A. Firm Information
Sightline Wealth Advisors LLC (“Sightline” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”)
under the laws of the State of Connecticut. Sightline became a registered investment advisor in April 2015.
Sightline is owned and operated by Stefan “Alex” Pellish (Principal and Chief Compliance Officer) and Mark J.
Steffen (Principal). This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by Sightline.
B. Advisory Services Offered
Sightline offers investment advisory services to individuals, high net worth individuals, trusts, estates and
businesses (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 towards each Client and seeks to mitigate potential
conflicts of interest. Sightline’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.
Sightline provides unbiased investment advice to help Clients achieve their financial goals. At Sightline, the
Advisor believes in a long-term approach to building Client wealth through a combination of passive and active
management, asset allocation, diversification, and risk management. The Advisor further believes that
investment management must be aligned with proper, ongoing financial planning to fully understand a Client’s
needs and to help them achieve and maintain their financial independence.
Sightline typically begins each Client engagement with a financial planning process to identify the Client’s goals
and time-based needs. Sightline will assist the Client in defining financial goals and formulating an investment
policy statement based on these goals and the Client’s financial situation, time horizon and tolerance to take
investment risk. Details of these services are described below.
Financial Planning Services
As noted above, Sightline generally conducts a formal financial planning process at the start of its relationship
each Client. Sightline will also provide a variety of financial planning services to individuals, families and
businesses separate from this process. The services are tailored to the specific needs of each Client. Services
are offered in several areas of a Client’s financial situation, depending on their goals and objectives.
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 to start or revise a Client’s investment programs, commence or alter retirement
savings, establish education savings and/or charitable giving programs. Sightline may also refer Clients to an
accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning
engagements, the Advisor will provide a written summary of a 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 months of 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 to maintain an ongoing relationship with the Advisor. If the Client
elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement
the transaction through the Advisor.
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Investment Management Services
Sightline provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary and/or non-discretionary investment
management and other related advisory services. Sightline works with each Client to identify investment goals,
objectives, risk tolerance and financial situation in order to create a long-term portfolio strategy. Sightline will then
construct a portfolio primarily comprised of exchange-traded funds (“ETFs”) and institutional or no-load mutual
funds to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, individual bonds,
covered options, and certificates of deposit to meet the needs of its Clients. In certain circumstances, the Advisor
may
also recommend alternative investments to meet the needs of a particular Client. The Advisor may retain
certain legacy investments based on portfolio fit and/or tax considerations.
Sightline will select, recommend, and/or retain, mutual funds on a fund-by-fund basis. Due to specific custodial
and/or mutual fund company constraints or material tax consideration, and/or systematic investment plans,
Sightline will select, recommend and/or retain a mutual fund share class that does not have trading costs, but do
have higher internal expense ratios than institutional share classes. Sightline 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 stated investment guidelines.
Sightline’s investment approach is 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. Sightline 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.
Sightline evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Sightline may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Sightline may recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a possible hedge against market movement. Sightline 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, change in risk tolerance of Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
At no time will Sightline accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement. For additional information, please see Item 12 –
Brokerage Practices.
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 a 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 will earn a
new (or increase 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.
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C. Client Account Management
Prior to engaging Sightline to provide investment advisory services, each Client is required to enter into one or
more advisory 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 Policy Strategy – Sightline, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Sightline will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk of each Client.
• Portfolio Construction – Sightline will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – Sightline will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Sightline does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by Sightline.
E. Assets Under Management
As of December 31, 2023, Sightline manages $242,397,670 in Client assets, $193,609,280 of which are
managed on a discretionary basis and $48,788,390 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.