Cypress Wealth Advisors, LLC

Firm Brochure - Form ADV Part 2A

 

 

 

This brochure provides information about the qualifications and business practices of Cypress Wealth Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at (210) 787-5410 or by email at: info@cypressria.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority.

 

Additional information about Cypress Wealth Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Cypress Wealth Advisors, LLC’s CRD number is: 166414

 

 

 

 

 

901 NE Loop 410, Suite 822

San Antonio, Texas, 78209

(210) 787-5410

info@cypressria.com

 

 

 

 

Registration does not imply a certain level of skill or training.

Version Date: 03/31/2017

 

Item 2: Material Changes

 

 

Item 4E.  Assets under Management updated to reflect client assets as of December 31, 2016.

 

 

 

Item 3: Table of Contents

 

Item 1: Cover Page

Item 2: Material Changes. i

Item 3: Table of Contents. ii

Item 4: Advisory Business. 1

A. Description of the Advisory Firm.. 1

B. Types of Advisory Services. 1

Investment Supervisory Services. 1

Financial Planning. 1

Services Limited to Specific Types of Investments. 2

C. Client Tailored Services and Client Imposed Restrictions. 2

D. Wrap Fee Programs. 2

E. Amounts Under Management2

Item 5: Fees and Compensation. 3

A. Fee Schedule. 3

Investment Supervisory Services Fees. 3

Financial Planning Fees. 4

Fixed Fees. 4

B. Payment of Fees. 4

Payment of Investment Supervisory Fees. 4

Payment of Financial Planning Fees. 4

C. Clients Are Responsible For Third Party Fees. 4

D. Prepayment of Fees. 5

E. Outside Compensation For the Sale of Securities to Clients. 5

Item 6: Performance-Based Fees and Side-By-Side Management5

Item 7: Types of Clients. 5

Minimum Account Size. 5

Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss. 6

A.             Methods of Analysis and Investment Strategies. 6

Methods of Analysis. 6

Charting analysis. 6

Fundamental analysis. 6

Technical analysis. 6

Cyclical analysis. 6

Investment Strategies. 6

B.              Material Risks Involved. 6

Methods of Analysis. 6

Fundamental analysis. 6

Technical analysis. 7

Cyclical analysis. 7

Investment Strategies. 7

C.              Risks of Specific Securities Utilized. 7

Item 9: Disciplinary Information. 8

A.             Criminal or Civil Actions. 8

B.              Administrative Proceedings. 8

C.              Self-regulatory Organization (SRO) Proceedings. 9

Item 10: Other Financial Industry Activities and Affiliations. 9

A.             Registration as a Broker/Dealer or Broker/Dealer Representative. 9

B.              Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor9

C.              Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests. 9

D.             Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections. 9

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. 9

A.             Code of Ethics. 9

B.              Recommendations Involving Material Financial Interests. 10

C.              Investing Personal Money in the Same Securities as Clients. 10

D.             Trading Securities At/Around the Same Time as Clients’ Securities. 10

Item 12: Brokerage Practices. 10

A.             Factors Used to Select Custodians and/or Broker/Dealers. 10

1.               Research and Other Soft-Dollar Benefits. 10

2.               Brokerage for Client Referrals. 11

3.               Clients Directing Which Broker/Dealer/Custodian to Use. 11

B.              Aggregating (Block) Trading for Multiple Client Accounts. 11

Item 13: Reviews of Accounts. 11

A.             Frequency and Nature of Periodic Reviews and Who Makes Those Reviews. 11

B.              Factors That Will Trigger a Non-Periodic Review of Client Accounts. 11

C.              Content and Frequency of Regular Reports Provided to Clients. 11

Item 14: Client Referrals and Other Compensation. 12

A.             Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes)12

B.              Compensation to Non – Advisory Personnel for Client Referrals. 12

Item 15: Custody. 12

Item 16: Investment Discretion. 12

Item 17: Voting Client Securities (Proxy Voting)12

Item 18: Financial Information. 13

A.             Balance Sheet13

B.              Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients. 13

C.              Bankruptcy Petitions in Previous Ten Years. 13

Item 19: Requirements For State Registered Advisers. 13

A.             Principal Executive Officers and Management Persons; Their Formal Education and Business Background. 13

B.              Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any)13

C.              How Performance-based Fees are Calculated and Degree of Risk to Clients. 13

D.             Material Disciplinary Disclosures for Management Persons of this Firm.. 14

E.              Material Relationships That Management Persons Have With Issuers of Securities (If Any)14

 

 

Item 4: Advisory Business

 

A. Description of the Advisory Firm

 

Cypress Wealth Advisors, LLC is a Limited Liability Company organized in the state of Texas.  The firm was formed in November of 2012, and the principal owner is Steven R. Parker.

 

B. Types of Advisory Services

 

Cypress Wealth Advisors, LLC (hereinafter “CWA”) offers the following services to advisory clients:

 

Investment Supervisory Services

CWA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client.  CWA constructs a detailed financial plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following:

 

            •          Investment strategy   •          Personal investment policy

            •          Asset allocation          •          Asset selection

            •          Risk tolerance             •          Regular portfolio monitoring

 

CWA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon.  CWA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are discussed with each client and documented in their respective files.

 

Financial Planning

 

Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. These services are based on fixed fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement.

 

 

 

 

 

 

Services Limited to Specific Types of Investments

 

CWA generally limits its money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, REITs, insurance products including annuities, and government securities.    CWA may use other securities as well to help diversify a portfolio when applicable.

 

C. Client Tailored Services and Client Imposed Restrictions

 

CWA offers the same suite of services to all of its clients.  However, specific client financial plans and their implementation are dependent upon the client’s needs and resources.

 

Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CWA from properly servicing the client account, or if the restrictions would require CWA to deviate from its standard suite of services, CWA reserves the right to end the relationship.

 

D. Wrap Fee Programs

 

A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. CWA does not participate in any wrap fee programs.

 

E. Amounts Under Management

 

As of December 31, 2015, CWA managed $64,683,497 in client assets. 

 

 

 

 

Item 5: Fees and Compensation

 

A. Fee Schedule


Investment Supervisory Services Fees

 

Total Assets Under Management

Annual Fee

First $1,000,000

1.20%

$1,000,001 - $1,750,000

0.95%

$1,750,001 - $2,750,000

0.75%

$2,750,001 - $5,000,000

0.65%

Above $5,000,000

0.45%


These fees are negotiable depending upon the needs of the client and complexity of the situation, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. CWA charges a minimum annual fee of $9,000.  For clients with insufficient assets to generate this minimum fee, we may charge 1.5% on client assets to qualify for the full suite of services provided, change the range of services provided, or some other negotiated combination of fees and services. 

 

Fees are paid quarterly in advance, and clients may terminate their contracts with thirty days’ written notice. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Client shall be given thirty (30) days’ prior written notice of any proposed increase in fees.

 

Refunds are given on a prorated basis, based on the number of days remaining in a quarter at the point of termination.  Fees that are collected in advance will be refunded based on the prorated amount of work completed up to the day of termination within the quarter terminated. The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the quarter up to and including the day of termination. (*The daily rate is calculated by dividing the quarterly AUM fee by the number of days in the termination quarter). Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract.

 

In cases where Advisor fees are directly deducted, Advisor is required to a.) Obtain client authorization, b.) Send a copy of the invoice to the client at the same time that the CWA directs invoice to the custodian for payment, c.) Disclose that the custodian will send quarterly invoices to the client wherein Advisor fees are itemized.

 

 

 

 

Financial Planning Fees

 

Fixed Fees

 

Depending upon the complexity of the situation and the needs of the client, the rate for creating client financial plans is between $1,250 and $10,000. Fees are paid in in advance, but never more than six months in advance, with theremainder due upon presentation of the plan. Fees that are charged in advance will be refunded based on the prorated amount of work completed at the point of termination. The fees are negotiable and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Clients may terminate their contracts without penalty within five business days of signing the advisory contract.

 

The fee refunded will be the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed up to and including the day of termination.

 

B. Payment of Fees

 

Payment of Investment Supervisory Fees

 

Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid quarterly in advance.

 

Advisory fees may also be invoiced and billed directly to the client quarterly in advance.   Clients may select the method in which they are billed.

 

Payment of Financial Planning Fees

 

Fixed Financial Planning fees are paid via check in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Fees that are charged in advance will be refunded based on the prorated amount of work completed at the point of termination.

 

C. Clients Are Responsible For Third Party Fees

 

Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by CWA.  Please see Item 12 of this brochure regarding broker/custodian.  CWA reserves the right to rebate some third party commissions on a negotiated basis. 

 


 

D. Prepayment of Fees

 

CWA collects fees in advance. Fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination and the total days during the billing period. Financial Planning Fees will be returned within fourteen days to the client via mailed check. Investment Supervisory Fees will be deposited back into client’s account within fourteen days.

 

The fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the quarter up to and including the day of termination. (*The daily rate is calculated by dividing the quarterly AUM fee by the number of days in the termination quarter).

 

E. Outside Compensation For the Sale of Securities to Clients

 

Neither CWA nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or services fees from the sale of mutual funds.

 

Item 6: Performance-Based Fees and Side-By-Side Management

 

CWA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client.

 

  Item 7: Types of Clients

 

CWA generally provides investment advice and/or management supervisory services to the following types of clients:

 

v  Individuals

v  High-Net-Worth Individuals

v  Corporations or Business Entities

 

Minimum Account Size

 

In order to meet our minimum annual fee of $9,000 at our standard fee rate, client assets should be more than $750,000.  CWA reserves the right to waive or otherwise modify minimum account size on a case by case basis. 

 

 

 

Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss

 

A.    Methods of Analysis and Investment Strategies

 

Methods of Analysis

 

CWA’s methods of analysis include charting analysis, fundamental analysis, technical analysis, and cyclical analysis. 

 

Charting analysis involves the use of patterns in performance charts.   CWA uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security.

 

Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages.

 

Technical analysis involves the analysis of past market data; primarily price and volume.

 

Cyclical analysis involved the analysis of business cycles to find favorable conditions for buying and/or selling a security.

 

Investment Strategies

 

CWA uses long term trading, short term trading , and options writing (including covered options, uncovered options, or spreading strategies).

 

Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.

 

B.     Material Risks Involved

 

Methods of Analysis

 

Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in solely using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case.

 

Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.

 

 

 

Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not work long term.

 

Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold : 1) the markets do not always repeat cyclical patterns and 2) if too many investors begin to implement this strategy, it changes the very cycles they are trying to take advantage of.

 

Investment Strategies

 

Long term trading is designed to capture market rates of both return and risk.  Frequent trading, when done, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes.

 

Short term trading and options writing generally hold greater risk and clients should be aware that there is a material risk of loss using any of those strategies.

 

Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.

 

C.    Risks of Specific Securities Utilized

 

CWA generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. However, it will utilize short sales and options writing. Short sales, margin transactions, and options writing generally hold greater risk of capital loss and clients should be aware that there is a material risk of loss using any of those strategies. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency.

 

Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns.  They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned above).

 

Equity investment generally refers to buying shares of stocks by an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the stock increases.  There is an innate risk involved when purchasing a stock that it may decrease in value and the investment may incur a loss.

 

Treasury Inflation Protected/Inflation Linked Bonds: The Risk of default on these bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal.

 

Fixed Income is an investment that guarantees fixed periodic payments in the future that may involve economic risks such as inflationary risk, interest rate risk, default risk, repayment of principal risk, etc.   

 

Debt securities carry risks such as the possibility of default on the principal, fluctuation in interest rates, and counterparties being unable to meet obligations.

 

Stocks & Exchange Traded Funds (ETF): Investing in stocks & ETF's carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy).

 

Real Estate funds face several kinds of risk that are inherent in this sector of the market. Liquidity risk, market risk and interest rate risk are just some of the factors that can influence the gain or loss that is passed on to the investor. Liquidity and market risk tend to have a greater effect on funds that are more growth-oriented, as the sale of appreciated properties depends upon market demand. Conversely, interest rate risk impacts the amount of dividend income that is paid by income-oriented funds.

 

REITs have specific risks including valuation due to cash flows, dividends paid in stock rather than cash, and the payment of debt resulting in dilution of shares.

 

Precious Metal ETFs (Gold, Silver, Palladium Bullion backed “electronic shares” not physical metal):  Investing in precious metal ETFs carries the risk of capital loss.

 

Long term trading is designed to capture market rates of both return and risk.  Due to its nature, the long-term investment strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk.

 

Short term trading risks include liquidity, economic stability and inflation. 

 

Options writing involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market.

 

Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.

 

Item 9: Disciplinary Information

 

A.    Criminal or Civil Actions

 

There are no criminal or civil actions to report.

 

B.     Administrative Proceedings

 

There are no administrative proceedings to report.

 

C.    Self-regulatory Organization (SRO) Proceedings

 

            There are no self-regulatory organization proceedings to report.

 

Item 10: Other Financial Industry Activities and Affiliations

 

A.    Registration as a Broker/Dealer or Broker/Dealer Representative

 

Neither CWA nor its representatives are registered as or have pending applications to become a broker/dealer or as representatives of a broker/dealer. 

 

B.     Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor

 

Neither CWA nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. 

 

C.    Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests

 

Neither CWA nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. 

 

D.    Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections

 

CWA does not utilize nor select other advisers or third party managers.  All assets are managed by CWA management.

 

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

 

A.    Code of Ethics

 

We have a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions.   Our Code of Ethics is available free upon request to any client or prospective client.

 

B.     Recommendations Involving Material Financial Interests

 

CWA does not recommend that clients buy or sell any security in which a related person to CWA or CWA has a material financial interest. 

 

C.    Investing Personal Money in the Same Securities as Clients

 

From time to time, representatives of CWA  may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of CWA  to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients.   Such transactions may create a conflict of interest. CWA  will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold.

 

D.    Trading Securities At/Around the Same Time as Clients’ Securities

 

From time to time, representatives of CWA may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of CWA to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest.  CWA will always transact client’s transactions before its own when similar securities are being bought or sold.

 

Item 12: Brokerage Practices

 

A.    Factors Used to Select Custodians and/or Broker/Dealers

 

The Custodian, TD Ameritrade Institutional, a Division of TD Ameritrade, Inc., member FINRA/SIPC/NFA., was chosen based on their relatively low transaction fees and access to mutual funds and ETFs. CWA will never charge a premium or commission on transactions, beyond the actual cost imposed by Custodian.

 

1.      Research and Other Soft-Dollar Benefits

 

CWA receives no research, product, or services other than execution from a broker-dealer or third-party in connection with client securities transactions (“soft dollar benefits”).

 

 

2.       Brokerage for Client Referrals

 

CWA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.

 

3.      Clients Directing Which Broker/Dealer/Custodian to Use

 

CWA will require clients to use a specific broker-dealer to execute transactions.

 

B.     Aggregating (Block) Trading for Multiple Client Accounts

 

CWA maintains the ability to block trade purchases across accounts.  Block trading may benefit a large group of clients by providing CWA the ability to purchase larger blocks resulting in smaller transaction costs to the client. Declining to block trade can cause more expensive trades for clients.

 

Item 13: Reviews of Accounts

 

A.    Frequency and Nature of Periodic Reviews and Who Makes Those Reviews

 

Client accounts are reviewed at least monthly only by Steven R. Parker, Managing Member. Steven R. Parker is the chief advisor and is instructed to review clients’ accounts with regard to clients’ respective investment policies and risk tolerance levels.  All accounts at CWA  are assigned to this reviewer. 

 

All financial planning accounts are reviewed upon financial plan creation and plan delivery by Steven R. Parker, Managing Member, or a qualified staff member. There is only one level of review and that is the total review conducted to create the financial plan.

 

 

B.     Factors That Will Trigger a Non-Periodic Review of Client Accounts

 

Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance).

 

C.    Content and Frequency of Regular Reports Provided to Clients

 

Each client will receive at least monthly from the custodian, a written report that details the client’s account including assets held and asset value which will come from the custodian.

 

Item 14: Client Referrals and Other Compensation

 

A.    Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes)

 

CWA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to CWA clients.

 

B.     Compensation to Non – Advisory Personnel for Client Referrals

 

CWA does not directly or indirectly compensate any person who is not advisory personnel for client referrals.

 

Item 15: Custody

 

CWA, with client written authority, has limited custody of client’s assets through direct fee deduction of CWA’s fees only. If the client chooses to be billed directly by TD Ameritrade Institutional, a Division of TD Ameritrade, Inc., member FINRA/SIPC/NFA., CWA would have constructive custody over that account and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy.

 

Item 16: Investment Discretion

                                                          

For those client accounts where CWA will have investment discretion, the client has given CWA written discretionary authority over the client’s accounts with respect to securities to be bought or sold and the amount of securities to be bought or sold.   Details of this relationship are fully disclosed to the client before any advisory relationship has commenced. The client provides CWA discretionary authority via a discretionary investment management clause in the Investment Advisory Contract and/or a limited power of attorney clause in the contract between the client and the custodian.

                                                     

Item 17: Voting Client Securities (Proxy Voting)

 

CWA will not ask for, nor accept voting authority for client securities.  Clients will receive proxies directly from the issuer of the security or the custodian.    Clients should direct all proxy questions to the issuer of the security. 

 

Item 18: Financial Information

 

A.    Balance Sheet

 

CWA does not require nor solicit prepayment of more than $500 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure.

 

B.     Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients

 

Neither CWA nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients.

 

C.    Bankruptcy Petitions in Previous Ten Years

 

 CWA has not been the subject of a bankruptcy petition in the last ten years.

 

Item 19: Requirements For State Registered Advisers

 

A.    Principal Executive Officers and Management Persons; Their Formal Education and Business Background

 

CWA currently has only one management person/executive officer; Steven R. Parker.   Steven R. Parker’s education and business background can be found on the Supplemental ADV Part 2B form.

 

B.     Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any)

 

Steven R. Parker’s other business activities can be found on the Supplemental ADV Part 2B form.

 

C.    How Performance-based Fees are Calculated and Degree of Risk to Clients

 

CWA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client.

 

D.    Material Disciplinary Disclosures for Management Persons of this Firm

 

No management person at CWA or CWA has been involved in an arbitration claim or been found liable in a civil, self-regulatory organization, or administrative proceeding that is material to the client’s evaluation of the firm or its management.

 

E.     Material Relationships That Management Persons Have With Issuers of Securities (If Any)

 

Neither CWA, nor its management persons, has any relationship or arrangement with issuers of securities.

 

 

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