be a factor Advisors
consider when deciding which securities to select and whether to place transactions in the account.
The lack of transaction charges to WEAS for Class A Share purchases and sales, together with the fact that
Platform Shares generally are less expensive for a client to own and presents a significant conflict of interest
between WEAS and the client. Clients should understand this conflict and consider the additional indirect expenses
borne as a result of the mutual fund fees when negotiating and discussing with your Advisor the advisory fee for
management of an account.
Retirement Plan Consulting Services
WEAS offers investment advisory and consulting services to employer-sponsored retirement plans. Financial advisors
may offer investment advisory and consulting services through WEAS Retirement Plan Consulting Program (RPC) or
through LPL Financial advisory Retirement Plan Consulting Program (RPCP) for ERISA and Non-ERISA covered
plans.
WEAS services include various comprehensive consulting support which includes establishing and maintaining an
ongoing, documented process for ensuring a prudent oversight and due diligence plan review. At the request of
ERISA plan sponsors, WEAS provides non-discretionary investment advisory services to plans where we make
investment recommendations as a co-fiduciary under Section 3(21) of the Employee Retirement Income Security
Wealth Enhancement Advisory Services, LLC 11
Act (“ERISA”). We also provide discretionary investment management services as an ERISA 3(38) investment
manager wherein we make investment decisions on behalf of the plan sponsor.
WEAS and the WEAS financial advisor may provide the following services to Retirement Plan clients:
• Preparation of Investment Policy Statement: WEAS assists clients in preparing an initial draft
investment policy statement (“IPS”), including investment objectives, policies, and constraints consistent
with the plan’s requirements and provide a review, from time to time as required and/or as agreed upon,
of the IPS. The client will be responsible for reviewing and adopting the IPS and updating the IPS to
reflect changes in the plan and its investments from time to time.
• Investment Selection: WEAS conducts investment manager / mutual fund searches and recommends
investments consistent with the requirements of the plan’s IPS. This will include the identification of
investment products or model portfolios in connection with the definition of a QDIA under ERISA (for
plans subject to ERISA).
• Performance Monitoring and Reporting: WEAS prepares and provides the client (at intervals mutually
agreed upon by the client) with reports, monitoring plan investment managers and investments
comparing the performance to benchmarks set forth in the IPS. WEAS will recommend appropriate
action, when necessary, that may include replacing an investment or investment manager.
• Fiduciary Education Services: WEAS may provide training for clients, including their plan committee
members, relating to the investment duties of fiduciaries.
• Participant Education Services: If the plan is participant-directed, WEAS may provide investment
education and information to participants as agreed from time to time, including in-person sessions and
various educational materials.
• Model Portfolio Services: WEAS will recommend, for consideration and approval by client, asset
allocation target-date or risk-based model portfolios for the plan to make available to plan participants and
which funds from the lineup of investment options chosen by the client to include in such model portfolios.
• Other Services: WEAS may provide additional consulting services including, but not limited to, plan
design, needs assessments, plan service provider support, product sponsor and/or record keeper
evaluations, compilation of and coordinating data for plan testing, and review of periodic reports prepared
by the plan’s record keeper.
• Service Provider Search Support: WEAS will assist the client with the preparation of requests for
proposals, evaluation of proposals and bids, and interviews of investment providers offering plan
recordkeeping and investment services and other plan service providers, as requested by the client.
• Employee Advice Solution: Where sponsors elect to offer plan participants the option of using our
Employee Advice Solution for discretionary investment management services, WEAS will enter into a
separate agreement with the participant, describing our services and fees for that service. WEAS will also
ask that the participants provide information that will help WEAS understand their investment objectives.
In providing this service, WEAS and the WEAS financial advisor are deemed to be a fiduciary and an
Investment Manager as defined in ERISA Section 3(38).
Assets Under Management
Defined as regulatory assets by the SEC, the amount of assets under management by WEAS totaled$72.03 billion as of
December 31, 2023; $68.87 billion are managed on a discretionary basis and $3.16 billion are managed on a non-
discretionary basis.