Who Are We and What Do We Do?
Everest Consultants, LLC (hereafter referred to as “Everest”) is a multi-member limited
liability corporation under the State of New York and registered as an Investment
Advisor under the Laws of the State of New York. Alexander S. Pasquale is the founder
and Managing Member of the LLC and is properly licensed to conduct business as an
investment adviser representative. Anita P. Lombardi and Nathaniel Gavitt are minority
owners and members of the LLC and are also properly licensed to conduct business
as investment adviser representatives.
Our purpose is to provide investment advisory services. We are an independent
investment advisory firm so we are not obligated to any one investment advisor firm or
broker dealer. While we are able to work with various registered investment advisers
and broker/dealers to offer custody, brokerage and financial management products and
services, we have a contractual relationship with Charles Schwab & Co., Inc. a FINRA-
registered broker-dealer and SIPC member (“Schwab) to provide custodial and
reporting services to our clients to hold your assets and buy and sell securities. The
majority of our clients, about 68%, have established accounts through Schwab’s
advisor platform.
We also provide investment advisory services to employer-sponsored retirement plans
representing approximately 22% of our total client base. The majority of this business
is in participant directed 401k plans that are offered through partnerships with Paychex,
Voya, ADP and MVP Plan Administrators, wherein Everest provides investment
advisory services through the custodial-third party administrator’s platform. These
clients are subject to the Employee Retirement Income Security Act of 1974 (ERISA).
In addition to using Schwab’s advisor platform, many of our clients also have
investment assets that were procured through the use of an Outside Adviser,
Custodian, Issuer or Broker/Dealer (herein collectively called “Outside Adviser”).
Everest has a solicitor-referrer arrangement with one of these Outside Advisers,
Oppenheimer & Co., Inc. (“Oppenheimer”), however, Everest no longer participates in
this referrer arrangement although there are a few accounts that still have accounts
through Oppenheimer.
Recommendations to a client to use an Outside Adviser other than Schwab, is made
based on a particular type of investment that Everest may recommend a client.
Examples of such investments are 529 plans, fixed annuities, limited offerings and
partnerships, private placements, Crowd-funding investments, and digital assets
(crypto-currency, virtual coins and tokens).
Everest’s regulatory assets under management (RAUM) as of December 31, 2023 are
as follows:
Discretionary RAUM - $ 384,233,573
Non-discretionary RAUM - $ 165,681,919
The discretionary RAUM represent those clients whose assets are managed through
Schwab or as the advisor of a participant-directed 401k plan for which our firm provides
ongoing advice and makes investment recommendations. The non-discretionary
RAUM represent assets that are held through an Outside Adviser, broker-dealer,
private placement, insurance carrier, or other securities that are not within our discretion
or control.
Our Services
We assist our clients by developing an asset allocation, determining investment
strategies and choosing a tailored investment program based on financial need, risk
tolerance and investment philosophy. We then recommend an investment
management program best suited to your needs. We are independently owned and
operated and not affiliated with Schwab, or any of Schwab’s affiliates, or any of the
Outside Advisers. The investment program may include, but not be limited to, mutual
funds, exchange traded funds, professional money management programs, fixed
income, certificate of deposits, hedge funds, private placements, fixed annuities, private
notes and cash equivalents.
If you meet certain financial criteria, you may be able to participate in limited offerings,
private placements, fixed annuities, limited offerings and partnerships, crowd funding
investments, digital assets and hedge funds which may also be available through
Schwab, an Outside Adviser or issuer, broker-dealer or other qualified custodian. In all
cases, we do not custody any funds or securities in our own accounts.
Accounts are held in your name at Schwab or the selected institution, and statements
will be sent to you directly on at least a quarterly basis. Separate disclosures will also
be sent directly to you from Schwab or the selected institution, if applicable, which you
should review as it pertains to their management and treatment of your account. You
may also receive specific disclosures pertaining
to investments offered through an
Outside Adviser as described above.
We monitor your account investments, regardless of whether your accounts are held at
Schwab or through the Outside Adviser, perform asset allocation analysis, periodically
review your account performance, and, if applicable, recommend changes to
investments. While it is our practice to obtain prior approval of any investment changes,
if accounts are established at Schwab, then, you do give Everest discretion to manage
them accordingly.
While most of our business model is based on fee-based product or structures as
explained in more detail in Item 5, How We Get Paid below, Schwab and/or the Outside
Adviser may also provide brokerage services to buy other investments that are not in a
fee-based program such as, but not limited to, individual securities, CDs, structured
notes, hedge funds, REITS, unit trusts, 529 Plans, digital assets, crowd-funding
investments, private placements, etc.
Automated Investment Program through Schwab
Everest does offer an automated investment program (the Program) through which
clients are invested in arrange of investment strategies that we have constructed and
manage, each consisting of a portfolio for exchange-traded fund and mutual funds
(“Funds”) and a cash allocation. The client may instruct us to exclude up to three funds
from their portfolio. The client’s portfolio is held in a brokerage account opened by the
client at Schwab. We use the Institutional Intelligent Portfolio platform (“IIP Platform”),
offered by Schwab Performance Technologies (“SPT”), a software provider to
independent investment advisers and an affiliate of Schwab to operate the Program.
We are independent of and not owned by, affiliated with, or sponsored or supervised
by SPT, Schwab or their affiliates (herein, together, collectively referred to as Schwab).
Everest is responsible and is the client’s investment advisor and primary point of
contact with respect to the Program. Everest is responsible for determining the
appropriateness of the Program for the client, choosing a suitable investment strategy
and portfolio for the client’s investment needs and goals, and managing the portfolio on
an ongoing basis. Everest has contracted with SPT to provide the IIP Platform,
consisting of technology and related trading and account management services for the
Program. The IIP Platform enables us to make the Program available to clients online
and includes a system that automates certain key parts of our investment process.
Based on information the client provides to us, we will recommend a portfolio via the
System. The client may then indicate an interest in a portfolio that is more conservative
or aggressive than the recommended portfolio, but we then make the final decision and
select a portfolio based on all the information we have about the client. The System
also includes an automated investment engine through which we manage the client’s
portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if
the client is eligible and elects.)
Everest charges clients on the IIP Platform an advisory fee that is not set or supervised
by Schwab. A description of the advisory fee is described below in Item 5, Fees and
Compensation. Schwab does not charge or pay brokerage commissions or any other
fees to the client to participate on the Platform; however, it does receive other revenues.
These revenues include:
1) profit earned by Charles Schwab Bank, an affiliate of Schwab, for the cash portion
of the allocation of the portfolios offered on the IIP Platform;
2) advisory or administrative service fees received by Schwab’s affiliate, Charles
Schwab Investment Management, Inc., from Schwab ETFs, Schwab Funds,
Laudus Funds, or from mutual funds in the Schwab Mutual Fund Marketplace, if
any of these funds or ETFs are held in the IIP Platform’s allocation portfolios which
you are invested; and,
3) Schwab may receive a payment from the market centers where it routes ETF trade
orders for execution.
Outside Advisers (Custodians, Broker-Dealers, Issuers) other than Schwab
Everest may recommend an investment to you that can only be invested through a
particular custodian, broker-dealer, or issuer (collectively referred to as Outside
Adviser). You will establish an account directly with the Outside Adviser which will
provide the trading platform for the investment, custodial services and recordkeeping
of your investment asset. Everest will continue to monitor the investment as part of
your portfolio. Everest cannot and does not receive commissions, 12-b1 fees, trails or
any other compensation for the recommendation or sale of such securities. Everest
will charge an annual advisory fee, calculated and charged quarterly as described in