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EVOKE ADVISORS
Disclosure Brochure
EVOKE WEALTH, LLC
d/b/a
EVOKE ADVISORS
FORM ADV PART 2A
BROCHURE
Item 1 – Cover Page
March 28, 2025
10635 Santa Monica Blvd., Suite 240
Los Angeles, California 90025
(424) 372-1776
This brochure (“Brochure”) provides information about the qualifications and business practices of Evoke
Wealth, LLC. If you have any questions regarding the contents of this brochure, please do not hesitate to
contact our Chief Compliance Officer by telephone at (424) 372-1776. 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.
information about Evoke Wealth, LLC
is available on
Evoke Wealth, LLC is a registered investment advisor. Registration with the United States Securities and
Exchange Commission or any state securities authority does not imply a certain level of skill or training.
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
EVOKE ADVISORS
Disclosure Brochure
Item 2 – Material Changes
Form ADV Part 2 requires registered investment advisors to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an advisor’s disclosure brochure, the
advisor is required to notify you and provide you with a description of the material changes.
Evoke Wealth, LLC has made the following material changes since our last filing dated October 7, 2024
was filed:
• We have updated Item 4 of this Brochure to reflect that as of December 31, 2024 Evoke
manages approximately $12,453,071,296 on a discretionary basis and $15,242,414,286 on a
non-discretionary basis.
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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 and Compensation ................................................................................................................. 11
Item 6 - Performance-Based Fees and Side-by-Side Management ............................................................. 14
Item 7 - Types of Clients ............................................................................................................................ 15
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss .................................................... 15
Item 9 – Disciplinary Information .............................................................................................................. 23
Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 23
Item 11 – Code of Ethics, Participation or Interest in Client Transactions ................................................. 25
Item 12 – Brokerage Practices .................................................................................................................... 26
Item 13 – Review of Accounts .................................................................................................................... 30
Item 14 – Client Referrals and Other Compensation .................................................................................. 30
Item 15 – Custody ....................................................................................................................................... 31
Item 16 – Investment Discretion ................................................................................................................. 32
Item 17 – Voting Client Securities .............................................................................................................. 32
Item 18 – Financial Information ................................................................................................................. 32
EVOKE ADVISORS
Disclosure Brochure
Item 4 - Advisory Business
A. Description of the Advisory Firm
Evoke Wealth, LLC d/b/a Evoke Advisors (“EVOKE” or the “Firm”) is a limited liability company
organized in Delaware. EVOKE is an investment advisory firm registered with the United States Securities
and Exchange Commission (“SEC”). EVOKE is owned by Evoke Holdings, LLC with a 1% minority
interest held by passive estate planning entities owned by Mr. David Hou and Mr. Mark Sear through their
trusts. The principal owner of Evoke Holdings, LLC as of the time of this Brochure filing is David Hou.
B. Types of Advisory Services
EVOKE provides holistic and personalized financial planning and discretionary and non-discretionary
investment advisory services to individuals, including high and ultra-high net worth individuals, and
entities, including, but not limited to, family offices, trusts, and estates. EVOKE also offers consulting and
advisory services to pension and retirement/profit-sharing plans, pooled investment vehicles, foundations,
endowments, charitable organizations, guilds and health plans, investment companies, family offices,
corporations, and other business entities.
Financial Planning and Consulting Services
EVOKE provides a variety of comprehensive financial planning and consulting services to clients. Such
engagements may be part of the investment advisory engagement, or pursuant to a written Family Office
Services Agreement (“FOSA”), or pursuant to a separate engagement. Generally, such financial planning
services will involve preparing a financial plan or rendering a financial consultation based on the client’s
financial goals and objectives. This planning or consulting may encompass one or more areas of need,
including, but not limited to, cash flow analysis, investment planning, retirement planning, estate planning,
personal savings, educational savings, and other areas of a client’s financial situation.
This planning or consulting may encompass one or more areas of need, including but not limited to the
following:
• Tax planning
• Estate planning
• Philanthropic planning
• Generational involvement and planning
• Risk management & insurance coverages
• Cash flow planning & management
• Business management and consulting services
A financial plan developed for, or financial consultation rendered to, a client will typically include general
recommendations for a course of activity or specific actions to be taken by the client. For example,
recommendations may be made that the client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs. EVOKE may
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recommend the services of itself and/or other professionals to implement its recommendations. Clients are
advised that a conflict of interest exists if EVOKE recommends its own services, as such a recommendation
may increase the advisory fees paid to EVOKE. The client is under no obligation to act upon any of the
recommendations made by EVOKE under a financial planning or consulting engagement to engage the
services of any such recommended professional, including EVOKE itself.
Investment Management Services
EVOKE seeks to tailor its investment management services to meet the needs of its individual clients and
seeks to manage client portfolios in a manner consistent with those needs and objectives. EVOKE consults
with clients on an initial and periodic basis to assess their specific risk tolerance, time horizon, liquidity
constraints, and other related factors relevant to the management of their portfolios. Clients are advised to
promptly notify EVOKE if there are changes in their financial situation or if they wish to place any
limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates
on the management of their accounts if EVOKE determines, in its sole discretion, the conditions would not
materially impact the performance of a management strategy or prove overly burdensome to EVOKE’s
management efforts.
In designing and implementing customized models and portfolio strategies, EVOKE can manage, on a
discretionary or non-discretionary basis, a broad range of investment strategies and vehicles. EVOKE
primarily allocates client assets among various investment managers’ mutual funds, exchange-traded funds
(“ETFs”), closed-end funds (“CEFs”), structured products, options, debt securities, and alternative
investments in accordance with clients’ stated investment objectives, risk profile and financial condition.
EVOKE may recommend to clients that all or a portion of their investment portfolio be managed on a
discretionary basis by one or more unaffiliated or affiliated money managers or investment platforms
(“External Managers”). The client may be required to enter into a separate agreement with the External
Manager(s), which will set forth the terms and conditions of the client’s engagement of the External
Manager. In addition to this Brochure, clients may also receive the written disclosure documents of the
respective External Managers engaged to manage their assets. EVOKE generally renders services to the
client relative to the discretionary selection of External Managers. EVOKE also assists in establishing the
client’s investment objectives for the assets managed by External Managers, monitors and reviews the
account performance and defines any restrictions on the account. The investment management fees charged
by the designated External Managers, together with the fees charged by the corresponding designated
broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, advisory fees charged
by EVOKE. EVOKE evaluates a variety of information about External Managers, which may include the
External Managers’ public disclosure documents, materials supplied by the External Managers themselves
and other third-party analyses it believes are appropriate and reputable. To the extent possible, EVOKE
seeks to assess the External Managers’ investment strategies, past performance, and risk results in relation
to its clients’ individual portfolio allocations and risk exposure. EVOKE also takes into consideration each
External Manager’s management style, returns, reputation, financial strength, reporting, pricing, and
research capabilities, among other factors.
EVOKE may also recommend that clients invest in unaffiliated or affiliated private investment vehicles
whose interests are not publicly offered under the Securities Act of 1933 (“Private Funds”). Such Private
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Funds may be structured as fund of funds or as access vehicles to underlying funds or portfolios managed
by third-party investment advisors. EVOKE will, from time to time and as appropriate, solicit clients to
invest in such vehicles, and EVOKE will decide which clients to approach for some or all of these
investments at its own discretion. All relevant information pertaining to Private Fund recommendations,
including the compensation received by EVOKE (if any) or an EVOKE affiliate or related person (as
applicable), and by the third-party manager resulting from a client’s investment in a Private Fund, other
fees and expenses paid by the respective Private Fund, withdrawal rights, minimum investments,
qualification requirements, suitability, risk factors, and potential conflicts of interest is set forth in the
respective Private Fund’s disclosure documents, governing documents and other offering materials
pertaining to such interests (the “Offering Materials”). Each investor is required to receive, review, and
execute (as applicable) the Offering Materials prior to being accepted as an investor in any such Private
Fund.
It is important to note that any EVOKE advisory fee charged to clients for investing in a Private Fund is in
addition to the fees charged by the Private Funds to investors. This is a conflict of interest with the multiple
fees charged because EVOKE affiliates may serve as general partners of affiliated Private Funds and will
receive multiple forms of compensation. It should also be noted that certain members of EVOKE may
directly participate in any of the investment opportunities described for which an affiliated Private Fund is
established and/or may participate through the Private Fund itself for the purposes of investing. This right
to participate and any corresponding economic interest therefrom will likely mean that certain members of
EVOKE will derive a direct or indirect benefit from their direct participation and may also receive
management fees, carried interest, and other fees that a Private Fund charges to investors and clients for
their participation in the respective investment opportunity. As such, a conflict of interest arises between
the presentation of a private market investment opportunity to EVOKE clients and prospective clients, and
those members of EVOKE who will have an interest in the alternative investment opportunity and who,
through an affiliated Private Fund, may also be charging clients and investors a variety of fees for
investment in the respective investment opportunity. Therefore, it should be understood that members of
EVOKE may be highly incentivized to recommend an alternative investment opportunity to clients. Clients
are strongly advised and encouraged to discuss this conflict of interest with their advisors and to assess the
risks, merits, charges, suitability, and appropriateness of the opportunity prior to making any investment
decision.
Sub-Advisory Services
Evoke provides the above-mentioned Investment Management Services as contracted with one or more
established insurance carriers for the purpose of supporting certain benefits payable under one or more
variable life insurance, variable annuity, or other variable insurance policies as characterized under Section
817(d) of the U.S. Internal Revenue Code of 1986, as amended (the “Code”) as a “variable contact” (each
a “Contract”) issued by the Carriers to the Contract owners (each, a “Contract Owner”). These services are
provided pursuant to Investment Policy Statements as agreed upon with each carrier.
ERISA Services
EVOKE can provide either discretionary or non-discretionary, fiduciary, and non-fiduciary advisory
services to the sponsors of defined contribution, defined benefit and non-qualified deferred compensation
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plans, who in certain circumstances have ultimate authority to direct the investing and reinvesting of plan
assets as they deem appropriate, considering each plan’s stated objective, liquidity needs, stated policies
and guidelines. Providing investment services to plans under the Employee Retirement Income Security
Act of 1974, as amended (“ERISA”), means that the ERISA plan client retains and exercises the final
decision-making authority for implementing or rejecting EVOKE’s recommendations. Certain of the
foregoing services are provided by EVOKE as a fiduciary. When EVOKE provides investment advice for
a fee to an ERISA plan or ERISA plan participant, it is a fiduciary under ERISA. In addition, EVOKE is a
fiduciary under the Internal Revenue Code when it provides investment advice to an ERISA plan, ERISA
plan participant, an IRA, or an IRA owner (collectively, a “Retirement Account Client”). EVOKE is subject
to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other
things, prohibited transaction rules which are intended to prohibit fiduciaries from engaging in specified
conflicts of interest.
Retirement Plan and Investment Consulting Services
EVOKE also offers clients a broad range of retirement plan and investment consulting services, which may
include advice regarding asset allocation, manager selection, and investment risk management, among other
areas.
EVOKE may recommend clients engage the Firm for additional related services and/or other professionals
to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage
EVOKE or its affiliates to provide additional services for compensation. Clients retain absolute discretion
over all decisions regarding implementation and are under no obligation to act upon any of the
recommendations made by EVOKE under a retirement plan or investment consulting engagement. In
performing these services, EVOKE is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely
on such information. Clients are advised that it remains their responsibility to promptly notify the Firm of
any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or
revising EVOKE’s’ recommendations and/or services.
Evoke engages with retirement plan Clients in a wide range of capacities. For plans subject to the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”), this could include serving as an ERISA
Section 3(21) fiduciary providing investment recommendations to the plan sponsor and/or plan trustee, or
as an ERISA Section 3(38) “investment manager” with discretionary authority to make investment
decisions on behalf of the plan. In addition to allocating plan assets and portfolio management, these
services can include assistance in setting up an Investment Policy Statement for the portfolio, managing
cash and liquidity needs, selecting professional record‐keepers, administrators and custodians, and
providing in depth quarterly or annual review with the portfolio’s performance and our outlook on financial
market conditions. In addition, Evoke has adopted policies and procedures designed to comply with the
ERISA fiduciary standards when advising retirement asset rollovers as set forth in the Department of Labor
Fiduciary Rule (“DOL PTE Rule”). Clients will be presented with disclosure documents as prescribed by
the DOL PTE Rule.
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Advisory Services to Proprietary Funds
EVOKE has entered into an investment management agreement with Advanced Research Alpha Fund, L.P.
and Advanced Research Alpha Fund, Ltd. in addition to certain feeder fund vehicles for which Evoke’s
affiliate, EVOKE GP, LLC serves as the general partner. EVOKE provides investment management and
advisory services to these funds through their investment in other privately offered investment funds.
Affiliated Sponsor and Index Provider for the RPAR Risk Parity ETF
In December 2019, Tidal ETF Services launched the RPAR Risk Parity ETF (“RPAR”) with EVOKE’s
affiliate, Advanced Research Investment Services, LLC (“ARIS”) serving as fund sponsor. While EVOKE
does not manage, advise, or sub-advise RPAR, EVOKE’s affiliate, RPAR, LLC, currently serves as the
fund sponsor and manages the Advanced Research Risk Parity Index (“RPARTR”) which RPAR seeks to
replicate. As such, RPAR, LLC is considered an affiliated index provider to RPAR. To mitigate any
potential for conflicts with respect to its affiliated Index Provider, EVOKE has retained a separate,
unaffiliated, and independent third party to serve as calculation agent to RPAR (the “Calculation Agent”).
EVOKE has no affiliation with RPAR’s Calculation Agent, RPAR’s adviser, RPAR’s sub-adviser, RPAR’s
distributor, nor any of their respective affiliates. The Calculation Agent, using the applicable rules-based
methodology, calculates, maintains, and disseminates RPARTR on a daily basis. RPAR, LLC monitors the
results produced by the Calculation Agent to help ensure that RPARTR is being calculated in accordance
with the applicable rules-based methodology. In addition, EVOKE has established policies and procedures
designed to prevent non-public information about pending changes to RPARTR from being used or
disseminated in an improper manner. Furthermore, EVOKE has established policies and procedures
designed to prevent improper use and dissemination of non-public information about RPAR’s portfolio
strategy.
It is important to note that as EVOKE’s affiliate RPAR, LLC is the sponsor of RPAR, EVOKE receives a
portion of the fees collected, and therefore, is incentivized to market RPAR to EVOKE clients and
prospective investors. This inherently creates a conflict of interest that both EVOKE clients and prospective
investors should carefully consider when deciding whether to invest in RPAR. To the extent that EVOKE
invests advisory client assets in RPAR, EVOKE or its related persons may charge management fees both
at the RPAR level and client account level; however, we or our related persons may also waive management
fees (or certain portions thereof) on client assets invested in RPAR, credit or rebate a client account for the
fees paid by RPAR to us or our related persons, or otherwise avoid or limit the payment of duplicative fees
to us and our related persons.
Affiliated Sponsor and Index Provider for the UPAR Ultra Risk Parity ETF
In January 2022, Tidal ETF Services launched the UPAR Ultra Risk Parity ETF (“UPAR”) with EVOKE’s
affiliate, Advanced Research Investment Services, LLC (“ARIS”) serving as fund sponsor. While EVOKE
does not manage, advise, or sub-advise UPAR, EVOKE’s affiliate, RPAR, LLC, currently serves as the
fund sponsor and manages the Advanced Research Ultra Risk Parity Index (“UPARTR”) which UPAR
seeks to replicate. As such, RPAR, LLC is considered an affiliated index provider to UPAR. To mitigate
any potential for conflicts with respect to its affiliated Index Provider, EVOKE has retained a separate,
unaffiliated, and independent third party to serve as calculation agent to UPAR (the “Calculation Agent”).
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EVOKE has no affiliation with UPAR’s Calculation Agent, UPAR’s adviser, UPAR’s sub-adviser,
UPAR’s distributor, nor any of their respective affiliates. The Calculation Agent, using the applicable rules-
based methodology, calculates, maintains, and disseminates UPARTR on a daily basis. RPAR, LLC
monitors the results produced by the Calculation Agent to help ensure that UPARTR is being calculated in
accordance with the applicable rules-based methodology. In addition, EVOKE has established policies and
procedures designed to prevent non-public information about pending changes to UPARTR from being
used or disseminated in an improper manner. Furthermore, EVOKE has established policies and procedures
designed to prevent improper use and dissemination of non-public information about UPAR’s portfolio
strategy.
It is important to note that as EVOKE’s affiliate RPAR, LLC is the sponsor of UPAR, EVOKE receives a
portion of the fees collected, and therefore, is incentivized to market UPAR to EVOKE clients and
prospective investors. This inherently creates a conflict of interest that both EVOKE clients and prospective
investors should carefully consider when deciding whether to invest in UPAR. To the extent that EVOKE
invests advisory client assets in UPAR, EVOKE or its related persons may charge management fees both
at the UPAR level and client account level; however, we or our related persons may also waive management
fees (or certain portions thereof) on client assets invested in UPAR, credit or rebate a client account for the
fees paid by UPAR to us or our related persons, or otherwise avoid or limit the payment of duplicative fees
to us and our related persons.
C. Client-Tailored Advisory Services
Financial counsel and investment advice is customized and tailored to the unique goals, objectives, and
needs of each client. The planning process begins with an in-depth discovery of the client’s goals,
objectives, and attitudes toward risk and reward. The goals and objectives for each client are documented
in writing and approved by the client. The stated goals and objectives for each client are reflected in the
client’s overall recommended financial and investment program and advice that we provide on an ongoing
basis.
D. Donor Advised Fund Services
Certain EVOKE clients will establish donor advised funds through various third-party charitable programs,
including the Fidelity Charitable Gift Fund Program and the Schwab Charitable Fund (each, a “Charitable
Platform”), in which funds will be managed in accordance with the specific investment policies and
guidelines of the applicable the Charitable Platform. Clients will establish a donor advised account, transfer
funds earmarked for charitable donation and recognize a tax deduction in the year that funds are transferred
into an account opened on a Charitable Platform. The funds remain in such account until the client
designates a charity, an amount, and a date to donate to such charity.
Under independent advisor programs established within each Charitable Platform, donors nominate an
independent investment adviser, including EVOKE, to manage accounts established on the Charitable
Platforms. If nominated, EVOKE will manage the donor's account pursuant to investment guidelines
established by each Charitable Platform.
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E. Tax Compliance, Planning, Preparation and Consulting
To the extent specifically requested by a client, we provide coordinated tax compliance, planning,
preparation, and consulting services (collectively referred to as “tax services”) to investment advisory
clients as an integrated part of our investment advisory services. We also provide tax services on a stand-
alone basis, pursuant to a separate tax engagement agreement, to individuals, businesses, and family offices.
The Firm’s tax planning practice includes employees who are certified public accountants (CPAs) with
backgrounds in complex tax matters as well as enrolled agents (EAs), who are federally authorized tax
practitioners with technical expertise in the field of taxation and are qualified to represent taxpayers before
all administrative levels of the Internal Revenue Service for audits, collections, and appeals.
Although the Firm is a registered investment adviser under the Investment Advisers Act of 1940 (“Advisers
Act”), the Firm is not serving in a fiduciary capacity in its provision of stand-alone tax services and will
not provide ongoing investment advisory services with respect to stand-alone tax clients’ assets or accounts.
For clients who receive tax services on a stand-alone basis, we may recommend the Firm be retained as
their investment adviser pursuant to a separate investment advisory agreement; however, such clients are
under no obligation to do so. The Firm may also recommend the services of other, nonaffiliated
professionals to provide tax services. Our clients are under no obligation to engage the services of any such
recommended professional. It is solely up to our clients as to whether they accept or reject any
recommendation made by the Firm.
Please Note: Our clients agree that, if any dispute arises between our client and any other professional
recommended by the Firm, they will seek recourse exclusively from and against the engaged qualified
professional.
Please Note: While certain investment adviser representatives of the Firm are licensed CPAs or EAs, they
are not responsible for providing tax services unless the client’s Agreement with the Firm specifically sets
forth that such tax services will be provided. The Firm typically charges an additional or separate fee for
tax services.
Material Conflicts of Interest: Tax compliance, planning, preparation, and consulting service
recommendations as described herein may pose a conflict between the interests of the Firm and the interests
of clients. For example, a recommendation by Firm personnel to engage the Firm for these services poses
a conflict, as it would increase the total fees paid to the Firm. Clients are not obligated to implement any
recommendations made by the Firm or maintain an ongoing tax services relationship with the Firm.
F. Administrative Services
As an accommodation, EVOKE may provide administrative services to certain of its clients ranging from
client reporting, asset allocation, back-office functions, and consolidated reporting on client non-advisory
assets (“Administrative Services”). Non-advisory assets are assets independently owned by clients and not
included as assets under management by EVOKE. These non-advisory assets will not be subject to
EVOKE’s portfolio diversification review and no investment advice will be provided with respect to such
non-advisory assets. EVOKE will report the value of each non-advisory asset to the client, based solely on
the valuations received by EVOKE from the third-party managers of the non-advisory assets, the clients
themselves, or other third parties, but EVOKE will not have any obligation to independently examine,
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confirm, or review non-advisory asset valuations. These Administrative Services are in addition to other
advisory services and are offered and may be performed at an additional charge.
G. IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance
Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction
Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment
to clients and prospective clients.
When we provide investment advice regarding a client’s or prospect’s retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with a client’s interests, so we operate under a
special rule that requires us to act in a client’s best interest and not put our interest ahead of our clients.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of a client’s assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management and, in
turn, our advisory fees. A conflict of interest exists if EVOKE recommends a rollover of retirement
accounts, as such a recommendation may increase advisory fees paid to EVOKE. While EVOKE may
educate clients as to investment options available to them in rolling over their assets, EVOKE has adopted
a policy of not recommending such rollovers and clients are advised to carefully review their options before
choosing to roll over their retirement assets to EVOKE’s management. As a fiduciary, we only recommend
a rollover on an exception basis when we believe it is in a client’s best interest.
H. Assets Under Management
As of December 31, 2024, EVOKE manages approximately $12,453,071,296in assets on a discretionary
basis and $15,242,414,286 on a non-discretionary basis.
Item 5 - Fees and Compensation
A. Fees for Advisory Services
EVOKE charges an annual advisory fee that is agreed upon with each client and set forth in an agreement
executed by EVOKE and the client. EVOKE’s fee for investment advisory services is negotiable and varies
based on several factors, including, but not limited to, the size of the relationship, the nature and complexity
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of the products and investments involved, time commitments, and travel requirements. If based on a
percentage of the value of assets under management, the fee generally ranges between .075% and 1.00%
annually of the value of the assets under management. If based on a percentage of assets under management,
the advisory fee for the initial quarter is payable on a pro rata basis, in arrears, based on the period ending
value of the net billable assets under management. For subsequent quarters, the advisory fee generally is
payable in advance based on the net billable asset value of the client’s accounts on the last day of the
previous quarter as provided by third-party sources such as pricing services, custodians, fund
administrators, and client-provided sources. Client deposits of $10 million or more that occur during a
quarter, other than the initial quarter, are charged an advisory fee on a pro rata basis, in arrears, based upon
the number of days remaining in the applicable quarter.
If fixed, the advisory fee for the initial quarter is payable, on a pro rata basis, in arrears. For subsequent
quarters, the fixed fee generally is payable in advance
Clients have five (5) business days from the date of execution of the client agreement to terminate EVOKE’s
services. The investment advisory agreement between EVOKE and the client may be terminated at will by
either EVOKE or the client upon written notice. EVOKE does not impose termination fees when the client
terminates the investment advisory relationship, except when agreed upon in advance. In the event the
investment advisory agreement is terminated, the fee for the final billing period is prorated through the
effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded
to the client, as appropriate.
EVOKE offers its clients financial planning services. Such services are generally included as part of the
annual advisory fee. Clients may also enter into a separate agreement with EVOKE for financial planning
services. Fees for services performed pursuant to such separate agreements for financial services are
negotiable and are based on either an hourly rate that varies, depending on the experience, knowledge, and
skill of those performing the services on behalf of EVOKE, or a flat fee agreed upon in writing by EVOKE
and the client.
B. Fees for Financial Planning Services
Either EVOKE or the Client may terminate the FOSA at any time by providing advance written notice to
the other party. The Client may also terminate the FOSA within five (5) business days at no cost to the
Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times
the contractual hourly rate. Upon termination, EVOKE will refund any unearned, prepaid planning fees
from the effective date of termination to the end of the billing period. The Client’s FOSA with EVOKE is
non-transferable without the Client’s prior consent. Fees are billed in accordance with the respective
FOSAs. Fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the
FOSA.
C. Payment of Advisory Fees
EVOKE generally deducts its advisory fee from a client’s investment account(s) held at his/her custodian
pursuant to the terms of the investment management agreement between EVOKE and the client. The
investment management agreement generally provides EVOKE with the flexibility to debit fees from
accounts of related entities of clients under EVOKE’s discretion, as agreed upon or consented to by the
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respective client. Upon engaging EVOKE to manage such account(s), a client grants EVOKE this limited
authority through a written instruction to the custodian of his/her account(s). The client is responsible to
verify the accuracy of the calculation of the advisory fee; the custodian will not determine whether the fee
is accurate or properly calculated. The fee generally is billed in advance on a quarterly basis, as described
above in Item 5.A. A client may utilize the same procedure for the payment of financial planning or
consulting fees if the client has investment accounts held at a custodian.
Although clients generally are required to have their investment advisory fees deducted from their accounts,
in some cases, EVOKE will directly bill a client for investment advisory fees if it determines that such
billing arrangement is appropriate given the circumstances.
The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating
separate line items for all amounts disbursed from the client's account(s), including any fees paid directly
to EVOKE.
Clients may make additions to and withdrawals from their account at any time, subject to EVOKE’s right
to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to
liquidate transferred securities or decline to accept particular securities into a client’s account. Clients may
withdraw account assets at any time on notice to EVOKE, subject to the usual and customary securities
settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the
withdrawal of assets may impair the achievement of a client’s investment objectives. EVOKE may consult
with its clients about the options and implications of transferring securities. Clients are advised that when
transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees,
fees assessed at the mutual fund level (e.g. contingent deferred sales charges) and/or tax ramifications.
D. Clients Responsible for Fees Charged by Financial Institutions and External Money
Managers
In connection with EVOKE’s management of an account, a client will incur fees and/or expenses separate
from and in addition to EVOKE’s advisory fee. These additional fees may include transaction charges and
the fees/expenses charged by any custodian, subadvisor, mutual fund, ETF, CEF, External Manager,
separate account manager (and the manager’s platform manager, if any), limited partnership, or other
advisor, transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any
charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan account
fees (where applicable), margin interest, brokerage commissions, mark-ups or mark-downs and other
transaction-related costs, electronic fund and wire fees, and any other fees that reasonably may be borne by
a brokerage account.
For External Managers, clients should review each manager’s Form ADV 2A disclosure brochure and any
contract they sign with the External Manager (in a dual contract relationship). The client is responsible for
all such fees and expenses.
The investment management fees charged by the manager of a Private Fund, including a manager who is
an affiliate or related person of EVOKE, are exclusive of, and in addition to, advisory fees charged by
EVOKE on the assets under management in the Private Fund. Clients should review the Offering Materials
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of the Private Fund for disclosure of fees and expenses charged by the Private Fund.
EVOKE is deemed to be a fiduciary to advisory clients that are employee benefit plans subject to ERISA
or plans subject to Section 4975 of the Internal Revenue Code of 1986 (the "Code"), such as individual
retirement accounts (IRAs). As such, EVOKE is subject to specific duties and obligations under ERISA
and the Code that include, among other things, restrictions concerning certain forms of compensation. To
avoid engaging in prohibited transactions, EVOKE will only charge fees for investment advice on products
for which EVOKE does not receive any commissions or trailing fees such as 12b-1 fees, unless such
payments are structured in a manner that complies with ERISA and the regulations and rulings of the
Department of Labor.
E. Fees for Administrative Services
EVOKE may, at our sole discretion, charge an annual fee for Administrative Services of up to 0.25%, which
shall be calculated based on the aggregate net market value of certain non-advised assets, and charged
quarterly in advance. The fee for Administrative Services generally appears as a separate itemized
deduction from a client’s account.
F. Tax Compliance and Consulting Fees (Stand-Alone)
To the extent specifically requested by a client and agreed to by the Firm, we will provide clients with tax
compliance, preparation, consulting, and planning services typically for an additional fee and generally
billed on either a fixed fee or hourly rate basis. The Firm’s tax preparation fees are negotiable depending
on the level and scope of the service(s) required and the professional(s) rendering the service(s). We reserve
the right to waive or reduce the fee at our discretion for investment advisory clients. The Firm has a full tax
practice with clients that are not investment advisory clients. Fees for tax clients are determined on a case-
by-case basis by members of the tax practice.
G. Prepayment of Fees
As noted in Item 5(B) above, EVOKE’s advisory fees generally are paid in advance. Upon the termination
of a client’s advisory relationship, EVOKE will issue a refund equal to any unearned management fee for
the remainder of the quarter. The client may specify how he/she would like such refund issued (i.e., a check
sent directly to the client or a check sent to the client’s custodian for deposit into his/her account).
H. Outside Compensation for the Sale of Securities or Other Investment Products to Clients
EVOKE does not buy or sell securities and does not receive any compensation for securities transactions
in any client account, other than the investment advisory fees noted above.
Item 6 - Performance-Based Fees and Side-by-Side Management
Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client’s
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-based
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fees. EVOKE’s fees are calculated as described in Item 5 above. EVOKE does not charge performance-
based fees or participate in side-by-side management.
However, EVOKE does recommend External Managers and investment funds, including Private Funds,
which typically assess a performance-based fee. Such recommendations to invest with an External Manager
or in a Private Fund with a performance-based fee arrangement would be preceded by an assessment as to
the suitability and appropriateness of such an investment, relative to other similar investments, if any, which
do not assess a performance-fee arrangement.
It is important to note that any EVOKE advisory fee charged to clients for investing in a Private Fund is in
addition to the fees charged by the Private Funds to investors. This is a conflict of interest with the multiple
fees charged because certain owners of EVOKE are owners and general partners of affiliated Private Funds
and will receive multiple forms of compensation. It should also be noted that certain members of EVOKE
may directly participate in any of the investment opportunities described for which an affiliated Private
Fund is established and/or may participate through the Private Fund itself for the purposes of investing.
This right to participate and any corresponding economic interest therefrom will likely mean that certain
members of EVOKE will derive a direct or indirect benefit from their direct participation and may also
receive management fees, carried interest, and other fees that a Private Fund charges to investors and clients
for their participation in the respective investment opportunity. As such, a conflict of interest arises between
the presentation of a private market investment opportunity to EVOKE clients and prospective clients, and
those members of EVOKE who will have an interest in the alternative investment opportunity and who,
through an affiliated Private Fund, may also be charging clients and investors a variety of fees for
investment in the respective investment opportunity. Therefore, it should be understood that members of
EVOKE may be highly incentivized to recommend an alternative investment opportunity to clients. Clients
are strongly advised and encouraged to discuss this conflict of interest with their advisors and to assess the
risks, merits, charges, suitability, and appropriateness of the opportunity prior to making any investment
decision.
Item 7 - Types of Clients
EVOKE’s clients include, but are not limited to, individuals, including high and ultra-high net worth
individuals, and entities, including, family offices, trusts, and estates. EVOKE also offers services to
pension and retirement/profit-sharing plans, affiliated Private Funds (as that term is defined in Item 4 of
this Brochure), pooled investment vehicles, foundations, endowments, charitable organizations, guilds and
health plans, investment companies, family offices, corporations, and other business entities.
EVOKE does not have a minimum fee or a minimum asset requirement as a condition for starting and
maintaining an investment advisory relationship. With respect to affiliated Private Funds managed by
EVOKE’s affiliate, Evoke GP, LLC, EVOKE reserves the right in its sole discretion to waive investment
minimums (as set forth in the respective Offering Materials) in certain circumstances.
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Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss
A. Methods of Analysis and Risk of Loss
Overall investment strategies recommended to each client generally emphasize long-term ownership of a
diversified portfolio of marketable and non-marketable investments intended to provide superior after-tax,
inflation-adjusted, economic returns. EVOKE generally recommends broad diversification via a long-term
asset allocation strategy -- diversified both across asset classes and within asset classes -- in an effort to
improve the risk and return potential of client portfolios. More specifically, we may recommend multiple
asset classes (both liquid and illiquid), market capitalizations, market styles, and geographic regions to
provide diversification.
Client portfolios with similar investment objectives and asset allocation goals may own different securities
and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, long-term wealth transfer
objectives, time horizon and choice of custodian are all factors that influence EVOKE’s investment
recommendations.
Investment advice given to clients more often than not includes recommending long-term purchases or
holding on to certain assets. However, other investment strategies that may also be recommended include
short-term purchases, margin transactions, short-selling, and options strategies.
Marketable asset classes recommended by EVOKE primarily include equities, corporate bonds, U.S.
government and municipal debt securities, mutual funds, CEFs, ETFs, and structured products. Investment
recommendations may also include warrants, commercial paper, certificates of deposit, options contracts,
and interests in limited partnerships. Mutual fund, CEF, ETF and separately managed account
recommendations are generally developed with the objective of selecting a well-diversified fund, or group
of funds, with appropriate historical performance, at a level of volatility (risk) determined to be appropriate
for each client.
EVOKE may also recommend Private Funds to clients. See Item 4(B) (“Types of Advisory Services”) for
a description of Private Funds.
EVOKE relies on various third parties, including investment research organizations, consultants,
appraisers, accountants, and lawyers as necessary for specialized assistance.
EVOKE does not represent, imply, or guarantee that the services or methods of analysis used by EVOKE
to make investment recommendations can or will produce successful results, successfully identify market
tops or bottoms, or insulate clients from losses due to market corrections or crashes. No guarantees can be
offered that a client’s goals or objectives will be achieved. Past performance is not an indication or
guarantee of future results. Clients are advised that the recommendations offered by EVOKE are not legal
or tax advice. Clients are advised to promptly notify EVOKE with respect to any changes in their financial
situation and/or financial goals and objectives. Failure to do so could result in our recommendations not
meeting the objectives and/or needs of the client.
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B. Material Investment Risks
The mutual funds, ETFs, CEFs, separately managed accounts, Private Funds and External Managers that
the Firm typically utilizes to invest client assets generally own, purchase, and sell securities and therefore
also involve the risk of loss that is inherent in investing in securities. Past performance of a security, fund,
or manager is not necessarily indicative of future performance or risk of loss. Investing in securities
involves a risk of loss. A client can lose all or a substantial portion of his/her investment. A client should
be willing to bear such a loss. Some investments are intended only for sophisticated investors and can
involve a high degree of risk.
The following events could cause equities and fixed income securities, mutual funds, ETFs, CEFs, Private
Funds, and other investments managed for clients, as well as those managed by External Managers, to
decrease in value:
Market Risk: The price of an equity security, bond, or mutual fund, ETF or CEF may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external factors independent
of a security’s or fund’s particular underlying circumstances. For example, changes in political, economic,
or social conditions may trigger adverse market events.
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example,
when interest rates rise, yields on existing bonds become less attractive, causing their market values to
decline.
Event Risk: An adverse event affecting a particular company or that company’s industry could depress the
price of a client’s investment in that company’s stocks or bonds. The company, government or other entity
that issued bonds in a client’s portfolio could become less able to, or fail to, repay, service or refinance its
debts, or the issuer’s credit rating could be downgraded by a rating agency. Adverse events affecting a
particular country, including political and economic instability, could depress the value of investments in
issuers headquartered or doing business in that country.
Liquidity Risk: Securities that are normally liquid may become difficult or impossible to sell at an
acceptable price during periods of economic instability or other emergency conditions. Some securities may
be infrequently or thinly traded even under normal market conditions.
Leverage Risk: The use of leverage may lead to increased volatility of a fund’s NAV and market price
relative to its common shares. Leverage is likely to magnify any losses in the fund’s portfolio, which may
lead to increased market price declines. There is no assurance that a leveraging strategy will be successful.
Domestic and/or Foreign Political Risk: The events that occur in the U.S. relating to politics, government,
and elections can affect the U.S. markets. Political events occurring in the home country of a foreign
company such as revolutions, nationalization, and currency collapse can have an impact on the security.
Inflation Risk: Inflation carries the risk of eroding purchasing power over time due to rising prices.
Countries around the globe may be more, or less, prone to inflation than the U.S. economy at any given
time.
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Currency Risk: Overseas investments are subject to fluctuations in the value of the U.S. dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
Reinvestment Risk: This risk is that future proceeds from investments may have to be reinvested at a
potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.
Operational Risk: Fund advisors and service providers may experience disruptions or operating errors such
as processing errors or human errors, inadequate or failed internal or external processes, or systems or
technology failures, that could negatively impact the fund.
Regulatory/Legislative Developments Risk: Regulators and/or legislators may promulgate rules or pass
legislation that places restrictions on, adds procedural hurdles to, affects the liquidity of, and/or alters the
risks associated with certain investment transactions or the securities underlying such investment
transactions. Such rules/legislation could affect the value associated with such investment transactions or
underlying securities.
Illiquid Securities: Investments in Private Funds or other private investment vehicles or private securities
may underperform publicly offered and traded securities because such investments:
• Typically require investors to lock‐up their assets for a period of time and may be unable to meet
redemption requests during adverse economic conditions.
• Have limited or no liquidity because of restrictions on the transfer of, and the absence of a market
for, interests in these funds.
• Are more difficult to monitor and value due to a lack of transparency and publicly available
information about these funds.
• May have higher expense ratios and involve more inherent conflicts of interest than publicly traded
•
investments.
Involve different risks than investing in registered funds and other publicly offered and traded
securities. These risks may include those associated with more concentrated, less diversified
investment portfolios, investment leverage and investments in less liquid and non‐traditional asset
classes.
C. Use of External Managers
EVOKE may select certain External Managers to manage a portion of its clients’ assets. In these situations,
EVOKE conducts due diligence on such managers, but the success of such recommendations relies to a
great extent on the External Manager’s ability to successfully implement their investment strategies. In
addition, EVOKE generally may not have the ability to supervise the External Managers on a day-to-day
basis.
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D. Business Continuity Risks
EVOKE’s business operations may be vulnerable to disruption in the case of catastrophic events such as
fires, natural disaster, terrorist attacks, or other circumstances resulting in property damage, network
interruption, and/or prolonged power outages. Although the Firm has implemented measures to manage
risks relating to these types of events, there can be no assurances that all contingencies can be planned for.
These risks of loss can be substantial and could have a material adverse effect on the Firm and investments
therein.
E. Outbreak Risks
An epidemic outbreak or pandemic, and reactions thereto could cause uncertainty in markets and
businesses, including EVOKE's business, and may adversely affect the performance of the global
economy, including causing market volatility, market and business uncertainty and closures, supply chain
and travel interruptions, the need for employees and vendors to work at external locations, and extensive
medical absences. EVOKE has policies and procedures to address known situations, but because a large
epidemic or pandemic may create significant market and business uncertainties and disruptions, not all
events that could affect EVOKE's business and/or the markets can be determined and addressed in
advance.
F. Artificial Intelligence Risk
We may use artificial intelligence ("AI") in our business operations, in order to promote operational
efficiency and augment our client service. We currently do not knowingly utilize AI in our investment
selection process or to formulate the specific investment advice we render to you. AI models are highly
complex and may result in output that is incomplete or incorrect. Our use of AI includes certain third-
party technologies aimed at driving operational efficiency by automating meeting prep, meeting notes,
CRM updates, meeting recap notes, task management, and other client service-related functions. We
believe the use of this technology allows us to reduce administrative time, prepare for client engagement,
and improve overall client experience. The use of AI poses risks related to the challenges the Evoke faces
in properly managing its use. Content generated by AI technologies may be deficient, inaccurate, or
biased, and the use of AI tools may lead to errors in decision-making. Use of AI tools could also pose
risks related to the protection of client or proprietary information. Such risks may include the exposure of
confidential information to unauthorized recipients, violation of data privacy rights, or other data leakage
events. For example, in the case of generative AI, if confidential information, including material non-
public information or personal identifiable information is input into an AI application, such information is
at risk of becoming part of a dataset accessible by other AI applications and users. The regulatory
environment relating to AI is rapidly evolving and could require changes in our adoption and
implementation of AI technology in the future. The use of AI may also expose us to litigation risk or
regulatory risk.
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G. Risks of Specific Securities
Mutual Funds and ETFs
An investment in a mutual fund or an ETF involves risk, including the loss of principal. Mutual fund and
ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for
a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily
per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption
fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a
mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may,
among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least
once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However,
certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There
is also no guarantee that an active secondary market for such shares will develop or continue to exist.
Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more).
Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may
have no way to dispose of such shares.
Closed-End Funds
CEFs typically use a high degree of leverage. They may be diversified or non-diversified. Risks associated
with closed-end fund investments include liquidity risk, credit risk, volatility and the risk of magnified
losses resulting from the use of leverage. Additionally, closed-end funds may trade below their net asset
value.
Options Trading
Certain strategies employed by External Managers, ETFs, CEFs or mutual funds may involve the use of
options. Investments in options contracts have the risk of losing value in a relatively short period of time.
Options are investments whose ultimate value is determined from the value of the underlying investment.
Option contracts are leveraged instruments that allow the holder of a single contract to control many shares
of an underlying stock. This leverage can compound gains or losses.
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Call Options
The seller (writer) of a call option which is covered (i.e., the writer holds the underlying security) assumes
the risk of a decline in the market price of the underlying security below the purchase price of the underlying
security less the premium received and gives up the opportunity for gain on the underlying security above
the exercise price of the option. The seller of an uncovered call option assumes the risk of a theoretically
unlimited increase in the market price of the underlying security above the exercise price of the option. The
securities necessary to satisfy the exercise of an uncovered call option may be unavailable for purchase,
except at much higher prices, thereby reducing or eliminating the value of the premium. Purchasing
securities to cover the exercise of an uncovered call option can cause the price of the securities to increase,
thereby exacerbating the loss. The buyer of a call option assumes the risk of losing its entire premium
investment in the call option.
Put Options
The seller (writer) of a put option which is covered (i.e., the writer has a short position in the underlying
security) assumes the risk of an increase in the market price of the underlying security above the sales price
(in establishing the short position) of the underlying security plus the premium received, and gives up the
opportunity for gain on the underlying security if the market price falls below the exercise price of the
option. The seller of an uncovered put option assumes the risk of a decline in the market price of the
underlying security below the exercise price of the option. The buyer of a put option assumes the risk of
losing its entire investment in the put option.
Index Options
The value of an index or index option fluctuates with changes in the market values of the assets included
in the index. Because the value of an index or index option depends upon movements in the level of the
index rather than the price of a particular asset, whether the client will realize appreciation or depreciation
from the purchase or writing of options on indices depends upon movements in the level of instrument
prices in the assets generally or, in the case of certain indices, in an industry or market segment, rather than
movements in the price of particular assets.
Hedging transactions
Options may be used for risk management purposes. However, EVOKE or an External Manager may be
unable to anticipate the occurrence of a particular risk and, therefore, may be unable to attempt to hedge
against it. The use of hedging transactions may result in poorer overall performance than if EVOKE or the
External Manager had not engaged in any such transactions. Moreover, client portfolios will always be
exposed to certain risks that cannot be hedged.
Risks Associated with Structured Notes
Complexity. Structured notes are complex financial instruments. Clients should review the prospectus and
other offering documents associated with structured notes. Clients should understand the reference asset(s)
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or index(es) and determine how the note’s payoff structure incorporates such reference asset(s) or index(es)
in calculating the note’s performance. This payoff calculation may include leverage multiplied on the
performance of the reference asset or index, protection from losses should the reference asset or index
produce negative returns, and fees. Structured notes may have complicated payoff structures that can make
it difficult for clients to accurately assess their value, risk, and potential for growth through the term of the
structured note. Determining the performance of each note can be complex and this calculation can vary
significantly from note to note depending on the structure. Notes can be structured in a wide variety of
ways. Payoff structures can be leveraged, inverse, or inverse-leveraged, which may result in larger returns
or losses. Clients should carefully read the prospectus for a structured note to fully understand how the
payoff on a note will be calculated and discuss these issues with us.
Market risk. Some structured notes provide for the repayment of principal at maturity, which is often
referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing
financial institution. Many structured notes do not offer this feature. For structured notes that do not offer
principal protection, the performance of the linked asset or index may cause clients to lose some, or all, of
their principle. Depending on the nature of the linked asset or index, the market risk of the structured note
may include changes in equity or commodity prices, changes in interest rates or foreign exchange rates, or
market volatility. The valuation of a structured note prior to maturity can be detached from the valuation of
the underlying or referenced security.
Issuance price and note value. The price of a structured note at issuance will likely be higher than the fair
value of the structured note on the date of issuance. Issuers now disclose an estimated value of the structured
note on the cover page of the offering prospectus, allowing investors to gauge the difference between the
issuer’s estimated value of the note and the issuance price. The initial market value of the notes is likely
lower than the issuance price of the note to investors because issuers include the costs for selling,
structuring, or hedging the exposure on the note in the initial price of their notes. After issuance, structured
notes may not be re-sold on a daily basis and thus may be difficult to value given their complexity.
Liquidity. The ability to trade or sell structured notes in a secondary market is often very limited as
structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on security
exchanges. As a result, the only potential buyer for a structured note may be the issuing financial
institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In addition, issuers
often specifically disclaim their intention to repurchase or make markets in the notes they issue. Clients
should, therefore, be prepared to hold a structured note to its maturity date, or risk selling the note at a
discount to its value at the time of sale.
Credit risk. Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is obligated
to make payments on the notes as promised. These promises, including any principal protection, are only
as good as the financial health of the structured note issuer. If the structured note issuer defaults on these
obligations, investors may lose some, or all, of the principal amount they invested in the structured notes
as well as any other payments that may be due on the structured notes.
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H. Cybersecurity
The computer systems, networks, and devices used by EVOKE and service providers to us and our clients
to carry out routine business operations employ a variety of protections designed to prevent damage or
interruption from computer viruses, network failures, computer and telecommunication failures, human
error, infiltration by unauthorized persons and security breaches. Despite the various protections utilized,
systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result
of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks,
or devices; infection from computer viruses or other malicious software code; and attacks that shut down,
disable, slow, or otherwise disrupt operations, business processes, or website access or functionality.
Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in
financial losses to a client, impediments to trading, the inability by us and other service providers to transact
business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage,
reimbursement, or other compensation costs, or additional compliance costs, as well as the inadvertent
release of confidential information. Similar adverse consequences could result from cybersecurity breaches
affecting issuers of securities in which a client invests, governmental and other regulatory authorities,
exchange and other financial market operators, banks, brokers, dealers, and other financial institutions. In
addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches
in the future.
I. Pay-to-Play
Several U.S. states and municipal pension plans have adopted so-called “pay-to-play” laws, regulations, or
policies that prohibit, restrict, or require that individuals or entities seeking to do business with state entities,
including those seeking investments by public retirement funds, disclose payments to and/or contracts with
state officials. The SEC has adopted rules prohibiting investment advisers from providing advisory services
for compensation to a government client for two years after the adviser or certain of its executives,
employees, or agents makes a contribution to certain elected officials or candidates. If EVOKE, any of its
employees or affiliates, or any service providers acting on its behalf fail to comply with such laws,
regulations, or policies, it could adversely and materially affect EVOKE’s business and its ability to
manager certain client accounts.
Item 9 – Disciplinary Information
Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary
events that would be material to a client’s evaluation of EVOKE and the integrity of EVOKE’s
management. EVOKE has no information to disclose applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Effective October 1, 2018, Damien Bisserier became an Advisor of Wealthsimple Financial Corporation
(“Wealthsimple”). Mr. Bisserier’s advisory services include participating as a member of Wealthsimple’s
Investment Advisory Committee and advising Wealthsimple’s management in strategic areas. As
compensation for his advisory services, Mr. Bisserier was granted an option to purchase non-voting
common shares of Wealthsimple. In addition, Mr. Bisserier is entitled to reimbursement of reasonable
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expenses incurred in connection with his performance of advisory services, in accordance with the
applicable policies of Wealthsimple.
In December 2019, Tidal ETF Services launched the RPAR Risk Parity ETF (“RPAR”) with Evoke’s
affiliate, ARIS, serving as fund sponsor. While EVOKE does not manage, advise or sub-advise RPAR,
EVOKE’s affiliate, RPAR, LLC, currently serves as the fund sponsor and manages the Advanced Research
Risk Parity Index (“RPARTR”) which RPAR seeks to replicate. As such, RPAR, LLC is considered an
affiliated index provider to RPAR. To mitigate any potential for conflicts with respect to its affiliated Index
Provider, EVOKE has retained a separate, unaffiliated, and independent third party, Solactive AG, to serve
as the calculation agent (the “Calculation Agent”). EVOKE has no affiliation to RPAR’s Calculation Agent,
RPAR’s adviser, RPAR’s sub-adviser, RPAR’s distributor, nor any of their respective affiliates. The
Calculation Agent, using the applicable rules-based methodology, calculates, maintains, and disseminates
RPARTR on a daily basis. RPAR, LLC monitors the results produced by the Calculation Agent to help
ensure that RPARTR is being calculated in accordance with the applicable rules-based methodology. In
addition, EVOKE has established policies and procedures designed to prevent non-public information about
pending changes to RPARTR from being used or disseminated in an improper manner. Furthermore,
EVOKE has established policies and procedures designed to prevent improper use and dissemination of
non-public information about RPAR’s portfolio strategy.
In January 2022, Tidal ETF Services launched the UPAR Ultra Risk Parity ETF (“UPAR”) with Evoke’s
affiliate, ARIS serving as fund sponsor. While EVOKE does not manage, advise or sub-advise UPAR,
EVOKE’s affiliate, RPAR, LLC currently sponsors the fund and manages the Advanced Research Ultra
Risk Parity Index (“UPARTR”) which UPAR seeks to replicate. As such, RPAR, LLC is considered an
affiliated index provider to UPAR. To mitigate any potential for conflicts with respect to its affiliated Index
Provider, EVOKE has retained a separate, unaffiliated, and independent third party, Solactive AG, to serve
as calculation agent to UPAR (the “Calculation Agent”). EVOKE has no affiliation to UPAR’s Calculation
Agent, UPAR’s adviser, UPAR’s sub-adviser, UPAR’s distributor, nor any of their respective affiliates.
The Calculation Agent, using the applicable rules-based methodology, calculates, maintains, and
disseminates UPARTR on a daily basis. RPAR, LLC monitors the results produced by the Calculation
Agent to help ensure that UPARTR is being calculated in accordance with the applicable rules-based
methodology. In addition, EVOKE has established policies and procedures designed to prevent non-public
information about pending changes to UPARTR from being used or disseminated in an improper manner.
Furthermore, EVOKE has established policies and procedures designed to prevent improper use and
dissemination of non-public information about UPAR’s portfolio strategy.
It is important to note that as Evoke’s affiliate, RPAR, LLC serves as the sponsor of RPAR and UPAR,
EVOKE receives a portion of the fees collected, and therefore, is incentivized to market RPAR and UPAR
to EVOKE clients and prospective investors. This inherently creates a conflict of interest that both EVOKE
clients and prospective investors should carefully consider when deciding whether to invest in RPAR and/or
UPAR. To the extent that EVOKE invests advisory client assets in RPAR and/or UPAR, EVOKE or its
related persons may charge management fees both at the RPAR/UPAR level and client account level;
however, we or our related persons may also waive management fees (or certain portions thereof) on client
assets invested in RPAR and/or UPAR, credit or rebate a client account for the fees paid by RPAR and/or
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UPAR to us or our related persons, or otherwise avoid or limit the payment of duplicative fees to us and
our related persons.
Recommendation of External Managers
EVOKE may recommend that clients use External Managers based on the client’s needs and suitability.
EVOKE does not receive separate compensation, directly or indirectly, from such external managers for
recommending that clients use their services. EVOKE does not have any other business relationships with
the recommended External Managers.
Recommendation of Private Funds
As disclosed in Item 4.B, EVOKE may recommend that clients invest in Private Funds based on the client’s
needs, financial condition, risk profile and other suitability factors. EVOKE does not receive separate
compensation, directly or indirectly, from the managers of unaffiliated Private Funds. In the case of a
Private Fund that is affiliated with EVOKE, or managed by an affiliate of EVOKE, an EVOKE affiliate or
an EVOKE-related person will benefit financially if EVOKE recommends that its clients invest in the
Private Fund. Please see Item 4 and Item 5 for more information.
Affiliated Registered Investment Adviser
Effective May 1, 2020, Evoke Holdings, LLC acquired 100% of the interests of Advanced Research
Investment Solutions, LLC (“ARIS”), an SEC-registered investment adviser.
Effective August 2023, EVOKE’s affiliate, INbalance Advisors, LLC withdrew its registration from the
SEC, and EVOKE became a successor in interest to INbalance Advisors, LLC and its clients.
Effective July 2024, EVOKE’s affiliate, Advanced Research Investment Solutions, LLC withdrew its
registration from the SEC, and EVOKE became a successor in interest to Advanced Research Investment
Solutions, LLC and its clients.
Item 11 – Code of Ethics, Participation, or Interest in Client Transactions
A. Description of Code of Ethics
EVOKE has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that
sets forth the standards of conduct expected of its Supervised Persons. EVOKE’s Code of Ethics contains
written policies reasonably designed to prevent certain unlawful practices such as the use of material non-
public information by EVOKE or any of its Supervised Persons and the trading of the same securities ahead
of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of EVOKE’s personnel to report their personal securities holdings
and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited
offerings). However, EVOKE’s Supervised Persons are permitted to buy or sell securities that it also
recommends to clients if done in a fair and equitable manner that is consistent with EVOKE’s policies and
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procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently
broad markets to permit transactions by certain personnel to be completed without any appreciable impact
on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the
policies stated below.
When EVOKE is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person with access to this information may knowingly effect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that
security unless:
• The transaction for the Supervised Person is completed as part of a batch trade with clients.
• The transaction is in a highly liquid, large volume issuer (as defined in the Code of Ethics) where
such personal transaction will have no material impact.
• A decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii)
money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements, and other high-quality short-term debt instruments; (iii) shares issued by mutual
funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively
in one or more mutual funds.
Clients and prospective clients may contact EVOKE to request a copy of its Code of Ethics.
Item 12 – Brokerage Practices
A. Factors Used to Select Custodians and/or Broker-Dealers
EVOKE generally recommends that its investment management clients utilize the custody and brokerage
services of an unaffiliated broker/dealer custodian (a “BD/Custodian”) with which EVOKE has an
institutional relationship. Currently, this includes Charles Schwab & Co., Inc. (“Schwab”) and Fidelity
Clearing & Custody Solutions, a division of Fidelity Investments, Inc. (“Fidelity”), both FINRA-registered
broker-dealers and members of SIPC and a “Qualified Custodian” as that term is described in Rule 206(4)-
2 of the Investment Advisers Act of 1940 (“Advisers Act”). Each BD/Custodian provides custody of
securities, trade execution, and clearance and settlement of transactions placed by EVOKE. If your accounts
are custodied at Schwab or Fidelity, they will hold your assets in a brokerage account and buy and sell
securities when we instruct them to.
In deciding to recommend Schwab or Fidelity, some of the factors that EVOKE considers include:
• Trade order execution and the ability to provide accurate and timely execution of trades.
• The reasonableness and competitiveness of commissions and other transaction costs.
• Access to a broad range of investment products.
• Access to trading desks.
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• Technology that integrates within EVOKE’s environment, including interfacing with EVOKE’s
portfolio management system.
• A dedicated service or back-office team and its ability to process requests from EVOKE on behalf
of its clients.
• Ability to provide EVOKE with access to client account information through an institutional
website.
• Ability to provide clients with electronic access to account information and investment and
research tools.
EVOKE generally places portfolio transactions through the BD/Custodian where the clients’ accounts are
custodied. In exchange for using the services of the BD/Custodian, EVOKE will, in some circumstances,
receive, without cost, computer software and related systems support that allows EVOKE to monitor and
service its clients’ accounts maintained with such BD/Custodian.
Fidelity also makes available to the Firm products and services that benefit the Firm but may not directly
benefit the client or the client’s account. These products and services assist us in managing and
administering client accounts. They include investment research, both Fidelity’s own and that of third
parties. EVOKE may use this research to service all or some substantial number of client accounts,
including accounts not maintained at Fidelity. In addition to investment research, Fidelity 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 allocates aggregated trade orders for multiple client accounts.
• Provides pricing and other market data.
• Facilitates payment of our fees from our clients’ accounts.
• Assists with back-office functions, recordkeeping, and client reporting.
Fidelity also offers other services intended to help us manage and further develop our business enterprise.
These services include:
access to employee benefits providers, human capital consultants, and insurance providers.
• Educational conferences and events.
• Technology, compliance, legal, and business consulting.
• Publications and conferences on practice management and business succession.
•
Fidelity may provide some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to the Firm. Fidelity may also discount or waive its fees for some of these services or
pay all or a part of a third party’s fees. Fidelity may also provide the Firm with other benefits such as
occasional business entertainment of Firm personnel.
In connection with the launch of EVOKE and the Firm’s intention to recommend that clients custody their
assets with Fidelity, Fidelity has agreed to provide EVOKE with reimbursement of Transfer or Account
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Exit Fees. These funds will be used toward fees client accounts will bear if the accounts are transferred to
Fidelity. Fidelity has also agreed to pay for eligible third-party vendor services and services such as certain
marketing, technology, consulting, and research expenses provided by Fidelity affiliates.
The reimbursement of transition-related expenses by Fidelity presents a conflict of interest because it will
be used for the payment of expenses that do not directly benefit client accounts. The financial benefits
received from Fidelity do not reduce the investment management fees clients pay to EVOKE. These
products and services from Fidelity benefit EVOKE in that EVOKE does not have to purchase them. The
benefits provide an incentive for EVOKE to routinely recommend Fidelity as custodian over custodians
who do not offer such products and services. EVOKE addressed this conflict through this disclosure and
by reviewing the pricing of fees, expenses, and quality of services offered by Fidelity and determining that
the recommendation of Fidelity is in the best interest of clients.
EVOKE may offer certain qualified clients trading services which gives EVOKE the ability to execute
trades through other broker-dealers when placing securities transactions on behalf of clients with assets
custodied at Schwab, Fidelity, or another BD/Custodian. In such instances where EVOKE trades away from
Fidelity or another BD/Custodian, the account will incur a trade-away fee from a BD/Custodian for each
transaction that is executed on a trade-away basis. The fee is separate from the commission/transaction fee
or mark-up/mark-down imposed by the broker-dealer through which the trade was executed.
Trading away may be advantageous for the client because:
• The broker-dealer may have expertise in a particular security or market.
• The broker-dealer makes a market in a particular security.
• The particular security is thinly traded.
• The broker-dealer can identify a counter-party for a trade.
A client may pay higher net execution costs than he/she would have paid if the transaction were placed
through the BD/Custodian holding his or her assets.
EVOKE will periodically review its arrangements with BD/Custodians and other broker-dealers against
other possible arrangements in the marketplace as it strives to achieve best execution on behalf of its clients.
EVOKE maintains a list of broker-dealers that have been approved for trading clients’ assets away from a
BD/Custodian. 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, but not limited to, the following:
• A broker-dealer’s trading expertise, including its ability to complete trades, execute and settle
difficult trades, obtain liquidity to minimize market impact and accommodate unusual market
conditions, maintain anonymity, and account for its trade errors and correct them in a satisfactory
manner.
• A broker-dealer’s infrastructure, including order-entry systems, adequate lines of communication,
timely order execution reports, an efficient and accurate clearance and settlement process, and
capacity to accommodate unusual trading volume.
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• A broker-dealer’s ability to minimize total trading costs while maintaining its financial health, such
as whether a broker-dealer can maintain and commit adequate capital when necessary to complete
trades, respond during volatile market periods, and minimize the number of incomplete trades.
• A broker-dealer’s ability to provide research and execution services, including advice as to the
value or advisability of investing in or selling securities, analyses and reports concerning such
matters as companies, industries, economic trends and political factors, or services incidental to
executing securities trades, including clearance, settlement, and custody.
• A broker-dealer’s ability to provide services to accommodate special transaction needs, such as the
broker-dealer’s ability to execute and account for client-directed arrangements and soft dollar
arrangements, participate in underwriting syndicates, and obtain initial public offering shares.
As described above, Fidelity provides EVOKE, without cost, research and trade execution services. Fidelity
makes these services available to similarly situated investment advisers whose clients custody their assets
with Fidelity. Access to research and trade execution services is not predicated on the execution of client
securities transactions (e.g., not “soft dollars”). EVOKE has not entered into any formal “soft dollar”
arrangements with broker-dealers.
EVOKE’s clients may utilize qualified custodians other than Fidelity for certain accounts and assets,
particularly where clients have a previous relationship with such qualified custodians. EVOKE may choose
to recommend additional qualified custodians in the future.
Brokerage for Client Referrals
EVOKE does not consider, in selecting or recommending broker/dealers, whether the Firm receives client
referrals from the financial institutions or other third parties.
Client-Directed Brokerage
The client may direct EVOKE in writing to use a particular Financial Institution to execute some or all
transactions for the client. In that case, the client will negotiate terms and arrangements for the account with
that Financial Institution and the Firm will not seek better execution services or prices from other financial
institutions or be able to “batch” client transactions for execution through other financial institutions with
orders for other accounts managed by EVOKE (as described above). As a result, the client may pay higher
commissions or other transaction costs, greater spreads or may receive less favorable net prices, on
transactions for the account than would otherwise be the case. Subject to its duty of best execution, EVOKE
may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage
arrangements would result in additional operational difficulties.
B. Trade Aggregation
To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities,
including securities in which the Firm’s supervised persons may invest, the Firm will generally do so in a
fair and equitable manner in accordance with applicable rules promulgated under the Advisers Act and
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guidance provided by the staff of the SEC and consistent with policies and procedures established by the
Firm.
Item 13 – Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
EVOKE monitors investment advisory portfolios as part of a continuous and ongoing process. EVOKE
advisers aspire to meet quarterly with each client and have at least one annual meeting with every client to
conduct a formal review of each client’s account. These reviews may include the following:
• Comparing the account’s allocation with stated goals and client cash-flows at time of review.
• Reviewing holdings and considering alternatives.
• Monitoring the size of individual securities relevant to their sectors, asset classes, and overall
account size.
• Analyzing an account’s composition and performance, income, appreciation, gains or losses, and
asset allocation.
• Assessing the account’s performance.
Factors that may trigger an additional review, other than a periodic review, include material market,
economic, or political events, known significant changes in a client’s financial situation and/or objectives,
and large deposits or withdrawals from the accounts. Clients are encouraged to notify EVOKE if changes
occur in the client’s personal financial situation that might affect the client’s investment plan.
B. Other Reviews
EVOKE may perform compliance and/or supervisory reviews of a sampling of client accounts. These
reviews may include comparing an account’s strategy and/or allocation to the account’s stated objectives,
reviewing commission and transaction costs borne by the account, and reviewing the billing rate and
charges.
C. Content and Frequency of Regular Reports Provided to Clients
Clients will receive brokerage statements no less than quarterly from their respective qualified custodians.
These brokerage statements are sent directly from the custodian to the client. The client may also establish
electronic access to the custodian’s website so that the client may view these reports and their account
activity. Client brokerage statements will include all positions, transactions, and fees relating to the client’s
account(s). The client advisor may also provide clients with periodic reports regarding their holdings,
allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients
EVOKE does not receive benefits from third parties for providing investment advice to clients.
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B. Non-Economic Benefits Provided by Third Parties
As discussed in Item 12, EVOKE refers clients to Fidelity or one of its affiliates to provide custodial
services with respect to accounts managed by EVOKE. As described in detail in Item 12, EVOKE entered
into a Support Services Agreement with Fidelity, pursuant to which Fidelity paid for certain services related
to the transition of client accounts from other investment managers to EVOKE. These services, which
included (among others) technology, legal, and compliance related services associated with client transition
that were intended to support EVOKE in conducting its business and serving the best interests of its clients.
EVOKE's clients do not pay more for assets maintained at Fidelity as a result of this arrangement. However,
EVOKE benefitted from the referral arrangement because the cost of these transition-related services would
otherwise have been borne directly by EVOKE. Clients should consider this conflict of interest when
selecting a custodian.
EVOKE does not consider the provision of transition related services by Fidelity in the selection of brokers
or dealers for the exercise of transactions for client accounts.
C. Compensation to non-Supervised Persons for Client Referrals
EVOKE has entered into referral arrangements with unaffiliated entities and individuals who may from
time-to-time refer potential investors and/or clients to EVOKE for investment management services and be
compensated for successful referrals by receiving a percentage of the advisory fee EVOKE receives from
such clients. These unaffiliated entities and individuals are considered promoters and/or sponsors under the
Marketing Rule of the Advisers Act, and as such, any arrangements entered into are in compliance with
Rule 206(4)-1 of the Advisers Act.
Item 15 – Custody
Rule 206(4)-2 of the Advisers Act (the "Custody Rule") sets forth extensive requirements regarding
possession or custody of client funds or securities. The Custody Rule requires advisers that have custody
of client funds or securities to implement a set of controls designed to protect those client assets from being
lost, misused, misappropriated, or subject to financial reverses.
Pursuant to Rule 206(4)-2, EVOKE is deemed to have custody of client Account's funds and securities
because (i) EVOKE may debit fees directly from the accounts of such clients and/or (ii) certain clients have
executed a letter of instruction or similar asset transfer authorization arrangement with a qualified custodian
whereby EVOKE is authorized to withdraw client funds or securities maintained with a qualified custodian
upon our instruction to the qualified custodian. EVOKE intends to comply with Rule 206(4)-2 and the
relevant SEC staff guidance thereunder.
EVOKE may also be deemed to have custody and “safe keeping requirements” of certain client brokerage
accounts where it arranges transfers to certain Private Funds sponsored or managed by EVOKE or its
affiliates out of convenience for the client. In order to meet such requirements, EVOKE has ensured:
• Such brokerage accounts are held by qualified custodians.
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• Such brokerage accounts are opened directly by the client, not by EVOKE.
• Account statements are sent to the client’s address on file directly by the qualified custodian.
The BD/Custodian recommended by EVOKE has agreed to send a statement to the client, at least quarterly,
indicating all amounts disbursed from the account including the amount of management fees paid directly
to EVOKE. EVOKE encourages clients to review the official statements provided by the BD/Custodian,
and to compare such statements with investment reports received from EVOKE or any other outside vendor.
For more information about BD/Custodians and brokerage practices, see Item 12, Brokerage Practices.
EVOKE has custody of select client assets related to business management and/or trustee services pursuant
to a written FOSA. All Clients must place their assets with a qualified custodian. Clients are required to
enter a separate agreement with the Custodian to retain their funds and securities and direct EVOKE to
utilize the Custodian for the Client’s security transactions. Clients should review statements provided by
the Custodian and compare to any reports provided by EVOKE to ensure accuracy as the Custodian does
not perform this review.
Pursuant to securities regulations, EVOKE is required to engage an independent accounting firm to perform
an annual surprise examination of those assets and certain of those accounts over which EVOKE maintains
custody. Any related opinions issued by an independent accounting firm are filed with the SEC and are
publicly available on the SEC’s Investment Adviser Public Disclosure website (http://adviserinfo.sec.gov).
Item 16 – Investment Discretion
Clients have the option of providing EVOKE with investment discretion on their behalf, pursuant to a grant
of a limited power of attorney contained in EVOKE’s client agreement. By granting EVOKE investment
discretion, a client authorizes EVOKE to direct securities transactions and determine which securities are
bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be
effected. Clients may impose reasonable limitations in the form of specific constraints on any of these areas
of discretion with the consent and written acknowledgement of EVOKE. See also Item 4(C), Client-
Tailored Advisory Services.
Item 17 – Voting Client Securities
As a matter of policy, EVOKE does not vote client securities (proxies) held in client accounts. The client
remains responsible for such matters.
Item 18 – Financial Information
A. Balance Sheet
EVOKE does not require prepayment of more than $1,200 in fees per client, six months or more in advance,
and therefore has not included a balance sheet with this Brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual
Commitments to Clients
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Neither EVOKE nor its management has any financial conditions that are reasonably likely to impair its
ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Years
EVOKE has not been the subject of a bankruptcy petition.
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