A. IHT Wealth Management LLC
IHT Wealth Management LLC (“IHT” and/or “the firm”) is an Illinois limited liability company
formed in 2014. The firm is principally owned by Steven J. Dudash and offers investment advice
and money management services.
IHT offers services through its network of investment advisor representatives (“Advisor
Representatives” or “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 IAR and
not of IHT. The IARs are under the supervision of IHT, and the advisory services of the IAR are
provided through IHT. IHT has the arrangement described above with the following Advisor
Representatives:
• Boardwalk Wealth Solutions
• Bridge Benefits Group
• Carrera Financial
• DeWitt Wealth Advisors
• DWF Wealth Management
• Equity Wealth Management
• Eclipse Private Wealth Management
• Gratitude Wealth Management
• J. David Barkley & Associates
• Jeff K. Ross Financial
• JLS Wealth Management
• KMG Wealth Management
• Lighthouse Financial Group
• LPG Financial
• Milestone Financial Services
• Mueller Financial Services
• nVision 401(K) Plan Advisors
• nVision Wealth
• Pinnacle Wealth Management
• Provident Wealth Management
• Riverstone Wealth Management
• Rocky Mountain Wealth Management
• Sewell Wealth Management
• Stonebriar Wealth Management
• Success Wealth Management
• SW Advisers
• Tall Oaks Advisors
• The Nessim Group
• Thrive Life 360
• Venice Wealth Partners
• W Investments
B. Advisory Services Offered
B.1. Discretionary Asset Management Services
For its discretionary asset management services, IHT receives a limited power of attorney to
effect securities transactions on behalf of its clients that include securities and strategies
described in Item 8 of this brochure.
IHT’s discretionary asset management services are predicated on the client's investment
objectives, goals, tolerance for risk, and other personal and financial circumstances. IHT will
analyze each client's current investments, investment objectives, goals, age, time horizon,
financial circumstances, investment experience, investment restrictions and limitations, and risk
tolerance and implement a portfolio consistent with such investment objectives, goals, risk
tolerance and related financial circumstances. IHT’s objective is to review the client’s tax,
financial, and estate planning objectives and goals in connection with the client’s investment
objectives, goals, tolerance for risk, and other personal and financial circumstances and make
appropriate recommendations and implementation decisions. IHT may engage third-party
service providers to assist with the tax and estate planning portion of the services provided to
clients. In addition, IHT may utilize third-party software to analyze individual security holdings
and separate account managers utilized within the client’s portfolio.
IHT’s investment advisory services to clients take into account a client's personal financial
circumstances, investment objectives and tolerance for risk (e.g., cash-flow, tax and estate). IHT’s
engagement with a client will include, as appropriate, the following:
Providing assistance in reviewing the client's current investment portfolio against the
client's personal and financial circumstances as disclosed to IHT in response to a
questionnaire and/or in discussions with the client and reviewed in meetings with IHT.
Analyzing the client's financial circumstances, investment holdings and strategy, and
goals.
Providing assistance in identifying a targeted asset allocation and portfolio design.
Implementing and/or recommending individual equity and fixed income securities,
mutual funds and ETFs.
Reporting to the client on a quarterly basis or at some other interval agreed upon with
the client, information on contributions and withdrawals in the client's investment
portfolio, and the performance of the client's portfolio measured against appropriate
benchmarks (including benchmarks selected by the client).
Proposing changes in the client's investment portfolio in consideration of changes in the
client's personal circumstances, investment objectives and tolerance for risk, the
performance record of any of the client's investments, and/or the performance of any
fund retained by the client.
If the client’s portfolio and personal circumstances, investment objectives, and tolerance
for risk make such advice appropriate, providing recommendations to hedge a client’s
portfolio through the use of derivative strategies, to generate additional income through
the use of covered call option writing strategies involving exchange listed or OTC
options, and/or to monetize or hedge concentrated stock positions.
In addition to providing IHT with information regarding their personal financial circumstances,
investment objectives and tolerance for risk, clients are obligated to provide the firm with any
reasonable investment restrictions that should be imposed on the management of their
portfolio, and to promptly notify the firm in writing of any changes in such restrictions or in the
client's personal financial circumstances, investment objectives, goals and tolerance for risk. IHT
will remind clients of their obligation to inform the firm of any such changes or any restrictions
that should be imposed on the management of the client’s account. IHT will also contact clients
at least annually to determine whether there have been any changes in a client's personal
financial circumstances, investment objectives and tolerance for risk.
B.2. LPL Financial Sponsored Advisory Programs – Guided Wealth Portfolios (“GWP”)
IHT may provide advisory services through the GWP program sponsored by LPL Financial LLC
(LPL), a registered investment advisor and broker-dealer. Below is a brief description of GWP. For
more information regarding GWP, including more information on the advisory services and fees
that apply, the types of investments available, and the potential conflicts of interest presented
by the program, please see the GWP program account packet (which includes the account
agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or GWP.
GWP offers clients the ability to participate in a centrally managed, algorithm-based investment
program, which is made available to users and clients through a web-based, interactive account
management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-
traded funds and open-end mutual funds are generated through proprietary, automated,
computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”),
based upon model portfolios constructed by LPL and selected for the account as described
below (such model portfolio selected for the account, the “Model Portfolio”). Communications
concerning GWP are intended to occur primarily through electronic means (including but not
limited to, through email communications or through the Investor Portal), although IHT will be
available to discuss investment strategies, objectives or the account in general in person or via
telephone.
A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five
(45) days to help users determine whether they would like to become advisory clients and
receive ongoing financial advice from LPL, FutureAdvisor and IHT by enrolling in the advisory
service (the “Managed Service”). The Educational Tool and Managed Service are described in
more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to
be advisory clients of LPL, FutureAdvisor or IHT, do not enter into an advisory agreement with
LPL, FutureAdvisor or IHT, do not receive ongoing investment advice or supervisions of their
assets, and do not receive any trading services.
A minimum account value of $5,000 is required to enroll in the Managed Service.
Features of the Managed Service
Investors participating in the Managed Service (“clients” and each, a “client”) complete an
account application (the “Account Application”) and enter into an account agreement (the
“Account Agreement”) with LPL, IHT and FutureAdvisor. As part of the account opening
process, clients are responsible for providing complete and accurate information regarding,
among other things, their age, risk tolerance, and investment horizon (collectively, “Client
Profile”). LPL, IHT and FutureAdvisor rely on the information in the Client Profile in order to
provide services under the Program, including but not limited to, determination of suitability
of the Program for clients and an appropriate Investment Objective and Model Portfolio for
clients. The Model Portfolios have been designed and are maintained by LPL or, in the future, a
third-party investment strategist (as applicable, the “Portfolio Strategist”) and shall include a
list of securities holdings, relative weightings and a list of potential replacement securities for
tax harvesting purposes. FutureAdvisor, IHT and clients cannot access, change or customize
the Model Portfolios. Only one Model Portfolio is permitted per account.
Based upon a client’s risk tolerance as indicted in the Client Profile, the client is assigned an
investment allocation track (currently Fixed Income Tilt, Balance Tilt or Equity Tilt), the purpose
of which is to slowly rotate the client’s equity allocation to fixed income over time. LPL
Research created these tracks using academic research on optimal retirement allocations, the
industry averages as calculated by Morningstar for the target date fund universe, and input
from FutureAdvisor.
Within the applicable allocation track and based upon a client’s chosen Retirement Age in the
Client Profile, the client will be assigned a Model Portfolio and one of five of LPL’s standard
investment objectives:
Income with capital preservation. Designed as a longer term accumulation account, this
investment objective is considered generally the most conservative. Emphasis is placed
on generation of current income with minimal risk of capital loss. Lowering the risk
generally means lowering the potential income and overall return.
Income with moderate growth. This investment objective emphasizes generation of
current income with a secondary focus on moderate capital growth.
Growth with income. This investment objective emphasizes modest capital growth with
some focus on generation of current income.
Growth. This investment objective emphasizes achieving high long-term growth and
capital appreciation. There is little focus on generation of current income.
Aggressive growth. This investment objective emphasizes aggressive growth and
maximum capital appreciation, with no focus on generation of current income. This
objective has a very high level of risk and is for investors with a longer timer horizon.
Both the client and IHT are required to review and approve the initial Investment Objective. As
a client approaches the Retirement Age, the Algorithm will automatically adjust the client’s
asset allocation. Any change to the Investment Objective directed by a client due to changes
in the Client’s risk tolerance and/or Retirement Age will require written approval from the
client and IHT before implementation. Failure to approve the change in Investment Objective
may result in a client remaining in a Model Portfolio that is no longer aligned with the
applicable Client Profile. The Investment Objective selected for the account is an overall
objective for the entire account and may be inconsistent with a particular holding and the
account’s performance at any time and may be inconsistent with other asset allocations
suggested to client by LPL, IHT or FutureAdvisor prior to client entering into the Account
Agreement. Achievement of the stated investment objective is a long-term goal for the
account, and asset withdrawals may impair the achievement of client’s investment objectives.
A Client Profile that includes a conservative risk tolerance over a long-term investment horizon
may result in the selection of an Investment Objective that is riskier than would be selected
over a shorter-term investment horizon. Clients should contact IHT if they believe the
Investment Objective does not appropriately reflect the Client Profile, such as their risk
tolerance.
By executing the Account Agreement, clients authorize LPL and FutureAdvisor to have
discretion to buy and sell only exchange-traded funds (“ETFs”) and open-end mutual funds
(“Mutual Funds”) (collectively, “Program Securities”) according to the Model Portfolio selected
and, subject to certain limitations described in the Account Agreement, hold or liquidate
previously purchased non-model securities that are transferred into the account (“Legacy
Securities”). In order to be transferred into an account, Legacy Securities must be Mutual
Funds with which LPL has a full or partial selling agreement, ETFs or individual U.S. listed
stocks. Securities that are not Program Securities included within the Model Portfolio will not
be purchased for an account, and FutureAdvisor, in its sole discretion, will determine whether
to hold or sell Legacy Securities, generally, but not solely, with the goal of optimizing tax
impacts for accounts that are subject to tax. Additional Legacy Securities will not be purchased
for the account. Clients may not impose restrictions on liquidating any Legacy Securities for
any reason. Clients should not transfer in Legacy Securities that they are not willing to have
liquidated at the discretion of FutureAdvisor.
In addition, uninvested cash may be invested in money market funds, the Multi-Bank Insured
Cash Account (“ICA”) or the Deposit Cash Account (“DCA”), as applicable, as described in the
Account Agreement. Dividends paid by the Program Securities in the account will be
contributed to the cash allocation and ultimately reinvested into the account based on the
Model Portfolio once the tolerance within cash allocation is surpassed.
Pursuant to the Account Agreement, FutureAdvisor is authorized to perform tax harvesting
when
deemed acceptable by the Algorithm based on the Legacy Securities’ respective tax lot
information. If tax lot information is missing for a Legacy Security, the Legacy Security will be
retained in the Account while FutureAdvisor and IHT use reasonable efforts to obtain the
missing information. If the information cannot be obtained within a reasonable timeframe
(generally no longer than 30 days), the Legacy Security will be sold and replaced with a
Program Security in the Model Portfolio. LPL, IHT and clients cannot alter trades made for tax
harvesting purposes. In order to permit trading in a tax-efficient manner, the Account
Agreement also grants FutureAdvisor the authority to select specific tax lots when liquidating
securities within the account. Although the Algorithm attempts to achieve tax efficiencies, by
doing so a client’s portfolio may not directly align with Model Portfolio. As a result, a client
may receive advice that differs from the advice received by accounts using the same Model
Portfolio, and the client’s account may perform differently than other accounts using the same
Model Portfolio.
During the term of the Account Agreement, FutureAdvisor will perform a daily review of the
account to determine if rebalancing is appropriate based on tolerance thresholds established
by LPL and/or FutureAdvisor. At each rebalancing review, the account will be rebalanced if at
least one of the account positions is outside such thresholds, subject to a minimum
transaction amount established by LPL and/or FutureAdvisor. In addition, LPL and/or
FutureAdvisor may review the account for rebalancing in the event that the Portfolio Strategist
changes a Model Portfolio. FutureAdvisor may delay placing rebalancing transactions for non-
qualified accounts by a number of days, to be determined by FutureAdvisor, in an attempt to
limit short-term tax treatment for any position being sold. In addition, trading in the account
at any given time is also subject to certain conditions, including but not limited to, conditions
related to trade size, compliance tests, the target cash allocation and allocation tolerances.
LPL, IHT and clients can alter the rebalancing frequency.
Selection of FutureAdvisor as Third-Party Robo Advisor
Under IHT’s agreement with LPL, IHT was provided the opportunity to offer GWP, which
utilizes FutureAdvisor’s Algorithm as described herein, to prospective clients. FutureAdvisor is
compensated directly by LPL for its services, including the Algorithm and related software,
through an annual sub-advisory fee (tiered based on assets under management by
FutureAdvisor, at a rate ranging from 0.10% to 0.17%). As each asset tier is reached, LPL’s
share of the compensation shall increase and clients will not benefit from such asset tiers. No
additional fee is charged for FutureAdvisor’s services.
IHT believes that certain clients will benefit from GWP’s advisor-enhanced advisory services,
particularly due to the relatively low minimum account balance and the combination of a
digital advice solution with access to an advisor. Unlike direct-to-consumer robo platforms,
IHT is responsible on an ongoing basis as investment advisor and fiduciary for the client
relationship, including for recommending the program for the client; providing ongoing
monitoring of the program, the performance of the account, the services of LPL and
FutureAdvisor; determining initial and ongoing suitability of the program for the client;
reviewing clients’ suggested portfolio allocations; reviewing and approving any change in
Investment Objective due to changes clients make to their Client Profile; answering questions
regarding the program, assisting with paperwork and administrative and operational details
for the account; and being available to clients to discuss investment strategies, changes in
financial circumstances, objectives or the account in general in person or via telephone. IHT
can also recommend other suitable investment programs if clients have savings goals or
investment needs for which GWP is not the optimal solution.
B.3. Consulting and Financial Planning Services
The firm offers financial planning services, which may include a review of a client’s current
financial situation, such as cash management, risk management, insurance, education funding,
goal setting, retirement planning, estate and charitable gift planning, tax planning, and capital
needs planning. Creation of a comprehensive financial plan generally requires at least four hours
of an investment adviser representative’s time. Financial planning services are offered to those
clients who express need for such comprehensive planning, and some clients do not utilize the
firm for such services.
A financial plan may include both long and short-term considerations, depending upon the
client’s financial situation. Upon completion, a plan is presented to the client, compatible with
the client’s stated goals and objectives. An implementation schedule is reviewed with the client
to determine what steps will be pursued, and with whom the steps may be accomplished.
The firm’s financial plan may be a comprehensive plan encompassing a client’s entire financial
situation, including asset allocation, investments, retirement planning, education expenses,
estate planning and insurance needs. Alternatively, in consultation with a client, the financial
plan may involve less than all of such components.
B.4. ERISA Plan Consulting Services
B.4.a. Non-Discretionary 3(21) Fiduciary Services
Investment Policy Statement (“IPS”): IHT will review with the plan sponsor the investment
objectives, risk tolerance, and goals of the plan. If the plan does not have an IPS, IHT will
provide recommendations to the plan sponsor to assist the plan sponsor with
establishing an IPS. If the plan has an existing IPS, IHT will review it for consistency with
the plan’s objectives. If the IPS does not represent the objectives of the plan, IHT will
recommend to the plan sponsor revisions to align the IPS with the plan’s objectives,
which recommendations may be considered by the plan sponsor.
Designated Investment Alternatives (“DIA”): Based on the plan’s IPS, IHT will review the
investment options available to the plan and will make recommendations to assist the
plan sponsor with selecting DIAs to be offered to participants. Once the plan sponsor
selects the DIAs, IHT will, on a periodic basis and/or upon reasonable request, provide
reports and information to assist the plan sponsor with monitoring the DIAs. If the IPS
criteria require a DIA to be removed, IHT will provide recommendations to assist the plan
sponsor with replacing the DIA.
Model Asset Allocation Portfolios (“Models”): Based on the plan’s IPS or other investment
guidelines established by the plan, IHT will review the DIAs available to the plan and will
make recommendations to assist the plan sponsor with creating risk-based models
comprised solely among the plan’s DIAs. Once the plan sponsor approves the models,
IHT will provide reports, information and recommendations, on a periodic basis,
designed to assist the plan sponsor with monitoring the models. If the IPS criteria require
any DIA(s) to be removed, IHT will provide recommendations to assist the plan sponsor
with evaluating replacement DIA(s) to be included in the models. Upon reasonable
request, and depending upon the capabilities of the recordkeeper, IHT will make
recommendations to the plan sponsor to reallocate and/or rebalance the models to
maintain their desired allocations.
Qualified Default Investment Alternative (“QDIA”): Based on the plan’s IPS or other
guidelines established by the plan, IHT will review the investment options available to the
plan and will make recommendations to assist the plan sponsor with selecting the plan’s
QDIA(s). Once the plan sponsor selects the plan’s QDIA(s), IHT will provide reports and
information, on a periodic basis and/or upon reasonable request, to assist the plan
sponsor in monitoring the QDIA(s). If the IPS criteria require a QDIA to be replaced, IHT
will provide recommendations to assist the plan sponsor with evaluating replacement
QDIA(s).
B.4.b. Plan Consulting Services
Administrative Support:
• Assist plan sponsor in reviewing objectives and options available through the plan
• Review plan committee structure and administrative policies/procedures
• Recommend participant education and communication policies under ERISA
§404(c)
• Assist with development/maintenance of fiduciary audit file and document
retention policies
• Deliver fiduciary training and/or education periodically or upon reasonable request
• Assist with coordination of participant disclosures under 404a-5
• Develop requirements for responding to participant requests
Service Provider Relationship Oversight:
• Assist fiduciaries with a process to select, monitor and replace service providers
• Assist fiduciaries with review of Covered Service Providers (“CSP”) disclosures under
ERISA §408(b)(2) and fee benchmarking
• Provide reports and/or information designed to assist fiduciaries with monitoring
CSPs
• Review ERISA Spending Accounts or Plan Expense Recapture Accounts
• Assist with preparation and review of Requests for Proposals and/or Information
• Coordinate and assist with CSP replacement and conversion
Investments:
• Periodic review of investment policy in the context of plan objectives
• Assist the plan committee with monitoring investment performance
• Provide analysis of investment managers and model portfolios
• Review and recommend Designated Investment Managers (“DIMs”) and/or third-
party advice providers as necessary
• Educate plan committee members, as needed, regarding replacement of DIA(s)
and/or QDIA(s)
Participant Services:
• Facilitate group enrollment meetings
• Coordinate employee education regarding plan investments and fees
• Assist participants in understanding plan benefits, retirement readiness and impact
of increasing deferrals
B.4.c. Discretionary 3(38) Fiduciary Services
IHT will implement the IPS by investing and reinvesting the plan’s assets consistent with
the IPS.
IHT will reallocate and/or rebalance the models to maintain their desired allocations.
Adviser will select investment options that are available under the plan.
B.5. Third-Party Money Managers
Clients may access unaffiliated third-party money managers who offer specialized asset
management expertise or services that IHT utilizes to manage all or a portion of the client’s
assets in appropriate cases. Such third-party money managers’ expertise ranges from research
and selection of investment options to monitoring the assets and deciding when to sell them.
Once selected, these third-party money managers have discretion with respect to the portion of
the client’s assets placed with them, allowing such third-party money managers to choose and
prudently manage investments for the client. In exercising their discretion, such third-party
money managers may develop an appropriate investment strategy, buying and selling securities
in accordance with that strategy, subject to restrictions imposed by the client. These programs
allow clients to obtain portfolio management services that typically have higher minimum
account sizes if the client sought to engage the manager off platform or outside of the program.
IHT has no ability to affect the trading decisions of the third-party money managers once a client
decides to participate in these programs and can only choose whether to engage or terminate a
third-party money manager.
IHT retains the right to replace (i.e., "hire or fire") third-party money managers on behalf of clients
that have given discretionary authority to IHT. Discretionary authority allows IHT to choose or
change any third- party money manager approved for a given platform, without additional
approvals from the client. IHT will evaluate the third-party money managers and investment
vehicles to determine whether the third-party money manager is suitable for the client, given the
third-party money manager’s style and allocation. In addition, IHT performs ongoing due
diligence of the individual third-party money managers’ performance and management,
continuously reviews the client’s account for adherence to objectives outlined with the manager
and will reallocate assets among managers if necessary.
Each third-party money manager maintains a separate disclosure document provided to clients,
outlining the manager’s investment vehicle. In addition, IHT and third parties administering wrap
fee programs maintain additional disclosure documents that specifically pertain to the wrap fee
programs that they administer. Clients should carefully review these disclosure documents for
important and specific details including, among other things, fees, experience, investment
objectives and risk guidelines, and disclosure of the third-party money manager's potential
conflicts of interest.
B.6. Collateralized Loan Programs
IHT participates in loan programs offered by Goldman Sachs Bank USA and The Bancorp Bank
whereby IHT clients may be referred for custom collateralized loans secured by certain
investment property, securities, securities entitlements, and other financial assets maintained in
their securities accounts. In order to participate in the loan programs, the client’s assets are
required to be custodied at certain approved custodians.
C. Client-Tailored Services and Client-Imposed Restrictions
Each client’s account will be managed on the basis of the client’s financial situation and
investment objectives and in accordance with any reasonable restrictions imposed by the client
on the management of the account—for example, restricting the type or amount of security to
be purchased in the portfolio.
D. Wrap Fee Programs
IHT offers a wrap fee in which it provides investment management services for one all-inclusive
fee. Please refer to Appendix 1 of Part 2A: IHT Wrap Fee Program Brochure. Please see Item 5.A.
of this Brochure for important disclosure regarding custodian investment programs.
E. Client Assets Under Management
As of December 31, 2023, IHT had $4,819,952,225 of discretionary and $510,351 of non-
discretionary assets under management.