A. Firm Information
Perigon Wealth Management, LLC (“Perigon” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the
laws of Delaware. Perigon was founded in March 2004 and is owned by Perigon Financial Holdings, LLC. Perigon
is operated by Arthur Ambarik (Chief Executive Officer and Partner), Charles Pinson-Rose (Chief Financial Officer
and Partner), Phil Hart (Founder and Partner), Jeremy Paul (President and Partner), Lindsay Sturmak (Partner),
and Jonathan Hoy (Chief Operations Officer), Courtney Holt (Chief Compliance Officer), and Rafia Hasan (Chief
Investment Officer). This Disclosure Brochure provides information regarding the qualifications, business
practices, and advisory services provided by Perigon.
Perigon offers services through the Advisor’s network of investment advisor representatives (“IARs”). IARs may
have their own legal business entities whose trade names and logos are used for marketing purposes and may
appear on marketing materials or client statements. The Client should understand that the businesses are legal
entities of the IARs and not of Perigon. The IARs are under the supervision of Perigon, and the advisory services
of the IARs are provided through Perigon. The Advisor has the arrangement described above for certain IARs
using the brand names Blue Water Capital Management, Burleson & Co., Cognizant Wealth Advisors, PM Wealth
Management, Prudeo Partners, Stakeholders Capital, and Wealth Advisors.
B. Advisory Services Offered
Perigon offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
charitable organizations, retirement plans, and banking or thrift institutions (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 toward each Client and seeks to mitigate potential
conflicts of interest. Perigon’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
Perigon provides Clients with wealth management services, which generally include a broad range of
comprehensive financial planning services in connection with discretionary and non-discretionary management of
investment portfolios, pursuant to a wealth advisory agreement. The investment management and financial
planning services are described below.
Internal Investment Management Services – Perigon offers investment management either as a component of
wealth management services or pursuant to a standalone investment management agreement. Perigon provides
customized investment advisory solutions for its Clients. This is achieved through continuous personal Client
contact and interaction while providing discretionary and non-discretionary investment management and related
advisory services. Perigon works closely with each Client to identify their investment goals and objectives, risk
tolerance, and financial situation to create a portfolio strategy.
Perigon will then construct an investment portfolio that utilizes independent investment managers, customized
investment management services, and/or one of its investment strategies (as described below) to achieve the
Client’s investment goals. Perigon may utilize mutual funds, exchange-traded funds (“ETFs”), individual stocks,
bonds, options contracts, alternative investments, including digital assets, and private collective investment
vehicles, as appropriate, to meet the needs of its Clients. The Advisor may retain certain types of investments
based on a Client’s legacy investments for portfolio fit and/or tax considerations.
Perigon’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. Perigon 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.
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Perigon evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Perigon may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Perigon may also recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a possible hedge against market movement. Perigon 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, changes in the risk tolerance of the Client, generating cash to meet Client needs, or
any risk deemed unacceptable for the Client’s risk tolerance.
Perigon selects, recommends, and/or retains mutual funds on a fund-by-fund basis and seeks to use non-retail or
institutional classes when possible. Due to specific custodial or mutual fund company constraints, material tax
considerations, and/or systematic investment plans, Perigon may select, recommend, and/or retain a mutual fund
share class that has a higher expense ratio than an equivalent share class. Perigon will seek to select the lowest
cost share class available that is in the best interest of each Client and will ensure the selection aligns with the
Client’s financial objectives and state investment guidelines.
Perigon uses a combination of core and non-core investment strategies. Each strategy is designed to meet a
particular investment goal. Perigon's core investment strategies typically represent the “core” of an investor’s
holdings.
Core Strategies:
1. Perigon Blue Chip – Seeks to invest in well-established, high-quality, large capitalization companies with
meaningful growth prospects that invest efficiently in their future growth prospects. The desired result is
a long-term balance of current growth and reinvestment in activities that give rise to a balanced increase
in long-term shareholder value. The strategy aims for returns consistent with the S&P 500.
2. Fixed Income – As dictated by Clients’ needs, fixed income portfolios range from taxable bonds to tax-
free bonds, and for smaller allocations, taxable ETFs. Across each of these strategies, Perigon’s principal
goal is to prudently obtain Client income objectives while preserving their capital invested against market
volatility and long-term inflation.
3. Dimensional Fund Advisors (“DFA”) – DFA is a third-party investment management company that
provides a passive, “multi-factor” strategy that combines insights of Modern Portfolio Theory and the
Efficient Markets Hypothesis with streamlined portfolio operations. The focus of DFA is on taking
"advantage of the ways markets are right – the ways they compensate investors." By incorporating the
dimensions of expected returns into an investment strategy, DFA offers a sound passive strategy with the
potential for outperformance but requires balancing the trade-offs among competing premiums. Perigon
is among the selected advisors with access to the DFA models and strategies.
4. Perigon Enhanced Equity – The enhanced equity strategy is designed to capture the meaningful upside
of a given asset class while tempering downside price volatility. This return profile is achieved by
combining underlying investments with exchange-traded options – considering implied volatility, interest
rates, recent performance, and many other factors to identify the preferred risk-adjusted structure to own
a given underlying investment.
Non-Core Strategy:
• Concentrated Position Management – Perigon offers customized concentrated stock position
management. Programs can be designed to meet individual Client needs, including volatility reduction,
monetizing out-of-the-money stock options, or implementing a structured sale program.
Each Client’s solution begins by analyzing the underlying securities, creating a “Price Probability Envelope”
defined by estimating the cost of protection vs. upside participation. Perigon manages these accounts on a
discretionary basis. Account supervision is guided by the Client’s stated objectives, as well as tax considerations.
Through personal discussions with the Client in which the Client’s goals and objectives are established, Perigon
determines if the strategy is suitable to the Client’s circumstances. Once Perigon determines the suitability of the
portfolio, the portfolio is managed based on the portfolio’s strategy rather than on each Client’s individual needs.
Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held
in their account[s]. Clients retain individual ownership of all securities. To ensure that Perigon’s initial
determination of an appropriate portfolio remains suitable and that the account continues to be managed in a
manner consistent with the Client’s financial circumstances, Perigon will:
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1. At least annually, contact each participating Client to determine whether there have been any changes in
the Client’s financial situation or investment objectives and whether the Client wishes to impose
investment restrictions or modify existing restrictions;
2. Be reasonably available to consult with the Client; and
3. Maintain Client suitability information in each Client’s record.
Use of Independent Managers – Perigon may 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, based on the Client’s needs and objectives. In certain 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 will
perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the
Independent Manager’s strategies and target allocations remain aligned with its Client's investment objectives
and overall best interests. The Advisor will also assist in the development of the initial policy recommendations
and managing the ongoing Client relationship. Prior to entering into an agreement with an unaffiliated Investment
Manager[s], the Client will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes
the appropriate disclosures).
Use of Sub-Advisors – Perigon may periodically recommend and refer Clients to unaffiliated money managers,
investment advisors (herein “Sub-Advisors”), or turnkey asset management programs (“TAMPs”) at Perigon’s
discretion or the Client’s request. In certain instances, the Client may be required to authorize and enter into an
investment management agreement with the Sub-Advisor or TAMP that defines the terms in which the Sub-
Advisor or TAMP will provide its services. Perigon will remain the Client’s primary Advisor and oversee the Client’s
investment allocation[s] and overall investment performance. While the Sub-Advisor or TAMP will assume day-
to-day investment management of the assets, Perigon will be responsible for establishing the Client’s investment
objectives and recommending a Sub-Advisor’s or TAMP’s investment strategy to meet those objectives. The Client
will be provided with the Sub-Advisor’s or TAMP’s Form ADV Part 2A (or a brochure that makes the appropriate
disclosures).
TAMPs may provide back-office administration services to Perigon, which can include research, trading and
rebalancing, and administrative services such as Client account paperwork, Client billing, performance reporting,
and investment due diligence. Perigon may not utilize all services offered by the TAMP. TAMPs typically rebalance
Client portfolios according to the specified model or asset allocation selected by Perigon or according to the
TAMP’s models. TAMPs are not responsible for the analysis of Perigon’s Clients’ financial situations, suitability
requirements, asset allocations, or investment restrictions.
SEI Investments Management Corporation – Certain IARs of Perigon recommend and refer Clients to SEI
Investments Management Corporation (“SIMC”), an unaffiliated investment advisor registered with the SEC.
These IARs’ recommendations and referrals of SIMC are at the IARs’ or Clients’ request. Through this
arrangement, the Client will enter into an advisory agreement with SIMC, and Perigon will assist and advise the
Client in establishing investment objectives and developing an investment strategy to meet those objectives by
identifying appropriate investments and monitoring such investments. In consideration for such services, SIMC
receives an investment advisory fee billed according to the fee schedule the Client establishes with SIMC.
Additionally, in these instances, Perigon receives a portion of the investment advisory fee for the solicitation and
referral of the Client to SIMC and may assist the Client with completing their account opening paperwork. Perigon
may also assist in the development of the initial policy recommendations and managing the ongoing relationship.
Prior to entering into an agreement with SIMC, Perigon will provide the client with SIMC’s Form ADV Part 2A (or
a brochure that contains the appropriate disclosures).
LPL Financial, LLC Sponsored Advisory Programs – Perigon may provide advisory services through certain
programs sponsored by LPL Financial, LLC (“LPL”), a registered investment advisor and broker-dealer (CRD#
6413). LPL charges fees for these sponsored programs that are in addition to Perigon’s advisory fees. Below is a
brief description of each LPL advisory program used by the Advisor. For more information regarding the LPL
programs, including information on the advisory services and fees that apply, the types of investments available
in the programs, and the conflicts of interest presented by the programs, please refer to the applicable LPL
program client account packet.
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•
Manager Access Select Program (“MAS”) – Manager Access Select offers Clients access to the
investment advisory services of professional portfolio management firms for the individual management
of Client accounts. The Advisor will assist the Client in identifying a third-party portfolio manager (“Portfolio
Manager”) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages
Clients’ assets on a discretionary basis. The Advisor will provide the initial and ongoing assistance
regarding the Portfolio Manager selection process. LPL requires a minimum account value of $50,000 for
Manager Access Select; however, in certain instances, the minimum account size may be lower or higher.
•
Model Wealth Portfolios Program (“MWP”) – MWP offers Clients a professionally managed mutual fund
asset allocation program. The Advisor will obtain the necessary financial data from the Client, assist the
Client in determining the suitability of the MWP program, and assist the Client in setting an appropriate
investment objective. The Advisor will initiate the steps necessary to open an MWP account and have the
discretion to select a model portfolio designed by LPL’s Research Department consistent with the Client’s
stated investment objective. LPL’s Research Department or a third-party portfolio strategist act as the
portfolio strategist responsible for selecting the mutual funds or ETFs within a model portfolio and for
making changes to the mutual funds or ETFs selected. The Client will authorize LPL to act on a
discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased
securities. The Client will also authorize LPL to effect rebalancing for MWP accounts. MWP requires a
minimum asset value for a program account to be managed. The minimums vary depending on the
portfolio[s] selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio
is $10,000.
All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the
advisory agreement. Please see Item 12 – Brokerage Practices. Under certain circumstances, Perigon may accept
or maintain custody of a Client’s funds or securities. Please see Item 15 – Custody for more information.
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,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to the 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 earns a new (or
increases 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.
Participant Account Management – As part of the Advisor’s investment management services, when appropriate,
the Advisor will use a third-party platform to facilitate the management of held-away assets, such as defined
contribution plan participant accounts, with investment discretion. The platform allows the Advisor to avoid being
considered to have custody of Client funds since the Advisor does not have direct access to Client log-in
credentials to affect trades. Perigon is not affiliated with the platform in any way and receives no compensation
from them for using their platform. A link will be provided to the Client, allowing the Client to connect an account[s]
to the platform. Once the Client’s account[s] is connected to the platform, the Advisor will review the current
account allocations. When deemed necessary, the Advisor will rebalance the account considering the Client’s
investment goals and risk tolerance, and any change in allocations will consider current economic and market
trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage
internal fees that harm account performance. Client account[s] will be reviewed at least quarterly, and allocation
changes will be made as deemed necessary.
Non-Purpose Loans – If in the best interest of the Client, the Advisor will introduce certain Clients to a Pledged
Asset Line®, a non-purpose revolving line of credit made available through Charles Schwab Bank, a subsidiary of
The Charles Schwab Corporation, secured by eligible assets held in an account maintained at the Custodian.
(“Lending Program”). In such instances, the Client’s assets in their account[s] at the Custodian will be utilized as
collateral for a non-purpose revolving line of credit. The recommendation of a Lending Program presents a conflict
of interest as the Advisor will continue to receive investment advisory fees for managing the collateralized assets
in the Client’s account[s]. Clients are not obligated to engage the Advisor for the Lending Program. For additional
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information related to the risks involved in non-purpose loans and lines of credit, please see Item 8 – Methods of
Analysis, Investment Strategies, and Risk of Loss.
Digital Assets – The Advisor will assist interested Clients with establishing a digital currency account[s] through
Fidelity Digital Asset Services, LLC (“FDAS”), a subsidiary of Fidelity Investments. FDAS is a platform for digital
assets, which the Advisor offers as a possible portfolio management diversification strategy for Clients who
express an interest in exposure to digital assets. “Digital asset” shall mean a digital asset (also called a
“cryptocurrency,” “virtual currency,” “digital currency,” or “digital commodity”), such as bitcoin, which is based on
the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-
source, and (iii) used as a medium of exchange and/or store of value. Clients will establish a Digital Asset account
and transfer funds into an account opened on the FDAS platform.
Financial Planning Services – Perigon will typically provide a variety of financial planning and consulting services
to Clients included with its wealth management services or pursuant to a written financial planning agreement.
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 needs, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings, and/or charitable giving programs.
Perigon may also refer Clients to an accountant, attorney, or other specialists as appropriate for their unique
situation. At the Advisor’s sole discretion, it may include all or a portion of a Client’s attorney fees as a component
of its financial planning services. For certain financial planning engagements, the Advisor will provide a written
summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc
engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed
within six (6) months of the contract date, assuming all information and documents requested are provided
promptly.
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. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor.
Consulting and Concierge Services
Perigon provides a variety of consulting and concierge services to Clients pursuant to a written consulting and
concierge services agreement. Certain legacy Clients may have consulting and concierge services included as a
component of their wealth management services. Consulting and concierge services generally include providing
Clients with advice on a more focused basis. This may include advice on an isolated area(s) of concern, such as
estate planning, retirement planning, business and personal tax planning, charitable planning, investment
planning, cost segregation study, corporate structure, real estate analysis, mortgage and debt analysis, insurance
analysis, line of credit evaluation, business planning, employee benefits analysis, or any other specific topic.
Concierge services such as bill pay, travel planning, relocation services, and other family matters. The Advisor
also provides specific consultation and administrative services regarding the investment and financial concerns
of the Client. Consulting recommendations are not limited to any specific product or service offered by a broker-
dealer or insurance company; all recommendations are of a generic nature.
Perigon may also refer Clients to an accountant, attorney, or other specialists as appropriate for their unique
situation. At the Advisor’s sole discretion, it may include all or a portion of a Client’s attorney fees as a component
of its consulting and concierge services. For certain consulting and concierge engagements, the Advisor will
provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting
or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically
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completed within six (6) months of the contract date, assuming all information and documents requested are
provided promptly.
Consulting and concierge 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. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor.
Retirement Plan Advisory Services
Perigon 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. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight Service (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendations and Assistance
• ERISA 404(c) Assistance
These services are provided by Perigon serving in the capacity of a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of Perigon’s fiduciary status, the specific services to be rendered,
and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Sub-Advisory Management Services
The Advisor may also act as a sub-advisor to unaffiliated third-party investment advisors (the "Primary Investment
Advisor"), whereby such third parties engage Perigon for the purpose of managing all or a portion of the unaffiliated
advisor's client assets ("outside accounts"). The third-party advisor will remain the Primary Investment Advisor for
its client accounts. Under such arrangements, Perigon provides discretionary asset management services, where
the management services provided to the outside accounts are based upon established model portfolios or
strategies that correlate to specific investment objectives and risk tolerance levels.
The model portfolio allocations will be constructed and maintained to provide investment objective-driven
management services to investors. The Primary Investment Advisor will communicate with and assist their clients
('the investor") in selecting the appropriate model based on information provided to the Primary Investment
Advisor. Perigon will monitor the investments contained in the outside accounts in order to provide ongoing
supervision as to changes in the investments and/or allocations of such investments, which are necessary to
adhere to the desired investment objective.
Subject to any written guidelines that the investor may provide, Perigon will be granted discretion and authority to
manage the outside accounts. Accordingly, the Advisor is authorized to perform various functions at the investor's
expense without further approval from the investor. Such functions include the determination of the type and
amount of securities to be purchased and/or sold. Perigon provides continuous supervision and rebalancing of
the outside account portfolios as changes in market conditions occur.
The Primary Investment Advisor
will be responsible for determining the initial and ongoing suitability of any of
Perigon’s portfolios in which to place the investor’s assets. Perigon will manage the outside accounts in
accordance with the chosen portfolio’s stated objectives and will not be responsible for determining the suitability
of any chosen strategy/portfolio.
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C. Client Account Management
Prior to engaging Perigon 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 – Perigon, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Perigon will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation, and tolerance of risk for each Client.
• Portfolio Construction – Perigon will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – Perigon will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
For certain legacy Client relationships, Perigon typically includes, in addition to securities transaction fees,
securities transaction fees for certain mutual funds, custody fees, commission fees, admin fees, redemption fees,
trade away fees, certain program or platform fees for unaffiliated investment managers or investment platforms
and other fees and expenses (herein “Covered Costs”) with its investment advisory fees. Including these fees into
a single asset-based fee is considered a “Wrap Fee Program.” The Advisor customizes its investment
management services for its Clients. The Advisor sponsors the Perigon Wrap Fee Program solely as a
supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the
Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own
transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is a separate supplement to this
Disclosure Brochure.
E. Assets Under Management
As of February 29, 2024, Perigon manages $6,940,945,795 in Client assets, $5,112,119,472 of which are
managed on a discretionary basis and $1,828,826,323 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.