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Form ADV Part 2A – Firm Brochure
Item 1: Cover Page
March 2025
1255 Coast Village Road, Suite 201A
Santa Barbara, CA 93108
Firm Contact:
Gene Dongieux
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Ariadne Wealth
Management, LP. If you have any questions about the contents of this brochure, please contact us by
telephone at (805) 456-4920 or info@ariadnewealth.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 Ariadne Wealth Management, LP also is available on the SEC’s website
at www.adviserinfo.sec.gov.
Please note that the use of the term “registered investment adviser” and description of Ariadne Wealth
Management, LP and/or our associates as “registered” does not imply a certain level of skill or training.
You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who
advise you for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Ariadne Wealth Management, LP is required to advise clients of any material changes to the Firm
Brochure (“Brochure”) from our last annual update.
Since the last annual amendment filing, the following material changes to report:
• We have added language to Item 8 below describing the risks of our use of illiquid private
securities in certain client accounts.
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Item 3: Table of Contents
Item 1: Cover Page ................................................................................................................................................................... 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ...................................................................................................................................................... 3
Item 4: Advisory Business .................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 6
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 7
Item 7: Types of Clients & Account Requirements ..................................................................................................... 7
Item 8: Method of Analysis, Investment Strategies & Risk of Loss ...................................................................... 8
Item 9: Disciplinary Information .................................................................................................................................... 10
Item 10: Other Financial Industry Activities & Affiliations ................................................................................. 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............ 10
Item 12: Brokerage Practices ........................................................................................................................................... 11
Item 13: Review of Accounts or Financial Plans ...................................................................................................... 14
Item 14: Client Referrals & Other Compensation .................................................................................................... 15
Item 15: Custody ................................................................................................................................................................... 15
Item 16: Investment Discretion ...................................................................................................................................... 16
Item 17: Voting Client Securities .................................................................................................................................... 16
Item 18: Financial Information ....................................................................................................................................... 17
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Item 4: Advisory Business
We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm has been registered as an Investment Adviser since August 2014. We were
formed as a California Limited Liability Company at that time and converted to a Limited Partnership
in 2018. The General Partner of our firm is Ariadne Wealth Holdings, LLC and our Limited Partners are
the Dongieux Family Trust, Rick DuBreuil, and Adam Stempel.
Description of the Types of Advisory Services We Offer
Comprehensive Wealth Management
Our Comprehensive Portfolio Management service encompasses asset management, financial
planning/financial consulting, pension consulting, and consideration of accounts held at another firm.
Asset Management:
It is designed to assist clients in meeting their financial goals through the use of financial investments.
We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via
telephone conference) with clients in order to understand their current financial situation, existing
resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment
approach to the client. We may propose an investment portfolio consisting of exchange traded funds
(“ETFs”), mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to
the proposed investment plan, we work with the client to establish or transfer investment accounts so
that we can manage the client’s portfolio. Once the relevant accounts are under our management, we
review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust
client accounts under our management. If the client experiences any significant changes to his/her
financial or personal circumstances, the client must notify us so that we can consider such information
in managing the client’s investments.
Our firm utilizes the sub-advisory services of a third-party investment advisory firm to aid in the
implementation of an investment portfolio designed by our firm. Before selecting a firm or individual,
our firm will ensure that the chosen party is properly licensed or registered. Our firm will not offer
advice on any specific securities or other investments in connection with this service. We will provide
initial due diligence on third party money managers and ongoing reviews of their management of client
accounts. In order to assist in the selection of a third-party money manager, our firm will gather client
information pertaining to financial situation, investment objectives, and reasonable restrictions to be
imposed upon the management of the account.
Our firm will periodically review third-party manager reports provided to the client at least annually.
Our firm will contact clients from time to time in order to review their financial situation and
objectives; communicate information to third-party money managers as warranted; and, assist the
client in understanding and evaluating the services provided by the third-party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
Financial Planning & Consulting:
As a part of this service, we provide financial planning and consulting services to individuals, families
and other clients regarding the management of their financial resources based upon an analysis of the
client’s current situation, goals, and objectives. Our Comprehensive Wealth Management service will
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involve preparing a financial plan and/or rendering a financial consultation for clients based on the
client’s financial goals and objectives. This planning or consulting may encompass one or more of the
following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning, Corporate Structure, Real Estate Analysis,
Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal
Financial Planning.
Our written financial plans usually include general recommendations for a course of activity or specific
actions to be taken by the clients. For example, recommendations may be made that the clients begin
or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage,
commence or alter retirement savings, or establish education or charitable giving programs. It should
also be noted that we refer clients to an accountant, attorney or other specialist, as necessary for non-
advisory related services. We provide our clients with a written summary of their financial situation,
observations, and recommendations. Implementation of the recommendations will be at the discretion
of the client.
Qualified Plan Asset Management:
We provide pension consulting services to employer plan sponsors on a one-time or ongoing basis as
a part of our Comprehensive Wealth Management Service. Generally, such pension consulting services
consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's
participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could
include: investment options, plan structure and participant education.
All pension consulting services shall be in compliance with the applicable state law(s) regulating
pension consulting services. This applies to client accounts that are pension or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services
to such accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA
(but only with respect to the provision of services described in section 1 of the Pension Consulting
Agreement).
Account Monitoring and Reporting:
We provide non-continuous and periodic outside account monitoring for assets not being managed by our
firm for consideration in the client’s overall financial plan. Portfolio Monitoring provides for no on-going
supervision, trading, or discretion with respect to securities transactions. Clients are responsible for
placing and executing their own trades, on their own.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Comprehensive Wealth Management
service.
Each client has the opportunity to place reasonable restrictions on the types of investments to be held in
the portfolio. Restrictions on investments in certain securities or types of securities may not be possible
due to the level of difficulty this would entail in managing the account. Restrictions would be limited
to our Comprehensive Wealth Management service.
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Participation in Wrap Fee Programs
We do not offer a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2024, we manage1 $539,312,768 which, $507,733,597 is managed on a
discretionary basis and $31,579,171 a non-discretionary basis.
Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
Comprehensive Wealth Management:
Fees for our Comprehensive Wealth Management service will be based on an individual fee schedule
for cost efficiency. All applicable fee schedules listed in the client agreement will be applied. The
maximum annual fee charged for this service will not exceed 1.00%. Our Qualified Plan Asset
Management fee, for our Pension Consulting Service, will be billed under the same fee schedules and
will not exceed 1.00% for any Plan.
Our firm’s fees are billed on a pro-rata annualized basis quarterly in arrears based on the time-
weighted daily average value of client account during the previous quarter. Fees may be negotiable
depending on the scope of the engagement. Unless otherwise agreed to in writing, fees will be
applicable on cash and cash equivalents. Fees will generally be automatically deducted from client’s
managed account, clients may elect invoice billing. As part of this process, the client is made aware of
the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Fees for third party management services will be separate and in addition to our firm’s advisory fee.
These fees will be outlined in a separate agreement between client and the chosen manager.
When Portfolio Monitoring is applicable, those fees will be billed on a pro-rata annualized basis
quarterly in arrears based on the value of client account on the last day of the quarter. We will directly
bill clients for this service, which is due and payable within thirty (30) days.
1 Please note that our method for computing the amount of “client assets we manage” can be different from the method for computing “assets
under management” required for Item 5.F in Part 1A of Form ADV. We have chosen to follow the method outlined for Item 5.F in Part 1A of
Form ADV. If we decide to use a different method at a later date to compute “client assets we manage,” we must keep documentation
describing the method we use and inform you of the change. The amount of assets we manage may be disclosed by rounding to the nearest
$100,000. Our “as of” date must not be more than three months before the date we last updated our Brochure in response to Item 4.E of Form
ADV Part 2A.
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Ariadne Wealth Management, LP
Financial Planning & Consulting:
Financial planning and consulting services are included in Wealth Management Fees for all clients.
Clients must opt into these services. Additionally, we may provide ancillary Financial Planning or
Consulting services for a flat, hourly, or asset-based fee. The exact terms and conditions of these
arrangements shall be spelled out in the executed advisory agreement.
Qualified Plan Asset Management:
Fees for this service are billed as a fee based on the percentage of Plan assets under management. The
total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. Fees based on a percentage of managed Plan assets will be billed quarterly
in arrears and shall not exceed 1.00%.
Account Monitoring & Reporting
Where available, we will link outside account with our data aggregation software to provide clients
with a wholistic picture of their financial portfolio. For this service we will charge a supplementary fee
of 10 basis points of the outside account value.
Other Types of Fees & Expenses
Clients will incur transaction charges for trades executed in their accounts. These transaction fees are
separate from our fees and will be disclosed by the firm executing the trades. Charles Schwab & Co.,
Inc. (“Schwab”) and Interactive Brokers do not charge transaction fees for U.S. listed equities and
exchange traded funds. Also, clients will pay the following separately incurred expenses, which we do
not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded
fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund
expenses).
Termination & Refunds
We charge our advisory fees quarterly in arrears. If client wishes to terminate our services, they are to
submit a letter stating their intention to cancel the advisory agreement. Upon receipt of client letter of
termination, we will proceed to close out client accounts and charge a pro-rata advisory fee(s) for
services rendered up to the point of termination.
Commissionable Securities Sales
We do not sell securities for a commission in our advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
We do not accept performance-based fees.
Item 7: Types of Clients & Account Requirements
We have the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
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• Pension and Profit Sharing Plans; and
• Corporations, Limited Liability Companies and/or Other Business Types
Our requirements for opening and maintaining accounts or otherwise engaging us:
• We require a minimum household balance of $10,000,000 for our Comprehensive Wealth
Management service. This requirement may be waived on a case-by-case basis.
Item 8: Method of Analysis, Investment Strategies & Risk of Loss
Our investment process integrates both quantitative and qualitative elements.
The quantitative process is data-driven. We analyze current performance, back-tested performance,
out-of-sample data, regression models, volatility, skew, kurtosis and more to understand how a
strategy performs on its own as well as in a portfolio of different assets. We analyze the data to ensure
a strategy is fulfilling its mandate and to keep our managers and ourselves accountable. We also look
to quantitative research in trade and academic journals to ensure we are on the cutting edge of
investing.
The qualitative element of our investing process uses our expert judgment to remain skeptical. We
always ask ourselves, “Why did this strategy have success?” and “Will that success persist in the
future?” Occasionally we will encounter a strategy whose performance and data is strong, but its
rationale is weak. Our qualitative judgment based on our many years of experience helps us parse
through conflicting information.
Once strategies have passed our quantitative and qualitative screens, we analyze the investment
options available e.g. individual securities, institutional mutual funds, ETFs etc. We carefully weigh
the various pros and cons of the of the investment solution. We also analyze the tax costs of the product
to identify whether it is more appropriate in taxable or tax-deferred accounts. Identifying every client’s
unique tax situation and by strategically placing suitable investments in their accounts helps increase
after-tax investment returns.
Risk of Loss
Investors should be aware that all investing involves risk at some level. There is a myriad of investment
risk levels ranging from conservative short-term highly rated U.S. Treasury bonds to volatile emerging-
market stocks. Even when diversified portfolios are built using well-thought-out combinations,
investment risk persists. Below are specific risks pertinent to some types of securities or strategies
that we recommend in client portfolios:
Interval funds can expose investors to liquidity risk, and that risk is greater in funds that invest in
securities of companies with smaller market capitalizations, derivatives or securities with substantial
market and/or credit risk. Even though interval funds make periodic offers to repurchase a portion of
outstanding shares, investors should consider interval fund shares to be an illiquid investment. There
is no guarantee that investors will be able to sell interval fund shares at any given time or in the
quantity that they desire. The price that shareholders will receive on a repurchase will be based on the
per share NAV determined as of a specified date. This date will occur sometime after the close of
business on the date that shareholders must submit their acceptances of the repurchase offer so
investor may not know the exact price they will receive for their redemption when effecting the
transaction. Additionally, this price may be subject to a redemption fee that further erodes the value
of the position upon redemption.
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Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”), Business Development
Companies (“BDCs”), and other alternative investments involve a high degree of risk and can be illiquid
due to restrictions on transfer and lack of a secondary trading market. They can be highly leveraged,
speculative and volatile, and an investor could lose all or a substantial amount of an investment.
Alternative investments may lack transparency as to share price, valuation and portfolio holdings.
Complex tax structures often result in delayed tax reporting. Compared to mutual funds, hedge funds
and commodity pools are subject to less regulation and often charge higher fees and may require
“capital calls” which would require additional investment. Alternative investment managers typically
exercise broad investment discretion and may apply similar strategies across multiple investment
vehicles, resulting in less diversification.
Private Funds pool capital from a number of investors and invest in securities and other instruments.
In almost all cases, a private fund is a private investment vehicle that is typically not registered under
federal or state securities laws. So that private funds do not have to register under these laws, issuers
make the funds available only to certain sophisticated or accredited investors and cannot be offered
or sold to the general public. Private funds are generally smaller than mutual funds because they are
often limited to a small number of investors and have a more limited number of eligible investors.
Many but not all private funds use leverage as part of their investment strategies. Private funds
management fees typically include a base management fee along with a performance component. In
many cases, the fund’s managers may become “partners” with their clients by making personal
investments of their own assets in the fund. Most private funds offer their securities by providing an
offering memorandum or private placement memorandum, known as “PPM” for short.
The PPM covers important information for investors and investors should review this document
carefully and should consider conducting additional due diligence before investing in the private fund.
The primary risks of private funds include the following: (a) Private funds do not sell publicly and are
therefore illiquid. An investor may not be able to exit a private fund or sell its interests in the fund
before the fund closes.; and (b) Private funds are subject to various other risks, including risks
associated with the types of securities that the private fund invests in or the type of business issuing
the private placement.
Our firm may purchase securities for your portfolio with money borrowed from your brokerage
account. This allows you to purchase more stock than you would be able to with your available cash
and allows us to purchase securities without selling other holdings. Margin accounts and transactions
are risky and not necessarily appropriate for every client. It should be noted that our firm bills advisory
fees on securities purchased on margin which creates a financial incentive for us to utilize margin in
client accounts.
The potential risks associated with these transactions are (1) You can lose more funds than are
deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3)
the sale of securities or other assets without contacting you; (4) you may not be entitled to choose
which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and (5)
custodians charge interest on margin balances which will reduce your returns over time.
Cash Management
We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit,
high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to
achieve the highest return on our client’s cash balances through relatively low-risk conservative
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investments. In most cases, at least a partial cash balance will be maintained in a money market
account so that our firm may debit advisory fees for our services related to Asset Management, as
applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Our firm has no other financial industry activities and affiliations to disclose.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
does not endanger the interest of any client. At the same time, we believe that if investment goals are
similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities.
Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-
clearing procedure) with respect to transactions effected by our members, officers and employees for
their personal accounts2. In order to monitor compliance with our personal trading policy, we have a
quarterly securities transaction reporting system for all of our associates.
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An
investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to
provide fair and full disclosure of all material facts and to act solely in the best interest of each of our
clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core
underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities
Transactions Policies and Procedures. We require all of our supervised persons to conduct business with
the highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an
acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm
and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.
Related persons of our firm may buy or sell securities for themselves at or about the same time they buy
or sell the same securities for client accounts. In order to minimize this conflict of interest, our related
persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a
copy of which is available upon request. Further, our related persons will refrain from buying or selling
the same securities within 24 hours prior to buying or selling for our clients. If related persons’ accounts
are included in a block trade, our related persons will always trade personal accounts last.
2 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her
minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate
controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial
interest in.
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This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a
potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon
request. Neither our firm nor a related person recommends to clients, or buys or sells for client
accounts, securities in which our firm or a related person has a material financial interest.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Custodian & Brokers Used
Our firm does not maintain custody of client assets (although our firm may be deemed to have custody
of client assets if given the authority to withdraw assets from client accounts. See Item 15 Custody,
below). Client assets must be maintained in an account at a “qualified custodian,” generally a broker-
dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division of Charles
Schwab & Co. Inc. (“Schwab”), Fidelity Brokerage Services, LLC (“Fidelity”) or Interactive Brokers, LLC
(“Interactive”) FINRA-registered broker-dealers, members SIPC, as the qualified custodians
(collectively “Custodians”). Our firm is independently owned and operated, and not affiliated with the
Custodians. Custodians will hold client assets in a brokerage account and buy and sell securities when
instructed. While our firm recommends that clients use these Custodians as custodian/broker, clients
will decide whether to do so and open an account with Custodians by entering into an account
agreement directly with them. Our firm does not open the account. Even though the account is
maintained with Custodians, our firm can still use other brokers to execute trades, as described in the
next paragraph.
How Brokers/Custodians Are Selected
Our firm seeks to recommend a custodian/broker who will hold client assets and execute transactions
on terms that are overall most advantageous when compared to other available providers and their
services. A wide range of factors are considered, including, but not limited to:
•
•
•
combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds, exchange traded
funds (ETFs), etc.)
• availability of investment research and tools that assist in making investment decisions quality
•
of services
competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate them
reputation, financial strength and stability of the provider
•
• prior service to our firm and our other clients
• availability of other products and services that benefit our firm, as discussed below (see
“Products & Services Available from Custodians”)
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Custody & Brokerage Costs
Custodians generally do not charge a separate for custody services, but is compensated by charging
commissions or other fees to clients on trades that are executed or that settle into the account. In
addition to commissions, Custodians charge a flat dollar amount as a “prime broker” or “trade away”
fee for each trade that our firm has executed by a different broker-dealer but where the securities
bought or the funds from the securities sold are deposited (settled) into the account. These fees are in
addition to the commissions or other compensation paid to the executing broker-dealer. Because of
this, in order to minimize client trading costs, our firm has the chosen custodial platform execute most
trades for the accounts.
Products & Services Available from Custodians
Custodians provide our firm and clients with access to their institutional brokerage – trading, custody,
reporting and related services – many of which are not typically available to retail customers. They
also makes available various support services. Some of those services help manage or administer our
client accounts while others help manage and grow our business. Custodians’ support services are
generally available on an unsolicited basis (our firm does not have to request them) and at no charge
to our firm. The availability of these products and services is not based on the provision of particular
investment advice, such as purchasing particular securities for clients. Here is a more detailed
description of these support services:
Services that Benefit Clients
Custodians’ institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Custodians include some to which our firm might not otherwise have access or that would
require a significantly higher minimum initial investment by firm clients. Custodians’ services
described in this paragraph generally benefit clients and their accounts.
Services that May Not Directly Benefit Clients
Custodians also make available other products and services that benefit our firm but may not directly
benefit clients or their accounts. These products and services assist in managing and administering
our client accounts. They include investment research, both Custodians’ and that of third parties. This
research may be used to service all or some substantial number of client accounts, including accounts
not maintained at Custodians. In addition to investment research, Custodians also makes available
software and other technology that:
• provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
facilitates payment of our fees from our clients’ accounts; and
•
• provides pricing and other market data;
•
• assists with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Our Firm
Custodians also offer other services intended to help manage and further develop our business
enterprise. These services include:
• educational conferences and events
•
technology, compliance, legal, and business consulting;
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• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance providers.
Custodians may provide some of these services themselves. In other cases, Custodians will arrange for
third-party vendors to provide the services to our firm. Custodians may also discount or waive fees for
some of these services or pay all or a part of a third party’s fees. Custodians may also provide our firm
with other benefits, such as occasional business entertainment for our personnel.
Irrespective of direct or indirect benefits to our client through Custodians, our firm strives to enhance
the client experience, help clients reach their goals and put client interests before that of our firm or
associated persons.
Our Interest in Custodians’ Services.
The availability of these services from Custodians benefits our firm because our firm does not have to
produce or purchase them. Our firm does not have to pay for these services, and they are not
contingent upon committing any specific amount of business to Custodians in trading commissions or
assets in custody.
In light of our arrangements with Custodians, a conflict of interest exists as our firm may have incentive
to require that clients maintain their accounts with Custodians based on our interest in receiving
Custodians’ services that benefit our firm rather than based on client interest in receiving the best
value in custody services and the most favorable execution of transactions. As part of our fiduciary
duty to our clients, our firm will endeavor at all times to put the interests of our clients first. Clients
should be aware, however, that the receipt of economic benefits by our firm or our related persons
creates a potential conflict of interest and may indirectly influence our firm’s choice of Custodians as a
custodial recommendation. Our firm examined this potential conflict of interest when our firm chose to
recommend Custodians and have determined that the recommendation is in the best interest of our firm’s
clients and satisfies our fiduciary obligations, including our duty to seek best execution.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions. Our firm believes that the selection of Custodians as a custodian and broker is the best
interest of our clients. It is primarily supported by the scope, quality and price of Custodians’ services,
and not Custodians’ services that only benefit our firm.
Client Brokerage Commissions
We do not acquire client brokerage commissions (or markups or markdowns).
Procedures to Direct Client Transactions in Return for Soft Dollars
We do not direct client transactions to a particular broker-dealer in return for soft dollar benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
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Ariadne Wealth Management, LP
Directed Brokerage
We routinely recommend that a client directs us to execute through a specified broker-dealer. Our firm
recommends the use of Schwab, Fidelity and Interactive Brokers. Each client will be required to establish
their account(s) with one of these platforms if not already done. We will occasionally direct certain bond
trades to outside dealers when doing so will result in more favorable execution for our clients on a case
by case basis.
Permissibility of Client-Directed Brokerage
We allow clients to direct brokerage outside our recommendation. However, we may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost clients
more money. For example, in a directed brokerage account, you may pay higher brokerage
commissions because we may not be able to aggregate orders to reduce transaction costs, or you may
receive less favorable prices.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through
a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is
permitted provided that the goods and services provided are reasonable expenses of the plan incurred
in the ordinary course of its business for which it otherwise would be obligated and empowered to
pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not
for the exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan
brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit
of the plan.
Aggregation of Purchase or Sale
We perform investment management services for various clients. There are occasions on which portfolio
transactions may be executed as part of concurrent authorizations to purchase or sell the same security
for numerous accounts served by our firm (“block trade”). When such block trades occur, the objective is
to execute trades in a manner which is deemed equitable to the accounts involved when we believe that
to do so will be in the best interest of the effected accounts.
Item 13: Review of Accounts or Financial Plans
We review accounts on at least a quarterly basis for our clients subscribing to our Comprehensive
Wealth Management service. The nature of these reviews is to learn whether clients’ accounts are in
line with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable. Clients will receive performance reports on a quarterly basis. Clients
will also receive a financial plan as a part of our Comprehensive Wealth Management service. Financial
Plans will be reviewed and updated as things change in the client’s circumstances. Verbal reports to
clients take place on at least an annual basis when we contact clients who subscribe to this service.
We may review client accounts more frequently than described above. Among the factors which may
trigger an off-cycle review are major market or economic events, the client’s life events, requests by
the client, etc.
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Ariadne Wealth Management, LP
Item 14: Client Referrals & Other Compensation
Charles Schwab & Co., Inc./ Fidelity Brokerage Services, LLC / Interactive Brokers LLC
We receive an economic benefit from Schwab, Fidelity, and Interactive in the form of the support
products and services they make available to us and other independent investment advisors that have
their clients maintain accounts at their respective platforms. These products and services, how they
benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices).
The availability to us of these products and services is not based on us giving particular investment
advice, such as buying particular securities for our clients.
While we recommend that you use these platforms as custodian/broker, you will decide whether to
do so and open your account with them by entering into an account agreement directly with them. We
do not open the account for you, we will facilitate the process. Even though your account is maintained
at Schwab, Fidelity, or Interactive, we can still use other brokers to execute trades for your account.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Our firm does not have custody of client funds or securities (except in the limited case of Standing
Letters of Authorization as described below). All of our clients receive account statements directly
from their qualified custodians at least quarterly upon opening of an account. Clients are encouraged
to raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under
the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody
Rule as well as clarified that an adviser who has the power to disburse client funds to a third party
under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has
adopted the following safeguards in conjunction with our custodian:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified
custodian’s form or separately, to direct transfers to the third party either on a specified
schedule or from time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such
as a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of
the third party, the address, or any other information about the third party contained in
the client’s instruction.
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Ariadne Wealth Management, LP
• The investment adviser maintains records showing that the third party is not a related
party of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming
the instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, we are
authorized to execute securities transactions, which securities are bought and sold, the total amount
to be bought and sold, and the costs at which the transactions will be effected. Limitations may be
imposed by the client in the form of specific constraints on any of these areas of discretion with our
firm’s written acknowledgement.
Item 17: Voting Client Securities
SEC Rule 206(4)-6 requires investment advisers who have voting authority with respect to securities
held in their clients’ accounts to monitor corporate actions and vote proxies in their clients’
interests. Our firm is required by the SEC to adopt written policies and procedures, make those policies
and procedures available to clients, and retain certain records with respect to proxy votes cast.
Our firm considers proxy voting an important right of our clients as shareholders and believe that
reasonable care and diligence must be taken to ensure that such rights are properly and timely
exercised. When our firm has discretion to vote the proxies of our clients, our firm will vote those
proxies in the client’s best interests and in accordance with these policies and procedures or abstain if
we determine the issue non-material to our client’s interests. Clients may request a copy of our written
policies and procedures regarding proxy voting and/or information on how particular proxies were
voted by contacting our Chief Compliance Officer, Gene Dongieux, by phone at 805-456-4900 or email
at gene@ariadnewealth.com.
Policy for Voting Proxies
Our firm votes client proxies when authorized to do so in writing by a client. Our firm understands our
duty to vote client proxies and to do so in the best interest of our clients. Furthermore, it is understood
that any material conflicts between our interests and those of our clients with regard to proxy voting
must be resolved before proxies are voted. Our firm subscribes to a proxy monitor and voting agent
service offered by Broadridge Investor Communication Solutions, Inc. (“Broadridge”), which includes
access to proxy analyses with research and vote recommendations from Glass, Lewis & Co. (“Glass
Lewis”). Our firm will generally vote in accordance with the recommendations of Glass Lewis, but may
vote in a different fashion on particular votes if our firm determines that such actions are in the best
interest of our clients. Where applicable, our firm will consider any specific voting guidelines
designated in writing by a client. Clients may request a copy of our written policies and procedures
regarding proxy voting and/or information on how particular proxies were voted by contacting our
Chief Compliance Officer, Gene Dongieux, by phone at 805-456-4900 or email at
gene@ariadnewealth.com.
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Ariadne Wealth Management, LP
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition that is reasonably likely to impair our ability to
meet contractual commitments.
• Our firm has never been the subject of a bankruptcy proceeding.
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Ariadne Wealth Management, LP