SEQUOIA WEALTH MANAGEMENT GROUP LLC

Item 1: Cover Page ADV Part 2A Firm Brochure Sequoia Wealth Management Group LLC 2026 Rocking Horse Rd. Gardnerville, NV 89410 Mailing Address: PO Box 1449 Minden, NV 89423 Phone: 707-763-8600 www.sequoiawmg.com March 17, 2025 This brochure provides information about the qualification and business practices of Sequoia Wealth Management Group LLC. If you have any questions about the contents of this brochure, please contact us at 707-763-8600, or by email at Matt@sequoiawmg.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Sequoia Wealth Management Group LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Registration does not imply a certain level of skill or training, and no inference to the contrary should be made.  There are no material changes since our last brochure dated August 6, 2024. Item 2: Material Changes 2 | P a g e  Table of Contents Item 1: Cover Page ........................................................................................................................................ 1 Item 3: Item 2: Material Changes .............................................................................................................................. 2 Item 3: Table of Contents ............................................................................................................................. 3 Item 4: Advisory Business ............................................................................................................................. 4 Item 5: Fees and Compensation ................................................................................................................... 5 Item 6: Performance-Based Fees & Side-by-Side Management ................................................................... 6 Item 7: Types of Clients ................................................................................................................................. 6 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 7 Item 9: Disciplinary Information ................................................................................................................... 8 Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 8 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 8 Item 12: Brokerage Practices ........................................................................................................................ 9 Item 13: Review of Accounts ...................................................................................................................... 10 Item 14: Client Referrals and Other Compensation.................................................................................... 11 Item 15: Custody ......................................................................................................................................... 11 Item 16: Investment Discretion .................................................................................................................. 11 Item 17: Voting Client Securities ................................................................................................................. 11 Item 18: Financial Information ................................................................................................................... 11  Firm Description Item 4: Advisory Business Sequoia Wealth Management Group, LLC (“Sequoia”) is a Nevada limited liability company formed in 2010. Principal Owners The principal owner of Sequoia is Matthew Schafer. Types of Services Sequoia provides investment management, financial planning, and consulting services to individuals and small/closely held businesses, hereinafter referred to as (“Client”). At Sequoia we believe no two investors are alike and that each has different circumstances and aspires to different dreams. For all prospective Clients, Sequoia conducts a Discovery Meeting to deeply comprehend not only the Client’s investment objectives and risk tolerances, but also their most important values, goals, relationships and interests. This level of insight allows Sequoia to construct an investment plan appropriate for the Client, set the foundation for a long-term relationship, and work with the Client precisely the way they prefer. Sequoia offers ongoing investment management services based on the individual goals, objectives, time Investment Management Services horizon, and risk tolerance of each Client. Sequoia creates an Investment Policy Statement for each Client, which outlines the Client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Sequoia evaluates the current investments of each client with respect to their risk tolerance levels and time horizon and ability to meet their goals. Sequoia will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Financial Planning/Consulting services my include but are not limited to life goal planning, business Financial Planning/Consulting Services planning support, retirement planning consulting, estate and trust planning, and assistance with life and disability insurance. These services are generally inclusive of the firms’ investment management services; however, Clients may engage Sequoia separately for them as well. See the Fees and Compensation section below for how these services are billed. In addition to the above services and depending upon the Client’s individual needs, Sequoia may act as Other Services trustee or successor trustee. This service will always include an additional charge distinct and separate from any Investment Management and/or Financial Planning/Consulting fees. A description of services and fees associated are defined within the Client’s agreement with Sequoia. 4 | P a g e  Tailored Relationships All investment accounts will be managed in accordance to set model portfolios or strategies. The model portfolios or strategies recommended for the Client will be based on the Client’s investment objectives, goals and risk tolerances. Sequoia will not allow Client’s to impose restrictions on their investment accounts. Client Assets As of December 31, 2024, Sequoia has discretionary regulatory assets under management of approximately $ 240,881,276. Description Item 5: Fees and Compensation Sequoia is compensated for its investment management services through an asset-based fee, based on the fair market value of the assets managed. Fees are assessed quarterly in advance. The current fee schedule is: $450,000 - $2,000,000 $2,000,001 - $5,000,000 $5,000,001 - $10,000,000 Above $10,000,001 1.60% 1.50% 1.25% 1.00% These fees include all financial planning and consulting services. There is a minimum flat fee of $1,750 per quarter. The fee is negotiable based on factors such as the size and complexity of the mandate, the services to be provided, anticipated additional assets to be added to the account, and other unique needs or attributes of the Client. If a Client would like to engage Sequoia for financial planning/consulting services only, Sequoia will charge a project-based flat fee that is either fixed or an hourly rate based on the estimated time to complete the project. The total fee, terms and conditions for the project will be presented to the Client and documented in the consulting services agreement before any work is commenced. The estimated time to complete the project is based on the projected number of hours to: review documents, complete the analysis, create a customized findings’ report and present the findings and recommendations to the Client. A non-refundable deposit of $1,000 fee is required, with the balance due on completion. If a Client would like to engage Sequoia for trustee and/or bill pay services, Sequoia will charge fees additional and separate to the fees described above. The fees are negotiable and will be fully disclosed in an executed agreement between the Client and Sequoia. 5 | P a g e  Fee Billing Sequoia deducts fees for the investment management services directly from Client accounts as authorized in writing by the Client in the investment advisory agreement. Fees for financial planning/consulting services only will be invoiced to the Client. Other Fees Clients should note that there are other fees associated with their account in addition to Sequoia’s advisory fee. For example, ETFs and mutual funds assess their own internal management and other fees. In addition, Clients may incur brokerage and other transaction charges (commissions), and custodial fees. These are assessed by the broker selected for execution and by the custodian(s) clients choose to hold their assets. Please see Item 12: Brokerage Practices for more information on Sequoia’s approach to Clients’ brokerage and custody options. Fees Paid in Advance Our services may be terminated by either party at any time with 30 days written notice. Any pre-paid fees will be refunded pro-rata from the date of termination, which is determined as the 30th day after written notice, with the exception of the $1,000 deposit for financial planning services only. Item 6: Performance-Based Fees & Side-by-Side Sequoia does not receive performance-based fees. Management Description Item 7: Types of Clients Sequoia provides services to individuals, estates and trusts, charitable organizations and small/closely held businesses. Account Minimums The minimum account size for new accounts is generally $500,000 per household, although Sequoia may elect to reduce or waive this requirement. There is no minimum account size required for only providing financial planning/consulting services. 6 | P a g e  Item 8: Methods of Analysis, Investment Methods of Analysis Strategies and Risk of Loss Sequoia’s objective is to attain an efficiency where the standard deviation gets the maximum return, while taking risk that is compensable. Investment Strategies Sequoia considers rolling ten-year periods when evaluating investments, strategies, and allocations. Portfolios will be held through market downturns. Rebalancing and the addition of new assets will be utilized as ways to capture opportunities during volition markets. Tactical moves will be limited as it reflects a short-term activity that tends to conflict with the firm’s longer-term planning. Sequoia will hold cash positions to ensure that planned and unplanned liquidity needs can be met. Cash positions reduce the need to sell holdings at inopportune times and allow the portfolios to weather market downturns. Investments need to serve the current needs of the clients while working towards future goals. Risk of Loss Investing in securities involves a risk of loss that you, as a Client, should be prepared to bear. Some of the specific risks are listed below. Equity Securities Risk - Stocks generally fluctuate in value more than bonds and may decline significantly over short time periods. There is the chance that stock prices overall will decline because stock markets tend to move in cycles, with periods of rising prices and falling prices. The value of a stock in which a fund invests may decline due to general weakness in the stock market or because of factors that affect a company or a particular industry. Exchange Traded Funds and Mutual Funds - An investment in an ETF or mutual fund involves risk, including the potential loss of principal. Mutual fund and ETF shareholders are subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Shareholders in funds also are responsible 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. The managers of the ETFs and mutual funds selected also may make poor investment decisions that cause them to underperform the benchmarks to which they compare their performance. Fixed Income Security Risk - Bonds have two main sources of risk. Interest rate risk is the risk that a rise in interest rates will cause the price of a debt security held by the fund to fall. Securities with longer maturities typically suffer greater declines than those with shorter maturities. Mortgage-backed securities can react somewhat differently to interest rate changes because falling rates can cause losses of principal due to increased mortgage prepayments and rising rates can lead to decreased prepayments 7 | P a g e  and greater volatility. Credit risk is the risk that an issuer of a debt security will default (fail to make scheduled interest or principal payments), potentially reducing income distributions and market values. This risk is increased when a security is downgraded or the perceived creditworthiness of the issuer deteriorates. Neither the firm nor its supervised persons has any legal or disciplinary events to disclose. Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Sequoia nor any supervised persons of Sequoia is affiliated with any entity, registered as a broker- Affiliations dealer, a futures commission merchant, commodity pool operator, or a commodity trading adviser. Sequoia utilizes the services of 55ip, a third party and unaffiliated entity, to outsource trading activities within client accounts. There will be no additional charges to clients as a result and Sequoia will remain the discretionary investment advisor. Item 11: Code of Ethics, Participation or Interest Code of Ethics in Client Transactions and Personal Trading Sequoia seeks to avoid conflicts of interest that could arise if its employees engage in personal investing for their own accounts. Sequoia has adopted a Code of Ethics which defines the standard of conduct that employees are required to maintain. The Code of Ethics includes provisions relating to personal securities trading and reporting procedures, conflicts of interest, and insider trading among other things. All Sequoia personnel must acknowledge the terms of the Code of Ethics upon hire, and when amendments are implemented. Clients or prospective clients may contact Sequoia to request a copy of the firm’s Code of Ethics. Invest in Same Securities Recommended to Clients Sequoia employees are permitted to buy and sell securities for their own personal investment accounts provided they comply with the Code of Ethics’ procedures and reporting requirements which are designed to prevent any potential conflict of interest with client transactions. Sequoia believes that these procedures are adequate to prevent any intentional or inadvertent conflict of interest. However, it is possible that, from time to time, Sequoia may recommend to clients, or purchase for or sell from 8 | P a g e  clients’ portfolios, securities that are also held in the personal investment portfolios of Sequoia employees. Personal Trading Policies Sequoia has a policy in place to monitor the personal securities transactions and securities holdings of its employees and their immediate family members. Sequoia‘s policy requires that each employee and their immediate family members provide the Chief Compliance Officer with a written report of his or her current securities holdings within ten (10) days after becoming an employee and annually thereafter. In addition, each employee and their immediate family member must provide the Chief Compliance Officer transactions on a quarterly basis. Selecting Brokerage Firms Item 12: Brokerage Practices Sequoia selects the brokers and dealers to effect client transactions unless a client provides specific instructions about placement of brokerage. Sequoia evaluates brokerage firms in terms of their best execution capabilities. Best execution considers more than just whether the broker will provide the best price for the desired transaction. In addition to the best price, best execution considers the overall reasonableness of brokerage commissions paid and other factors such as the level of service provided, the receipt of research products and services, investment product availability, technology solutions and access to analysis of economic and market data. Sequoia generally recommends to clients that they use either Raymond James & Associates, Inc. member New York Stock Exchange/SPIC or Charles Schwab & Co, Inc. as the qualified custodian for their discretionary investment management account. Research and Soft Dollars Sequoia does not participate in any formalized soft dollar arrangements. However, Sequoia may receive research and trading related products and services from brokerage firms, including Raymond James and Schwab. These products and services are generally made available to independent investment advisers such as Sequoia. Sequoia ’s recommended brokerage firms, Raymond James and Schwab, have a commission structure for trading securities that is competitive with the structures used industry-wide for similar types of trading. Nonetheless, Sequoia’s receipt of products and services creates a potential conflict of interest based on Sequoia’s recommendation of Raymond James and Schwab. Sequoia’s objectivity in evaluating brokerage firms could potentially be compromised. Sequoia seeks to manage this risk through its oversight of trading and any soft dollar products or services received. Brokerage for Client Referrals Sequoia does not receive client referral from broker dealers. 9 | P a g e  Directed Brokerage Clients may direct Sequoia, in writing, to direct their brokerage, if the firm is capable. The client may pay higher brokerage commission and other fees that might otherwise be paid had Sequoia been granted discretion to select the broker. In addition, if a client directs Sequoia to use a particular broker, Sequoia may not be able to aggregate trades with other clients. Order Aggregation Where feasible for transactions in the same security, Sequoia seeks to block orders for all clients into a single transaction with the objective of obtaining one average price for all participating clients. Sequoia follows this trade allocation policy among clients that are transacting in the same security. If an order is partially filled, the shares will be allocated to clients included in the batched order on a prorated basis based on the size of each participating client’s order or with other methodologies designed to treat all clients fairly over time. For block orders of a given security involving clients of multiple brokerage firms, Sequoia will place separate block orders per brokerage firm. Due to any timing difference in order entry and execution, clients of one brokerage firm may receive a different average price versus clients with another brokerage firm. Sequoia rotates the order of the respective brokerage firm trades to try to ensure that clients of a particular brokerage firm are not favored over other clients. Withdrawal or movement of funds The Advisor and its employees will not be responsible for any cost, or losses due to trade error resulting from insufficient funds due to the client withdrawing or moving money from the brokerage account without informing Sequoia at least 24 hours before the withdrawal. Sequoia bases trade considerations on the amount of funds in each brokerage account at any given time. A client withdrawing funds without informing Sequoia may cause Sequoia to effectuate trades without the proper funds. Client agrees to cover any losses incurred from a trade error caused by Client withdrawing funds without informing Sequoia. Periodic Reviews Item 13: Review of Accounts All portfolios are reviewed by Matt Schafer, Founder. The model portfolios are reviewed throughout the year as needed. A formal review will occur with the Client as least annually and more frequently as needed. Regular Reports Clients will receive a statement directly from their custodian on at least a quarterly basis that details the holdings and transactions. 10 | P a g e  Item 14: Client Referrals and Other Sequoia does not have any solicitations or referral arrangements in place. Compensation Sequoia does not maintain physical custody of client assets. Sequoia is considered to have custody Item 15: Custody because the Client’s investment management agreement gives us the authority to deduct fees directly from client accounts. All client assets are held with a qualified custodian; the custodian sends account statements directly to clients at least quarterly. Clients should carefully review these statements. In addition, Sequoia may offer trustee services to its advisory Clients. In such cases, the Firm is considered to have custody and Sequoia will obtain a surprise custody examination. Sequoia has discretionary authority to buy and sell securities held in the accounts of its clients. Clients Item 16: Investment Discretion grant Sequoia this authority by executing an investment management agreement with Sequoia. Sequoia executes transactions based solely on its assessment of which trades will best implement its stated strategy. Sequoia does not vote proxies for clients. Clients are expected to vote their own proxies and receive Item 17: Voting Client Securities their proxies directly from the custodian. Clients may contact us if they have questions on their proxies. Sequoia does not require or solicit prepayment of more than $1,200 for six months; fees are billed and Item 18: Financial Information paid quarterly. Sequoia is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual obligations to clients. Sequoia has never been the subject of a bankruptcy petition. 11 | P a g e