WealthPro, LLC may be referred to throughout this Brochure as “WealthPro”.
WealthPro was formed in the state of New York in July 2003 by Neal J. Solomon, CFP®, CLU,
ChFC, CASL, the firm’s sole owner and member, initially for the purpose of taking over the
investment advisory and financial planning elements of a professional practice that Mr. Solomon
began in 1983. Prior to WealthPro’s formation in July 2003, Mr. Solomon had offered similar
services to those offered by WealthPro through other firms.
WealthPro is an investment adviser providing WealthCraft®, a comprehensive offering of
financial planning, consulting, investment management and investment consulting services to
individuals, pension and profit-sharing plans, trusts, estates, charitable organizations,
corporations, not for profit organizations, and business entities, as well as the solicitation of
investment advisory services. WealthPro, depending upon the engagement, offers its services
on a fee basis which may include hourly and/or fixed fees. Alternatively, certain of the
WealthPro’s Associated Persons may offer brokerage services under a commission
arrangement, which may be used to offset WealthPro’s fees (as discussed below). Prior to
engaging WealthPro to provide any of the foregoing investment advisory services, the client will
be required to enter into one or more written agreements with WealthPro setting forth the terms
and conditions under which WealthPro shall render its services (collectively, the “Agreement”).
WealthPro is also a licensed insurance agent in the State of New York and may from time to
time become licensed as an insurance agency in other states.
WealthPro may provide its clients with a broad range of comprehensive or modular financial
planning and/or consulting services (which may include non-investment related matters).
WealthPro may charge a fixed fee and/or hourly fee for these services. WealthPro’s financial
planning and consulting fees are negotiable, but generally range from $3,000 to $12,000 on a
fixed fee basis and/or from $350 to $800 on an hourly rate basis, depending upon the level and
scope of the services and the professional rendering the financial planning and/or the consulting
services. Certain non-advisory, administrative and/or supporting services may be provided on
an hourly basis with fees ranging from $160 to $365 per hour.
Financial Planning Services and Financial Consulting
The practice of Financial Planning involves a process that typically includes, but is not limited to:
1) Establishing Goals, defining the client/planner relationship and the scope of work;
2) Gathering client data;
3) Analyzing and evaluating the client’s financial status;
4) Developing and presenting financial planning recommendations and alternatives;
5) Implementing the planning recommendations; and
6) Monitoring the financial plan and making necessary adjustments.
Financial Consulting services may include advice on one or more isolated areas of concern,
such as for example, retirement planning and/or college planning. Such services are not
comprehensive and WealthPro may not address other issues that may otherwise be considered
during a more comprehensive Financial Planning engagement. WealthPro may also provide
specific consultation and administrative services regarding investments and financial concerns
through a Consulting engagement.
WealthPro does not render any legal or tax advice in connection with the client’s financial plan
or consultation. WealthPro may present or discuss the tax aspects of certain investments or
financial strategies in general terms. Within this context, neither WealthPro nor an Associated
Person working through WealthPro provides specific tax advice. WealthPro recommends that all
tax questions or strategies should be discussed by the client, with the client’s qualified tax
professional.
As further discussed throughout this Brochure, WealthPro may provide its clients with a broad
range of comprehensive financial planning and/or consulting services (which may include non-
investment related matters). WealthPro may charge a separate fee for these services which
shall be agreed upon prior to rendering the services. WealthPro anticipates that it may devote
approximately fifteen percent (15%) of its time to such services.
Implementation of financial planning or financial consulting recommendations is entirely at the
client’s discretion. Should the client choose to implement WealthPro’s recommendations or
elements of a financial plan through WealthPro (for example engaging WealthPro to provide
investment management and/or investment consulting services), a separate agreement and
schedule of fees will apply related to that separate engagement.
Prior to engaging WealthPro to provide financial planning and/or consulting services, the client
will generally be required to enter into a written agreement with WealthPro setting forth the
terms and conditions of the engagement and describing the scope of the services to be
provided and the portion of the fee that is due from the client prior to WealthPro commencing
services. Generally, WealthPro requires one-half (50%) of the financial planning/consulting fee
(estimated hourly or fixed) payable upon entering the written agreement. The balance is
generally due upon delivery of the financial plan or completion of the agreed upon services. For
consulting engagements when the amount of time that will be required may not, in WealthPro’s
opinion, be accurately and completely estimated prior to beginning work, the client will be
offered an hourly arrangement and an initial payment will be required to begin work. As work
progresses and the initial payment is consumed, the client will be notified, and work may be
suspended until additional payment is received. WealthPro will not accept payments if it is not
expected that such payments will be earned within six months from the date of the payment.
Generally, at least an initial payment of $2,500 is required in order for WealthPro to commence
working. WealthPro may also, in its sole discretion under certain circumstances agree to bill a
client in arrears for hourly work, or to provide specified services for a pre-determined agreed
amount, with the client to be billed either hourly or and additional agreed amount for additional
services added through a supplemental agreement.
WealthPro and/or the client may terminate the agreement, at any time, by written notice to the
other. In the event the client terminates WealthPro’s financial planning and/or consulting
services, the balance of WealthPro’s unearned fees (if any) shall be refunded to the client. If the
client terminates the agreement within five (5) business days of entering into the agreement for
such services, the client shall be entitled to a full refund, minus the fee for any services that had
been already been performed prior to termination. In determining the amount of “unearned
fees,” it is WealthPro’s practice to consider all of the time spent on the client’s file and behalf,
including administrative efforts, regardless of whether the client was present during such time.
Should a client abandon an engagement prior to its completion, and WealthPro has received a
fee in advance, WealthPro may notify the client by letter that WealthPro is prepared to resume
work and invite the client to schedule a meeting to resume work. At the conclusion of six
months from the initiation of the engagement, if the client has not responded or returned,
WealthPro may, at its own choice, deem the engagement completed and all fees received fully
earned.
In performing its services, WealthPro shall not be required to verify any information received
from the client or from the client’s other professionals (e.g., attorney, broker-dealer, custodian,
insurance company, insurance agency, accountant, etc.) and is expressly authorized to rely on
such information. WealthPro may recommend the services of itself, its associated persons in
their individual capacities as registered representatives of a broker-dealer, and/or other
professionals for implementation purposes. Clients are advised that a conflict of interest exists if
WealthPro recommends its own services or services of its associated persons in their individual
capacities as registered representatives of a broker-dealer, or as insurance agent. The client is
under no obligation to act upon any of the recommendations made by WealthPro and/or to
engage the services of any such recommended professional, including WealthPro itself. The
client retains absolute discretion over all such implementation decisions and is free to accept or
reject any recommendation from WealthPro.
WealthPro may, in select instances utilize the services of another financial planning firm or
advisor selected by WealthPro, to perform certain financial plan document preparation
functions, and to perform certain calculations. In such instances, the work product will be
created in coordination with WealthPro, and WealthPro will disclose to the client involved that an
outside advisor prepared certain reports or calculations. WealthPro will review all reports and
calculations, and will present same, together with work product prepared internally at WealthPro
together to the client. In such instances WealthPro will be responsible for negotiating and
paying for the services of the outsourced service provider. WealthPro will assess the outside
service provider to confirm that such provider honors client privacy and confidentiality at a
standard no less that that used by WealthPro.
Moreover, each client is advised that it remains his/her/its responsibility to promptly notify
WealthPro if there is ever any change in his/her/its financial situation or investment objectives
for the purpose of reviewing, evaluating, or revising WealthPro’s previous recommendations
and/or services.
In the event the client chooses to engage WealthPro to provide investment management or
investment consulting services, WealthPro may provide such services on a fee basis. If
engaged, WealthPro shall charge an annual fee based upon a percentage of the market value
of the assets being managed by WealthPro. As discussed below, WealthPro’s annual fee is
exclusive of, and in addition to brokerage commissions, transaction fees, and other related
costs and expenses which shall be incurred by the client. WealthPro’s annual fee shall be
prorated and charged quarterly, in advance, based upon the market value of the assets on the
last day of the previous quarter. The annual fee shall generally vary from 0.70% to 1.65%, -
depending upon the market value of the assets under management and the type of investment
management services to be rendered. In a small number of instances, the selection a specific
third-party Independent Manager and/or Strategist (as further discussed below) the maximum
annual fee may be greater than 1.65%, typically when certain trading and/or custodial expenses
are bundled into the fee by the third-party manager selected. In such instances the client will be
advised of the fee variance at the time of account establishment.
WealthPro, in its sole discretion, may charge a lesser management fee based upon certain
criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar
amount of assets to be managed, related accounts, immediate family members of WealthPro’s
employees or associated persons, account composition, pre-existing client, account retention,
pro bono activities, etc.). All fees are subject to negotiation.
WealthPro shall primarily recommend that certain clients authorize the active discretionary
management of their assets by and/or among certain independent investment manager(s) either
directly or through a wrap fee program based upon the stated investment objectives of the
client. Rule 204-3(g)(4) of the Investors Act defines wrap fee program to be a “program under
which any client is charged a specified fee or fees not based directly on transactions in a client’s
account for investment advisory services (which may include portfolio management or advice
concerning the selection of other advisers) and execution of client transactions.” (Italics have
been added for emphasis.) A "wrap fee program" for purposes of the rule is a program under
which investment advisory and brokerage execution services are provided for a single
"wrapped" fee that is not based on the transactions in a client's account. An investment advisory
program under which all clients pay traditional, transaction-based commissions is not a wrap fee
program. Similarly, a program under which client assets are allocated among mutual funds is
not a wrap fee program because normally there is no payment for brokerage execution. Under a
typical wrap-fee program, a client will pay the sponsor a single fee (typically no more than 2.5%
of the client’s total assets held within the account or under management) for management,
brokerage, custody and other services provided under the program.”
The terms and conditions under which the client shall engage the Independent Manager(s) shall
be set forth in separate written agreements between (1) the client and WealthPro and (2) the
client and the designated Independent Manager(s) and/or wrap fee program sponsor.
WealthPro shall continue to render advisory services to the client relative to the ongoing
monitoring and review of account performance, for which WealthPro shall receive an annual
advisory fee which is based upon a percentage of the market value of the assets being
managed by the designated Independent Manager(s). WealthPro’s services in this regard are
provided on a non-discretionary basis (see Item 16 – Investment Discretion for additional
information on investment discretion). Factors that WealthPro shall consider in recommending
Independent Manager(s) include, but are not limited to, the client’s stated investment
objective(s), management style, performance, reputation, financial strength, reporting, pricing,
and research. When recommending an Independent Manager for a client, WealthPro shall
review information about the Independent Manager(s) such as its disclosure statement and/or
material supplied by the Independent Manager(s) or independent third parties for a description
of the Independent Manager’s investment strategies, past performance and risk results to the
extent available. The investment management fees charged by the designated Independent
Manager(s), together with the fees charged by the wrap fee program sponsor and
corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of,
and in addition to, WealthPro’s investment advisory fee set forth above. As discussed above,
the client may incur additional fees than those charged by WealthPro, the designated
Independent Manager(s), wrap fee program sponsor (if applicable), and corresponding broker-
dealer and custodian. A portion of WealthPro’s fee(s) may be remitted directly to The Strategic
Financial Alliance, Inc. (“The SFA”) as a solicitor’s fee or for The SFA’s supervision of
WealthPro. The SFA is a registered broker-dealer with Financial Industry Regulatory Authority
(“FINRA”) and is an investment advisor registered with the SEC.
WealthPro may also provide advice about any type of investment held in a client’s portfolio at
the beginning of or throughout the advisory relationship.
In addition to WealthPro’s written disclosure statement, the client shall also receive the written
disclosure statement of the designated Independent Manager(s) and wrap fee program sponsor
(if applicable). Certain Independent Manager(s) may impose more restrictive account
requirements and varying billing practices than WealthPro. In such instances, WealthPro may
alter its corresponding account requirements and/or billing practices to accommodate those of
the Independent Manager(s) or wrap fee program sponsor.
If WealthPro refers a client to certain Independent Manager(s) where WealthPro’s
compensation is included in the advisory fee charged by such Independent Manager(s) and the
client engages those Independent Manager(s), WealthPro shall be compensated for its services
by receipt of a fee to be paid directly by the Independent Manager(s) to WealthPro in
accordance with the requirements of Rule 206(4)-3 of the Investment Advisers Act of 1940, as
amended (the “Advisers Act”), and any corresponding state securities laws, rules, regulations,
or requirements. Any such fee shall be paid solely from the Independent Manager(s) investment
management fee or the program fee of the wrap fee program (as appropriate) and shall not
result in any additional charge to the client.
WealthPro may only implement its investment management recommendations after the client
has arranged for and furnished WealthPro with all information and authorization regarding
accounts with appropriate financial institutions. Financial institutions shall include, but are not
limited to, a broker-dealer recommended by WealthPro, a broker-dealer directed by the client, or
any other, broker-dealers, trust companies, banks etc. (collectively referred to herein as the
“Financial Institution(s)”). The Financial Institution(s) may also, alternatively be referred to as an
account(s) “Custodian.” Clients are advised that all checks or other payments or deposits into
an account are to be drafted or otherwise directed directly to the Custodian or Financial
Institution. Clients should never make a payment or deposit payable directly to WealthPro other
than a payment of a fee intended for WealthPro, LLC.
Clients may incur certain charges imposed by the Financial Institution(s) and other third parties
such as fees charged by Independent Manager(s), custodial fees, charges imposed directly by a
mutual fund or exchange traded fund in the account, which shall be disclosed in the fund’s
prospectus (e.g., fund management fees and other fund expenses), deferred sales charges,
short-term transaction or redemption fees, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Additionally, for assets outside of any wrap fee programs, clients may incur
brokerage commissions and transaction fees. Such charges, fees and commissions are
exclusive of and in addition to WealthPro’s fee.
WealthPro’s agreement with a client and/or the separate agreement with the Financial
Institution(s), may authorize the Financial Institution(s) to debit the client’s account for the
amount of WealthPro’s fee and to directly remit that management fee to WealthPro in
accordance with required SEC procedures as follows: (1) WealthPro shall send to the client and
the Financial Institution(s) at the same time a fee statement (“Fee Statement”) showing the
amount of the management fee for the period, and, additionally, shall include in the client’s Fee
Statement the specific manner in which the management fee was calculated and the value of
the client’s assets on which the fee was based, and/or (2) the Financial Institution(s) shall send
a statement to the client, at least quarterly, indicating all amounts disbursed from the account
including the amount of management fees paid directly to WealthPro. As discussed above, in
some instances WealthPro may alter its billing practices to accommodate those of the
Independent Manager(s), a wrap fee program sponsor, or a platform, and the calculation of fees
may be performed by such Independent Manager(s), wrap fee program sponsor or platform,
whose procedures WealthPro believes to also be in accordance with required SEC procedures.
For the initial quarter of investment management services, the first quarter’s fees shall be
calculated on a pro rata basis. The Agreement between WealthPro and the client will continue in
effect until terminated by either party pursuant to the terms of the Agreement. WealthPro’s
annual fee shall be prorated through the date of termination and any remaining balance shall be
charged or refunded to the client, as appropriate, in a timely manner.
Additions to an account may be paid in cash or securities provided that WealthPro reserves the
right to liquidate any transferred securities or decline to accept particular securities into a client’s
account. The account custodian(s) may likewise refuse or be unable to accept particular
securities. Transferred securities shall be liquidated without regard to any transaction fees, fees
assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax
ramifications.
WealthPro offers an asset allocation system known as the AssetMark, Inc. Platform (“AssetMark
Platform”). WealthPro refers to this program when offered to WealthPro’s clients as the
‘WealthCraft® - Managed Asset Allocation Program (“MAAP”)’ or “WealthCraft® - MAAP”. For
more information regarding the AssetMark Platform refer to the AssetMark Platform Disclosure
Brochure.
The minimum investment required in the AssetMark Platform depends upon the Investment
Solution chosen for a client’s account and is generally $10,000, $25,000, or $50,000 for Mutual
Fund accounts and $100,000 for certain Accounts, and from $50,000 to $1,000,000 for Privately
Managed and Unified Managed Accounts, depending on the investment strategy and Strategist
selected for the account, as described in more detail in the AssetMark Platform Disclosure
Brochure. Accounts below the stated minimums may be accepted on an individual basis at the
discretion of the Platform sponsor. The third-party asset managers may raise or lower their
minimum account sizes at any time or may add or eliminate access to certain Investment
Solutions.
Assets Under Management - As of December 31, 2023, WealthPro had $44,310,950 in assets
under management. Of this amount, $27,217,835 resided within the WealthCraft® MAAP.
To the extent that a client may be eligible to use more than one of the Independent Manager(s)
recommended by WealthPro, or in the instance of the AssetMark Platform, more than one of the
available “Strategist(s)” available on the AssetMark Platform, a conflict of interest may exist in
the selection of Independent Manager(s) or Strategist(s) when in some instances WealthPro
may receive greater compensation from the use of one Independent Manager(s) or Strategist(s)
or portfolio over another. Additionally, WealthPro may at times recommend that a client split its
investment accounts between two or more Independent Manager(s) or Strategist(s) in order to
gain additional investment diversification or access to unique services. Splitting an investment
portfolio among multiple accounts may increase the fees that a client will pay to their account
Custodial Financial Institution(s), as many of the Financial Institutions charge a minimum fee on
a per account basis. It is possible that in some instances these custodial or other Financial
Institution fees may be less were WealthPro to recommend, or the client to require, that a
minimal number of accounts be utilized. Likewise, should WealthPro place a client’s assets with
more than one of the available Independent Managers, the client may pay a higher fee than if
the assets were concentrated with a single Independent Manager. Typically, each Independent
Manager will offer a fee schedule whereby as a client’s account value with that Independent
Manager increases, its fees for management of larger accounts (and in some instances
WealthPro’s fees relative to the account(s)), may decrease. WealthPro, as a matter of routine
business, does believe that the benefits of greater investment diversification justify directing
client assets to multiple accounts and in some instances multiple Independent Managers and/or
Strategists. Diversification neither assures a profit nor eliminates the risk of experiencing
investment losses.
WealthPro’s clients are advised to promptly notify WealthPro if there are ever any changes in
their financial situation or investment objectives, or if they wish to impose any reasonable
restrictions upon WealthPro’s management services.
While WealthPro itself does not sell securities products to its investment advisory clients,
WealthPro does permit its Associated Persons, in their individual capacities as registered
representatives of The Strategic Financial Alliance, Inc. (The SFA”), to sell securities products to
its investment advisory clients. A conflict of interest exists to the extent that WealthPro
recommends the purchase of securities where WealthPro’s Associated Persons receive
commissions or other additional compensation as a result of WealthPro’s recommendations. In
the event the client desires, the client can engage certain persons associated with WealthPro
(but not WealthPro) to render securities brokerage services under a commission arrangement.
Under this arrangement, the client may implement securities transactions through certain of
WealthPro’s Associated Persons, in their respective individual capacities as registered
representatives of The SFA. Brokerage commissions may be charged by The SFA to effect
these securities transactions and thereafter, a portion of these commissions may be paid by The
SFA to such Associated Persons. Prior to effecting any transactions, the client will be required
to enter into a new account agreement with The SFA. The brokerage commissions charged by
The SFA may be higher or lower than those charged by other broker-dealers. In addition,
certain of WealthPro’s Associated Persons (as applicable), in their individual capacity as
representatives of The SFA may also receive additional ongoing 12b-1 fees or other asset-
based sales charges or service fees for mutual fund purchases from a mutual fund company
during the period that the client maintains the mutual fund investment with The SFA listed as
brokerage firm of record. Likewise, certain of WealthPro’s Associated Persons (as applicable),
may also receive additional ongoing asset-based compensation or service fees for variable
annuity purchases from the issuing insurance company during the period that the client
maintains the variable annuity investment. In a similar manner, certain other securities such as
managed futures funds, may also utilize the ongoing asset-based compensation or service fees
model. In such situations where one of WealthPro’s Associated Persons establishes an account
or accounts through The SFA on behalf of a WealthPro, LLC client, such account(s) through
The SFA are separate and distinct from accounts held through WealthPro, LLC. WealthPro, LLC
will not itself receive and such commission revenue from accounts held at The SFA. WealthPro,
LLC and The SFA are separate entities and each is responsible for its own business. It is
estimated that WealthPro’s Associated Persons currently devote approximately ten percent
(10%) to twenty percent (20%) of their time to commission securities brokerage business
through The SFA.
Neither WealthPro nor the client may assign an investment advisory or financial
planning/consulting Agreement without the consent of the other party. Transactions that do not
result in a change of actual control or management of WealthPro shall not be considered an
assignment.
A copy of WealthPro’s privacy policy notice and a written disclosure statement that meets the
requirements of Rule 204-3 of the Investment Advisers Act of 1940, as amended, shall be
provided to each client prior to or contemporaneously with the execution of the investment
advisory or financial planning/consulting Agreement. Any client who has not received a copy of
WealthPro’s Brochure at least forty-eight (48) hours prior to executing the Agreement, shall
have five (5) business days subsequent to executing the agreement to terminate WealthPro’s
services without penalty.
WealthPro does not vote proxies on behalf of its clients.
Operational risks, loss or disability of key personnel, disruptions at venders, custodians,
independent managers, information technology services, and the like may disrupt our business,
result in losses, limit or prevent our ability to provide service to clients.
Cyber incidents or attacks directed at us could result in information theft, data corruption,
operational disruption and/or financial loss.
We are heavily dependent on the capacity and reliability of the communications, information and
technology systems supporting our operations, whether developed, owned and operated by us
or by third parties. Operational risks such as trading or operational errors or interruption of our
financial, accounting, trading, compliance and other data processing systems, whether caused
by fire, natural disaster or pandemic, power or telecommunications failure, act of terrorism or
war or otherwise, could result in a disruption of our business, liability to clients, regulatory
intervention or reputational damage, and thus adversely affect our business. Although we have
back-up systems in place, our back-up procedures and capabilities in the event of a failure or
interruption may not be adequate. We depend on our headquarters in Gloversville, New York,
where our key employees, administration and technology resources are located, for the
continued operation of our business. Any significant disruption to our headquarters could have
an adverse effect on our business.
We depend on third-party service providers for services that are important to our business, and
an interruption or cessation of such services by any such service providers could have an
adverse effect on our business.
We depend on a number of service providers, including custodial and clearing firms, and
vendors of communications and networking products and services. We are not assured that
these providers will be able to continue to provide these services in an efficient manner. An
interruption, cyberattack, malfunction in, or the cessation of an important service by any third-
party and our inability to make alternative arrangements in a timely manner, or at all, could have
an adverse impact on our business, financial condition and client services.
The sophistication of cyber criminals has increased dramatically in recent years and some
cyber-attacks may be conducted by state actors or by groups supportive of or affiliated with
hostile governments. As we depend on digital technologies, including information systems,
infrastructure and cloud applications and services, including those of third parties with which we
may deal, we may be vulnerable, or others we depend on may be vulnerable to cyber-attacks or
various forms of cybercrimes including potentially acts of war either declared or undeclared.
Sophisticated and deliberate attacks on, or security breaches in, our systems or infrastructure,
or the systems or infrastructure of third parties or the cloud, could lead to corruption or
misappropriation of our assets, proprietary information and sensitive or confidential data. We
may not be sufficiently protected against such occurrences. We may not have sufficient
resources to adequately protect against, or to investigate and remediate any vulnerability to,
cyber incidents. It is possible that any of these occurrences, or a combination of them, could
have adverse consequences on our business and lead to financial loss. It is possible that any
cyber insurance that we may maintain would prove inadequate or a claim may be denied.
We depend on a small number of key individuals to operate our business. The loss or incapacity
of these individuals may adversely impact our ability to operate and provide services in a timely
manner if at all.