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SOUND VIEW WEALTH ADVISORS GROUP, LLC
FORM ADV PART 2A
BROCHURE
Item 1 – Cover Page
1 Skidaway Village Walk
Suite 201
Savanah, GA 31411
(912) 239-4630
www.svadvice.com
This brochure provides information about the qualifications and business practices of Sound View Wealth Advisors
Group, LLC. If you have any questions regarding the contents of this brochure, please do not hesitate to contact our
Chief Compliance Officer, Melissa Bouchillon, by telephone at (912) 239-4630 or by email at melissa@svadvice.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.
Sound View Wealth Advisors Group, 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. Additional
information about Sound View Wealth Advisors Group, LLC is available on the SEC’s website at www.adviserinfo.sec.gov.
March 19, 2025
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Item 2 – Material Changes
Form ADV Part 2A 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.
Since our last annual update filed on March 28, 2024, the following are material changes to this brochure:
In October 2024, the following updates were made to this brochure:
o All references to Focus Risk Solutions “FRS” were removed from Items 4, 5, and 10 of this brochure since
we no longer participate in that program;
o A reference to a related entity, Sound View Wealth Advisors Insurance, LLC, was added to Item 10;
o
Item 12 was updated to reflect current trade error correction processes.
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Item 3 - Table of Contents
Item 1 – Cover Page
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Item 2 – Material Changes
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Item 3 - Table of Contents
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Item 4 - Advisory Business
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Item 5 - Fees and Compensation
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Item 6 - Performance-Based Fees and Side-by-Side Management
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Item 7 - Types of Clients
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Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss
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Item 9 - Disciplinary Information
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Item 10 – Other Financial Industry Activities and Affiliations
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Item 11 – Code of Ethics, Participation or Interest in Client Transactions
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Item 12 – Brokerage Practices
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Item 13 – Review of Accounts
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Item 14 – Client Referrals and Other Compensation
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Item 15 – Custody
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Item 16 – Investment Discretion
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Item 17 – Voting Client Securities
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Item 18 – Financial Information
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Item 4 - Advisory Business
A.
Description of the Advisory Firm
Sound View Wealth Advisors Group, LLC (“Sound View Wealth” or the “Firm”) is an investment advisory firm that was
registered with the United States Securities and Exchange Commission (“SEC”) on March 26, 2019. Sound View Wealth
acquired the advisory business of Sound View Wealth Advisors, LLC which was registered with the United States
Securities and Exchange Commission (“SEC”) on January 3, 2018. Sound View Wealth is a limited liability company
organized in Delaware.
Sound View Wealth is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Sound View
Wealth is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is the sole managing member of
Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate
Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton,
Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect
owners of Focus LLC. Because Sound View Wealth is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone
Point investment vehicles are indirect owners of Sound View Wealth.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business
managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and
investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or
advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs.
We have a business arrangement with SCS Capital Management LLC (“SCS”), who is an indirect, wholly-owned subsidiary
of Focus LLC and Focus Inc., under which certain clients of Sound View Wealth have the option of investing in certain
private investment vehicles managed by SCS. Sound View Wealth is an affiliate of SCS by virtue of being under common
control with it. Please see Items 5, 10, and 11 of this Brochure for further details.
Sound View Wealth is managed by Kelly Bouchillon, Melissa Bouchillon, O. Emerson Ham III, and Edward Ambrose
(“Sound View Wealth Principals”), pursuant to a management agreement between SVWA Partners and Sound View
Wealth. The Sound View Wealth Principals serve as officers of Sound View Wealth and are responsible for the
management, supervision and oversight of Sound View Wealth.
B.
Types of Advisory Services
Sound View Wealth provides holistic and personalized financial planning and discretionary and non-discretionary
investment advisory services to individuals, including high net worth individuals, and entities, including, but not limited
to, family offices, trusts, estates, private foundations, and qualified retirement plans.
Financial Planning and Consulting Services 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.
A financial plan developed for or financial consultation rendered to the client will typically include general
recommendations for a course of activity or specific actions to be taken by the client. For example, recommendations
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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. Sound View Wealth may recommend the services of itself and/or
other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Sound View
Wealth recommends its own services, as such a recommendation may increase the advisory fees paid to Sound View
Wealth. The client is under no obligation to act upon any of the recommendations made by Sound View Wealth under a
financial planning or consulting engagement to engage the services of any such recommended professional, including
Sound View Wealth itself.
Investment Management Services
In designing and implementing customized models and portfolio strategies, Sound View Wealth can manage, on a
discretionary or nondiscretionary basis, a broad range of investment strategies and vehicles. Sound View Wealth
primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and individual debt and
equity securities in accordance with clients’ stated investment objectives.
Sound View Wealth may further recommend to clients that all or a portion of their investment portfolio be managed on
a discretionary basis by one or more unaffiliated 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 or will receive a Statement of Investment Selection in
a single contract relationship. Sound View Wealth generally renders services to the client relative to the discretionary
selection of External Managers. Sound View Wealth 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, the annual advisory fee charged by Sound View Wealth.
Investment Management Services for Qualified Retirement Plans
Discretionary Investment Advisory Services to Plans: When serving in a discretionary investment advisory capacity for a
Plan, Sound View Wealth is in the status defined by section 3(38) of the Employee Retirement Income Security Act of
1974 (“ERISA”). As a discretionary investment advisor to qualified retirement plans (“Plans”) Sound View Wealth
assumes the fiduciary responsibility for the selection, monitoring and replacement of the investment options of the Plan.
As an initial action step, Sound View Wealth seeks to obtain the investment policy statement for the Plan that details the
methodologies and criteria utilized to define the style universe of investment options, the specific investment options to
be utilized and the ongoing criteria for monitoring and replacing investment options. If the Plan does not have an
investment policy statement Sound View Wealth may assist the Plan sponsor/trustees of the Plan in drafting an
investment policy statement. In instances where an investment policy statement is not available, Sound View Wealth
will collect information from the Plan sponsor/trustees determined necessary for Sound View Wealth’s provision of
services to the Plan.
In its role as a 3(38) fiduciary, Sound View Wealth is only responsible for those Plan investments selected by Sound View
Wealth and Sound View Wealth has no responsibility for any other Plan investments maintained in the Plan by direction
of the Plan sponsor/trustees or any other person or entity. As an example, employer securities and investments held in a
directed brokerage account are not subject to any fiduciary responsibility or duty on the part of Sound View Wealth.
Furthermore, the Plan sponsor/trustees should be aware that when Sound View Wealth assumes the investment
responsibilities by serving as a 3(38) fiduciary, the Plan sponsor/trustees retain all of their fiduciary duties, obligations
and responsibilities pursuant to applicable law.
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Non-Discretionary Investment Advisory Services to Plans: When serving in a non-discretionary investment advisory
capacity for a Plan, Sound View Wealth is in the status defined by section 3(21) of ERISA. In this capacity, Sound View
Wealth assumes no fiduciary responsibility for the completion of an investment policy statement or any aspect of the
definition, selection, maintenance or replacement of any Plan investment options. In this non-discretionary role Sound
View Wealth provides information to the Plan sponsor/trustees regarding investment option style parameters and
performance reporting. The Plan sponsor/trustees exercise full authority over the selection of Plan investment options
and may, or may not, utilize the information provided by Sound View Wealth as part of their decision making process.
These other
Other Services for Plans: As part of providing the discretionary or non-discretionary investment services to Plans, Sound
View Wealth may provide certain information and services to the Plan and the Plan sponsor/trustees.
services are designed to assist the Plan sponsor/trustees in meeting their management and fiduciary obligations to the
Plan. The other services may consist of the following:
Assist with platform provider search and Plan set-up;
Plan review;
Plan fee and cost review;
Acting as third party service provider liaison;
Plan participant education and communication;
Plan benchmarking;
Assist with Plan conversion to new vendor platform; and
Assistance in Plan merger.
Additional Information Regarding ERISA Plans and Individual Retirement Accounts
As detailed above, Sound View Wealth is a fiduciary under ERISA with respect to investment management services and
investment advice provided to ERISA plan clients, including ERISA plan participants. Sound View Wealth is also a
fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with respect to investment management services
and investment advice provided to ERISA plans, ERISA plan participants, individual retirement accounts and individual
retirement account owners (collectively “Retirement Account Clients”). As such, Sound View Wealth is subject to specific
duties and obligations under ERISA and the IRC, that include, among other things, prohibited transaction rules which are
intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a
conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction
exemption (a “PTE”). In addition, the way Sound View Wealth makes money creates some conflicts with your interests,
so Sound View Wealth operates under a special rule that requires Sound View Wealth to act in your best interest and
not put our interest ahead of yours.
UPTIQ Treasury & Credit Solutions
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions
through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5
and 10 for a more complete discussion of these services and other important information.
C.
Client-Tailored Advisory Services
Sound View Wealth provides portfolio management services using investment models designed to meet a variety of
client investment objectives. Client portfolios are managed on the basis of individual clients’ financial situation and
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investment objectives. Clients may impose reasonable restrictions on the management of their accounts if Sound View
Wealth determines, in its sole discretion, that the conditions would not materially impact the performance of a
management strategy or prove overly burdensome for Sound View Wealth’s management efforts.
D.
Assets Under Management
As of December 31, 2024, Sound View Wealth had $1,937,657,662 in assets under management, of which
$1,924,665,025 were managed on a discretionary basis.
Item 5 - Fees and Compensation
A. Fee Schedule for Advisory Services
ADVISORY FEE SCHEDULE
Market Value of Assets
Rate
Up to $499,999
1.5%
$500,000 to $999,999
1.25%
$1,000,000 to $1,999,999
1.1%
$2,000,000 to $4,999,999
.95%
$5,000,000 to $9,999,999
.75%
$10,000,000 to $24,999,999
.60%
$25,000,000 to $49,999,999
.50%
$50,000,000 to $99,999,999
.40%
$100,000,000 and above
customizable
The percentage for the highest range of Managed Asset value achieved applies to all
Managed Assets, not just Managed Assets within that range.
Sound View Wealth charges an annual advisory fee that is agreed upon with each client and set forth in an agreement
executed by Sound View Wealth and the client. If based on a percentage of the value 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 market value of
the assets under management. For subsequent quarters, the advisory fee generally is payable in advance (except for
services to participant-directed 401k plans, which generally are payable in arrears), based on the average daily market
value of the client’s accounts through the last day of the previous quarter as provided by third-party sources. For both
the initial quarter and subsequent quarters, the value of assets under management will include cash, accrued interest
and securities held on margin. 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.
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Notwithstanding the foregoing, we have legacy clients who are subject to a different fee schedule than the schedule set
forth above, and our fees are subject to negotiation. Factors upon which a different annual advisory fee may be based
include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity
of the products and investments involved, time commitments, and travel requirements. The advisory fee charged by the
Firm will apply to all of the client’s assets under management, unless specifically excluded in the client agreement. The
advisory fee may include the financial planning services described above.
Clients have five (5) business days from the date of execution of the client agreement to terminate Sound View Wealth’s
services. The investment advisory agreement between Sound View Wealth and the client may be terminated at will by
either Sound View Wealth or the client upon written notice. Sound View Wealth does not impose termination fees when
the client terminates the investment advisory relationship, except when agreed upon in advance.
Sound View Wealth offers its clients financial planning services. Such services, for some clients, may be included as part
of the annual advisory fee. Clients may also enter into a separate agreement with Sound View Wealth for financial
planning services. Such fee is negotiable, and is based on either an hourly rate that varies, depending on the experience,
knowledge, and skill of those performing the services on behalf of Sound View Wealth, or a flat fee agreed upon in
writing by Sound View Wealth and the client.
The hourly rate for ad-hoc and project-based consultations for clients varies depending on the services provided and the
experience, knowledge, and skill of those performing the services on behalf of Sound View Wealth. Hourly rates may
generally range from $250 to $500 per hour. The scope and charges of all hourly ad-hoc work must be agreed-upon in
writing by Sound View Wealth and the client before any billing begins.
B. Payment of Fees
Sound View Wealth generally deducts its advisory fee from a client’s investment account(s) held at his/her custodian.
Upon engaging Sound View Wealth to manage such account(s), a client grants Sound View Wealth 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.
See Section A herewith for further information on fee billing. A client may utilize the same procedure for 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, Sound View Wealth 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 Sound View Wealth.
Clients may make additions to and withdrawals from their account at any time, subject to Sound View Wealth’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 Sound View Wealth, 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. Sound View Wealth 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.
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C.
Clients Responsible for Fees Charged by Financial Institutions and External Money Managers
In addition to Sound View Wealth’s advisory fee, clients will be responsible for the fees and expenses of the broker-
dealers who execute securities transactions for client accounts (such as commissions and mark-ups or mark-downs),
custodian(s), underlying mutual funds, ETFs, private investment funds, External Managers and their platform manager (if
any), 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),
electronic fund and wire fees. Clients should review the applicable prospectuses or private placement memoranda for
additional information about fund fees and expenses. For External Managers, clients should review each manager’s
Form ADV 2A disclosure brochure for additional information about fees and expenses charged.
D.
Prepayment of Fees
As noted in Item 5(B) above, Sound View Wealth’s advisory fees generally are paid in advance. Upon the termination of
a client’s advisory relationship, Sound View Wealth 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).
E.
Outside Compensation for the Sale of Securities or Other Investment Products to Clients
An advisory person of Sound View Wealth is a registered representative of Purshe Kaplan Sterling Investments (“PKS”), a
FINRA member broker-dealer, and through this relationship receives transaction-based compensation for annuities
where PKS is the broker of record. This is a potential conflict of interest in that it could incentivize the recommendation
of annuities based on the compensation the advisory person receives, rather than on a client’s needs. Sound View
Wealth addresses this conflict through this disclosure. Additionally, neither the advisory person nor Sound View Wealth
receive advisory fees on these annuities (e.g., they do not “double dip”).
Certain advisory persons of Sound View Wealth are licensed as insurance professionals for an affiliated entity, Sound
View Wealth Advisors Insurance, LLC. Such persons earn commission-based compensation for selling insurance products
to clients. Insurance commissions earned by advisory persons who are insurance professionals are separate from and in
addition to Sound View Wealth’s advisory fee. This practice presents a conflict of interest as an advisory person who is
an insurance professional may have an incentive to recommend insurance products for the purpose of generating
commissions rather than solely based on client needs. Clients are under no obligation to purchase insurance products
through any person affiliated with Sound View Wealth. Additionally, Sound View Wealth Advisors Insurance, LLC
permits advisory persons of Sound View Wealth to continue to earn commissions from insurance policies which the
advisory persons sold previously for a different entity.
We do not receive any compensation from SCS in connection with assets that our clients place in SCS’s pooled
investment vehicles. Sound View Wealth’s clients are not advisory clients of and do not pay advisory fees to SCS.
However, our clients bear the costs of SCS’s investment vehicle or vehicles in which they are invested, including any
management fees and performance fees payable to SCS. The allocation of Sound View Wealth client assets to SCS’s
pooled investment vehicles, rather than to an unaffiliated investment manager, increases SCS’s compensation and the
revenue to Focus LLC relative to a situation in which our clients are excluded from SCS’s pooled investment vehicles. As
a consequence, Focus LLC has a financial incentive to cause us to recommend that our clients invest in SCS’s pooled
investment vehicles.
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We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions
through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Focus Financial
Partners, LLC (“Focus”) is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by
such third-party financial institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ Inc.’s
investors, including Focus, our parent company. When legally permissible, UPTIQ also shares a portion of this earned
revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For non-residential mortgage loans made to our
clients, UPTIQ will share with FSH up to 25% of all revenue it receives from such third-party financial institutions. For
securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it
receives from such third-party financial institutions. For cash management products and services provided to our
clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and
other intermediaries that provide administrative and settlement services in connection with this program. This earned
revenue is indirectly paid by our clients through an increased interest rate charged by the third-party financial
institutions or, for cash balances, a lowered yield. FSH distributes this revenue to us when we are licensed to receive
such revenue (or when no such license is required) and the distribution is not otherwise legally prohibited. Further
information on this conflict of interest is available in Item 10 of this Brochure.
Item 6 - Performance-Based Fees and Side-by-Side Management
Sound View Wealth does not charge performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of a 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 fees. Sound View Wealth’s fees are calculated as
described in Item 5 above.
Item 7 - Types of Clients
Sound View Wealth offers investment advisory services to individuals, including high net worth individuals, families,
family offices, trusts, businesses, charitable foundations, and retirement/profit-sharing plans.
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Risk of Loss
A primary step in Sound View Wealth’s investment strategy is getting to know the clients – to understand their financial
condition, risk profile, investment goals, tax situation, liquidity constraints – and assemble a complete picture of their
financial situation. To aid in this understanding, Sound View Wealth offers clients financial planning that is highly
customized and tailored. This comprehensive approach is integral to the way that Sound View Wealth does business.
Once Sound View Wealth has a true understanding of its clients’ needs and goals, the investment process can begin, and
the Firm can recommend strategies and investments that it believes are aligned with the client’s goals and risk profile.
Sound View Wealth primarily employs fundamental analysis methods in developing investment strategies for its clients.
Research and analysis from Sound View Wealth is based on numerous sources, including third-party research materials
and publicly-available materials, such as company annual reports, prospectuses, and press releases.
Sound View Wealth generally employees a long-term investment strategy for its clients, as consistent with their financial
goals. Sound View Wealth will typically hold all or a portion of a securities position for more than a year, but may hold
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for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of clients. At times, the Firm
may also buy and sell positions that are more short-term in nature, depending on the goals of the client and/or the
fundamentals of the security, sector or asset class.
Sound View Wealth has an investment committee. The investment committee selects assets and products from across
many asset classes, including global and domestic equities, taxable and non-taxable fixed income, mutual funds and
ETFs. Once the investment committee reviews and approves mutual funds and ETFs, they are added to the Firm’s model
portfolios and approved list and may be purchased for clients. Similarly, Sound View Wealth may select External
Managers to manage a portion of its clients’ assets. The investment committee also reviews and approves the External
Managers in which the Firm has placed client assets. Overall investment strategies recommended to each client
emphasize long-term ownership of a diversified portfolio of marketable and non-marketable investments intended to
provide superior after-tax, inflation-adjusted, economic returns.
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, income needs, long-term wealth transfer
objectives, time horizon and choice of custodian are all factors that influence Sound View Wealth’s investment
recommendations.
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.
B. Material Risks Involved
The mutual funds, ETFs and External Managers that the Firm frequently invests client assets with or recommends to
clients generally own securities and therefore also involve the risk of loss that is inherent in investing in securities. The
extent of the risk of ownership of fund shares generally depends on the type and number of securities held by the fund.
Mutual funds invested in fixed income securities are subject to the same interest rate, inflation, and credit risks
associated with the fund’s underlying bond holdings. Fixed income securities may decrease in value as a result of many
factors, for example, increases in interest rates or adverse developments with respect to the creditworthiness of the
issuer. Risks also may be significantly increased if a mutual fund pursues an alternative investment strategy. An
investment in an alternative mutual fund involves special risks such as risk associated with short sales, leveraging the
investment, potential adverse market forces, regulatory changes, and potential illiquidity. Investing in alternative
strategies presents the opportunity for significant losses. Returns on mutual fund investments are reduced by
management costs and expenses.
An ETF’s risks include declining value of the securities held by the ETF, adverse developments in the specific industry or
sector that the ETF tracks, capital loss in geographically focused funds because of unfavorable fluctuation in currency
exchange rates, differences in generally accepted accounting principles, or economic or political instability, tracking
error, which is the difference between the return of the ETF and the return of its benchmark and trading at a premium
or discount, meaning the difference between the ETF’s market price and NAV. ETFs also are subject to the individual
risks described in their prospectus. Although many mutual funds and ETFs may provide diversification, risks can be
significantly increased if a mutual fund or ETF is concentrated in a particular sector of the market, primarily invests in
small cap or speculative companies, uses leverage to a significant degree, or concentrates in a particular type of security.
One of the main advantages of mutual funds and ETFs is that they give individual investors access to professionally
managed, diversified portfolios of equities, bonds and other securities.
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Although the goal of diversification is to combine investments with different characteristics so that the risks inherent in
any one investment can be balanced by assets that move in different cycles or respond to different market factors,
diversification does not eliminate the risk of loss. In some circumstances, price movements may be highly correlated
across securities and funds. A specific fund may not be diversified and a client portfolio may not be diversified.
Additionally, when diversification is a client objective, there is risk that the strategies that the Firm uses may not be
successful in achieving the desired level of diversification. There is also risk that the strategies, resources, and analytical
methods that the Firm uses to identify mutual funds and ETFs will not be successful in identifying investment
opportunities.
Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss.
The following events also could cause mutual funds, ETFs, equities and fixed income securities 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 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 particular
underlying circumstances. For example, changes in political, economic and 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 investments 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. Fluctuations in interest rates on borrowings or the dividend rates on preferred shares that take place
from changes in short- term interest rates may reduce the return to common shareholders or result in fluctuations in
the dividends paid on common shares. 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: Countries around the globe may be more, or less, prone to inflation than the U.S. economy at any
given time. Companies operating in countries with higher inflation rates may find it more difficult to post profits
reflecting its underlying health.
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.
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Cryptocurrency and Related Assets Risk: Cryptocurrency, often referred to as “virtual currency”, “digital
currency”, or “digital assets,” operates as a decentralized, peer-to-peer financial exchange and value storage that is used
like money. Cryptocurrency operates without central authority or banks, is not backed by any government, and is not
legal tender. Federal, state, or foreign governments may restrict the use and exchange of cryptocurrency, and regulation
in the U.S. is still developing. Cryptocurrency exchanges may stop operating or permanently shut down due to fraud,
technical glitches, hackers, or malware. Cryptocurrencies may experience very high volatility. Digital assets are highly
dependent on their developers and there is no guarantee that development will continue or the developers will not
abandon a project with little or no notice. Third parties may assert intellectual property claims relating to the holding
and transfer of digital assets and their source code. Any threatened action that reduces confidence in a network’s long-
term ability to hold and transfer cryptocurrency may affect investment value.
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 other ETF 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 ETF.
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 hedge funds and other private investment funds may underperform publicly
offered and traded securities because such investments:
Typically require investors to lock-up their assets for a period and may be unable to meet redemption
o
requests during adverse economic conditions;
o Have limited or no liquidity because of restrictions on the transfer of, and the absence of a market for,
interests in these funds;
o Are more difficult to monitor and value due to a lack of transparency and publicly available information
about these funds;
o May have higher expense ratios and involve more inherent conflicts of interest than publicly traded
investments; and
Involve different risks than investing in registered funds and other publicly offered and traded securities.
o
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.
Cybersecurity: The computer systems, networks and devices used by Sound View Wealth 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, 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
13
or website access or functionality. Cybersecurity breaches 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 other compliance costs; as well as the inadvertent release of
confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues 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; and other parties. In addition, substantial costs may
be incurred by those entities in order to prevent any cybersecurity breaches in the future.
COVID Risk Disclosure: The transmission of COVID and efforts to contain its spread have resulted in border
closings and other travel restrictions and disruptions, market volatility, disruptions to business operations, supply chains
and customer activity and quarantines. With widespread availability of vaccines, the U.S. Centers for Disease Control and
Prevention has revised its guidance, travel restrictions have started to lift, and businesses have reopened. However, the
COVID pandemic continues to evolve and the extent to which our investment strategies will be impacted will depend on
various factors beyond our control, including the extent and duration of the impact on economies around the world and
on the global securities and commodities markets. Volatility in the U.S. and global financial markets caused by the COVID
pandemic may continue and could impact our firm’s investment strategies. Although currently there has been no
significant impact, the COVID outbreak, and future pandemics, could negatively affect vendors on which our firm and
clients rely and could disrupt the ability of such vendors to perform essential tasks.
Use of Independent Managers
Sound View Wealth may select certain External Managers to manage a portion of its clients’ assets. In these situations,
Sound View Wealth conducts due diligence of such managers, but the success of such recommendations relies to a great
extent on the External Managers’ ability to successfully implement their investment strategies. In addition, Sound View
Wealth generally may not have the ability to supervise the External Managers on a day-to-day basis.
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 Sound View Wealth and the integrity of Sound View Wealth’s management.
Sound View Wealth has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Recommendation of External Managers
Sound View Wealth may recommend that clients use External Managers based on the client’s needs and suitability.
Sound View Wealth does not receive separate compensation, directly or indirectly, from such External Managers for
recommending that clients use their services. Sound View Wealth does not have any other business relationships with
the recommended External Managers.
Registered Representatives
As described above in Item 5, an advisory person of Sound View Wealth is a registered representative of PKS and
through this relationship receives transaction-based compensation for annuities where PKS is the broker of record. This
is a potential conflict of interest in that it could incentivize the recommendation of annuities based on the compensation
14
the advisory person receives, rather than on a client’s needs. Sound View Wealth addresses this conflict through this
disclosure. Additionally, neither the advisory person nor Sound View Wealth receive advisory fees on these annuities
(e.g., they do not “double dip”). Furthermore, as a result of this relationship PKS may have access to certain confidential
information (e.g., financial information, investment objectives, transactions and holdings) about clients, even if client
does not establish an account through PKS. If you would like a copy of the PKS privacy policy, please contact our Chief
Compliance Officer as described on the cover page of this brochure.
Licensed Insurance Agents
Certain of the Firm’s advisory persons are licensed insurance agents for an affiliated entity, Sound View Wealth Advisors
Insurance, LLC, and may offer certain insurance products on a fully-disclosed commissionable basis. Additionally, as
noted above under Item 5, Sound View Wealth Advisors Insurance, LLC permits advisory persons of Sound View Wealth
to continue to earn commissions for insurance policies which the advisory persons sold previously for a different entity.
Please refer to the advisory person’s individual 2B Supplement for more information. A conflict of interest exists to the
extent that Sound View Wealth recommends the purchase of insurance products where its advisory persons may be
entitled to insurance commissions or other additional compensation. The Firm seeks to make recommendations that are
in clients’ best interests. Clients are under no obligation to purchase insurance products through any person affiliated
with Sound View Wealth.
Focus Financial Partners
As noted above in response to Item 4, certain investment vehicles affiliated with CD&R collectively are indirect majority
owners of Focus LLC, and certain investment vehicles affiliated with Stone Point are indirect owners of Focus LLC.
Because Sound View Wealth is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment
vehicles are indirect owners of Sound View Wealth.
SCS Private Funds
As stated earlier in Items 4 and 5 of this Brochure, under certain circumstances we offer our clients the opportunity to
invest in pooled investment vehicles managed by SCS. SCS provides these services to such clients pursuant to limited
partnership agreement documents and in exchange for a fund-level management fee and performance fee paid by our
clients and not by us. SCS, like us, is an indirect wholly owned subsidiary of Focus LLC and is therefore under common
control with us. The allocation of our clients’ assets to SCS’s pooled investment vehicles, rather than to an unaffiliated
investment manager, increases SCS’s compensation and the revenue to Focus LLC relative to a situation in which our
clients are excluded from SCS’s pooled investment vehicles. As a consequence, Focus LLC has a financial incentive to
cause us to recommend that our clients invest in SCS’s pooled investment vehicles, which creates a conflict of interest
with our clients who invest in SCS’s pooled investment vehicles. More information about Focus LLC can be found at
www.focusfinancialpartners.com.
We believe this conflict is mitigated because of the following factors: (1) this arrangement is based on our judgment that
investing a portion of our clients’ assets in SCS’s investment vehicles is in the best interests of the affected clients;
(2) SCS and its investment vehicles have met the due diligence and performance standards that we apply to outside,
unaffiliated investment managers; (3) clients will invest in the pooled investment vehicles on a nondiscretionary basis
through the completion of subscription documentation; (4) subject to redemption restrictions, we are willing and able to
reallocate our client assets to other unaffiliated investment vehicles, in part or in whole, if SCS’s services become
unsatisfactory in our judgment and at our sole discretion; and (5) we have fully and fairly disclosed the material facts
regarding this relationship to you, including in this Brochure, and our clients who invest in SCS’s pooled investment
vehicles have given their informed consent to those investments.
15
UPTIQ Credit and Cash Management Solutions
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions
through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). These third-party
financial institutions are banks and non-banks that offer credit and cash management solutions to our clients, as well as
certain other unaffiliated third parties that provide administrative and settlement services to facilitate UPTIQ’s cash
management solutions. UPTIQ acts as an intermediary to facilitate our clients’ access to these credit and cash
management solutions.
We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is a minority investor in UPTIQ, Inc.
UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients.
The revenue paid to UPTIQ also benefits UPTIQ Inc.’s investors, including Focus. When legally permissible, UPTIQ also
shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For non-residential
mortgage loans made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives from the third-party
financial institutions. For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up
to 75% of all revenue it receives from such third-party financial institutions. For cash management products and
services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party
financial institutions and other intermediaries that provide administrative and settlement services in connection with
this program. This earned revenue is indirectly paid by our clients through an increased interest rate charged by the
third-party financial institutions for credit solutions or reduced yield paid by the providers of cash management
solutions. FSH distributes this revenue to us when we are licensed to receive such revenue (or when no such license is
required) and the distribution is not otherwise legally prohibited. This revenue is also revenue for FSH’s and our
common parent company, Focus. Additionally, the volume generated by our clients’ transactions allows Focus to
negotiate better terms with UPTIQ, which benefits Focus and us. Accordingly, we have a conflict of interest when
recommending UPTIQ’s services to clients because of the compensation [to us and] to our affiliates, FSH and Focus, and
the transaction volume to UPTIQ. We mitigate this conflict by: (1) fully and fairly disclosing the material facts
concerning the above arrangements to our clients, including in this Brochure; and (2) offering UPTIQ’s solutions to
clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services.
Additionally, we note that clients who use UPTIQ’s services will receive product-specific disclosure from the third-party
financial institutions and other unaffiliated third-party intermediaries that provide services to our clients.
We have an additional conflict of interest when we recommend credit solutions to our clients because our interest in
continuing to receive investment advisory fees from client accounts gives us a financial incentive to recommend that
clients borrow money rather than liquidate some or all of the assets we manage.
Credit Solutions
Clients retain the right to pledge assets in accounts generally, subject to any restrictions imposed by clients’ custodians.
While credit solution programs that we offer facilitate secured loans through third-party financial institutions, clients are
free instead to work directly with institutions outside such programs. Because of the limited number of participating
third-party financial institutions, clients may be limited in their ability to obtain as favorable loan terms as if the client
were to work directly with other banks to negotiate loan terms or obtain other financial arrangements.
Clients should also understand that pledging assets in an account to secure a loan involves additional risk and
restrictions. A third-party financial institution has the authority to liquidate all or part of the pledged securities at any
time, without prior notice to clients and without their consent, to maintain required collateral levels. The third-party
financial institution also has the right to call client loans and require repayment within a short period of time; if the
client cannot repay the loan within the specified time period, the third-party financial institution will have the right to
16
force the sale of pledged assets to repay those loans. Selling assets to maintain collateral levels or calling loans may
result in asset sales and realized losses in a declining market, leading to the permanent loss of capital. These sales also
may have adverse tax consequences. Interest payments and any other loan-related fees are borne by clients and are in
addition to the advisory fees that clients pay us for managing assets, including assets that are pledged as collateral. The
returns on pledged assets may be less than the account fees and interest paid by the account. Clients should consider
carefully and skeptically any recommendation to pursue a more aggressive investment strategy in order to support the
cost of borrowing, particularly the risks and costs of any such strategy. More generally, before borrowing funds, a client
should carefully review the loan agreement, loan application, and other forms and determine that the loan is consistent
with the client’s long-term financial goals and presents risks consistent with the client’s financial circumstances and risk
tolerance.
We use UPTIQ to facilitate credit solutions for our clients.
Cash Management Solutions
For cash management programs, certain third-party intermediaries provide administrative and settlement services to
our clients. Engaging the third-party financial institutions and other intermediaries to provide cash management
solutions does not alter the manner in which we treat cash for billing purposes. Clients should understand that in rare
circumstances, depending on interest rates and other economic and market factors, the yields on cash management
solutions could be lower than the aggregate fees and expenses charged by the third-party financial institutions, the
intermediaries referenced above, and us. Consequently, in these rare circumstances, a client could experience a
negative overall investment return with respect to those cash investments. Nonetheless, it might still be reasonable for
a client to participate in a cash management program if the client prefers to hold cash at the third-party financial
institutions rather than at other financial institutions (e.g., to take advantage of FDIC insurance).
We use UPTIQ to facilitate cash management solutions for our clients.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions A. Description of Code of Ethics
Sound View Wealth has a Code of Ethics (the “Code”) which requires Sound View Wealth’s employees (“supervised
persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other
things, the Code of Ethics sets forth policies and procedures related to conflicts of interest, outside business activities,
gifts and entertainment, compliance with insider trading laws and policies and procedures governing personal securities
trading by supervised persons.
Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in
client securities transactions or the investment opportunity available to clients. The Code addresses these potential
conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain
exceptions, supervised persons to report their personal securities holdings and transactions to Sound View Wealth for
review by the Firm’s Chief Compliance Officer. The Code also requires supervised persons to obtain pre-approval of
certain investments, including initial public offerings and limited offerings.
Sound View Wealth recommends that certain of our clients invest in a private investment fund managed by an affiliated
Focus partner firm. Please refer to Items 4, 5 and 10 for additional information.
Sound View Wealth will provide a copy of the Code of Ethics to any client or prospective client upon request.
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Item 12 – Brokerage Practices
A. Factors Used to Select Custodians and/or Broker-Dealers
Sound View Wealth generally recommends that its investment management clients utilize the custody and brokerage
services of an unaffiliated broker/dealer custodian (a “BD/Custodian”) with which Sound View Wealth has an
institutional relationship. Currently, this includes Schwab Advisor Services, a division of Charles Schwab & Co., Inc.
(“Schwab”), and Fidelity Investments (“Fidelity”), each of which is a “Qualified Custodian” as that term is described in
Rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Advisers Act”). Each BD/Custodian provides custody of
securities, trade execution, and clearance and settlement of transactions placed by Sound View Wealth.
In deciding to recommend a custodian, some of the factors that Sound View Wealth considers include:
Combination of transaction execution services along with asset custody services (generally without a separate fee
for custody);
Capability to execute, clear, and settle trades (buy and sell securities for your account)
Capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment,
etc.)
Breadth of investment products made available (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.)
Availability of investment research and tools that assist us in making investment decisions
Quality of services
Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and
willingness to negotiate them
Reputation, financial strength, and stability of the provider
Their prior service to us and our other clients
Availability of other products and services that benefit us, as discussed below (see “Products and Services Available
to Us from Custodians”)
Products and Services Available to Us from Custodians
Schwab 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 include investment research, both Schwab’s own and that of
third parties. Sound View Wealth may use this research to service all or some substantial number of client accounts,
including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that assists us in managing and administering your account. Schwab also offers other services
intended to help us manage and further develop our business enterprise. Schwab may provide some of these services
itself. In other cases, it will arrange for third-party vendors to provide the services to the Firm. Schwab may also discount
or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide the Firm
with other benefits such as occasional business entertainment of Firm personnel. These products and services from
Schwab benefit Sound View Wealth and may incentivize Sound View Wealth to recommend Schwab as custodian over
custodians who do not offer such products and services.
Fidelity provides Sound View Wealth with Fidelity’s “platform services”. The platform services include, among others,
brokerage, custodial, administrative support, record keeping and related services that are intended to support us in
conducting business and in serving the best interests of our clients. In addition, as part of our arrangement with Fidelity,
we also receive discounts on certain third-party software applications that are used by us to manage accounts for which
we have investment discretion. As a result, Sound View Wealth may have an incentive to continue to use or expand the
use of Fidelity’s services.
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Sound View Wealth will periodically review its arrangements with the 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. 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;
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; and
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.
Sound View Wealth has not entered into any formal “soft dollar” arrangements with broker-dealers.
Sound View Wealth’s clients may utilize qualified custodians other than Schwab for certain accounts and assets,
particularly where clients have a previous relationship with such qualified custodians.
Brokerage for Client Referrals
Sound View Wealth does not select or recommend broker-dealers based solely on whether or not it may receive client
referrals from a broker-dealer or third party.
Client-Directed Brokerage
Generally, in the absence of specific instructions to the contrary, for brokerage accounts that clients engage Sound View
Wealth to manage on a discretionary basis, Sound View Wealth has full discretion with respect to securities transactions
placed in the accounts. This discretion includes the authority, without prior notice to the client, to buy and sell securities
for the client’s account and establish and affect securities transactions through the BD/Custodian of the client’s account
or other broker-dealers selected by Sound View Wealth. In selecting a broker-dealer to execute a client’s securities
transactions, Sound View Wealth seeks prompt execution of orders at favorable prices.
A client, however, may instruct Sound View Wealth to custody his/her account at a specific broker-dealer and/or direct
some or all of his/her brokerage transactions to a specific broker-dealer. In directing brokerage transactions, a client
should consider whether the commission expenses, execution, clearance, settlement capabilities, and custodian fees, if
19
any, are comparable to those that would result if Sound View Wealth exercised its discretion in selecting the broker-
dealer to execute the transactions. Directing brokerage to a particular broker-dealer may involve the following
disadvantages to a directed brokerage client:
Sound View Wealth’s ability to negotiate commission rates and other terms on behalf of such clients
could be impaired;
such clients could be denied the benefit of Sound View Wealth’s experience in selecting broker-dealers
that are able to efficiently execute difficult trades;
opportunities to obtain lower transaction costs and better prices by aggregating (batching) the client’s
orders with orders for other clients could be limited; and
the client could receive less favorable prices on securities transactions because Sound View Wealth may
place transaction orders for directed brokerage clients after placing batched transaction orders for other clients.
In addition to accounts managed by Sound View Wealth on a discretionary basis where the client has directed the
brokerage of his/her account(s), certain institutional accounts may be managed by Sound View Wealth on a non-
discretionary basis and are held at custodians selected by the institutional client. The decision to use a particular
custodian and/or broker-dealer generally resides with the institutional client. Sound View Wealth endeavors to
understand the trading and execution capabilities of any such custodian and/or broker-dealer, as well as its costs and
fees. Sound View Wealth may assist the institutional client in facilitating trading and other instructions to the custodian
and/or broker-dealer in carrying out Sound View Wealth’s investment recommendations.
Trade Errors
Sound View Wealth’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade
error occurs, Sound View Wealth endeavors to identify the error in a timely manner, correct the error so that the client’s
account is in the position it would have been had the error not occurred, and, after evaluating the error, assess what
action(s) might be necessary to prevent a recurrence of similar errors in the future.
Trade errors generally are corrected through the use of a “trade error” account or similar account at Schwab, Fidelity, or
another BD, as the case may be. Sound View Wealth’s error correction practices are generally governed by the practices
of the relevant custodian broker-dealer. In the event an error is made in a client account custodied elsewhere, Sound
View Wealth works directly with the broker in question to take corrective action. In all cases, Sound View Wealth will
take the appropriate measures to return the client’s account to its intended position.
Corrections generally have a gain or loss resulting from market movement between the time of the error and time of
correction. Regarding errors corrected through a trade error account at Fidelity, at the end of each quarter, gains and
losses are netted. A net gain will be sent to a charity of Fidelity’s choice. A net loss is the responsibility of Sound View
Wealth. Conflicts of interest in maintaining a trade correction account are mitigated by Sound View Wealth’s policies
and procedures designed to prevent and promptly correct trade errors and the requirement that Fidelity approve the
trade error correction.
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
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in accordance with applicable rules promulgated under the Advisers Act and 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
Sound View Wealth monitors investment advisory portfolios as part of a continuous and ongoing process. Sound View
Wealth advisors have at least one annual meeting with each client to conduct a formal review the clients’ accounts.
These reviews may include the following:
compare the account’s allocation with stated goals and client cash-flows at time of review;
review holdings and consider alternatives;
monitor the size of individual securities relevant to their sectors, asset classes, and overall account size;
analyze an account’s composition and performance, income, appreciation, gains/losses, and asset
allocation; and
assess its 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 Sound View Wealth if changes occur in the client’s
personal financial situation that might adversely affect the client’s investment plan.
B. Other Reviews
Sound View Wealth 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 the qualified custodian. 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]. Sound View Wealth 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
Sound View Wealth does not receive benefits from third parties for providing investment advice to clients.
B.
Compensation to non-Supervised Persons for Client Referrals
Sound View Wealth does not currently have referral arrangements with solicitors but may in the future enter into
referral arrangements with unaffiliated individuals who may from time-to-time refer potential investors to Sound View
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Wealth for investment management services and be compensated for successful referrals by receiving a percentage of
the advisory fee Sound View Wealth receives from such clients. Any such arrangements must be in compliance with Rule
206(4)-1 of the Advisers Act.
C.
Other Compensation
Sound View Wealth’s parent company is Focus Financial Partners, LLC (“Focus”). From time to time, Focus holds
partnership meetings and other industry and best-practices conferences, which typically include Sound View Wealth,
other Focus firms and external attendees. These meetings are first and foremost intended to provide training or
education to personnel of Focus firms, including Sound View Wealth. However, the meetings do provide sponsorship
opportunities for asset managers, asset custodians, vendors and other third-party service providers. Sponsorship fees
allow these companies to advertise their products and services to Focus firms, including Sound View Wealth. Although
the participation of Focus firm personnel in these meetings is not preconditioned on the achievement of a sales target
for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education
activities conducted, and the access granted, at such meetings and conferences could cause Sound View Wealth to focus
on those conference sponsors in the course of its duties. Focus attempts to mitigate any such conflict by allocating the
sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for itself or any
affiliate, including Sound View Wealth. Conference sponsorship fees are not dependent on assets placed with any
specific provider or revenue generated by such asset placement.
The following entities have provided conference sponsorship to Focus from January 1, 2024 to February 1, 2025:
• Advent Software, Inc. (includes SS&C)
• BlackRock, Inc.
• Blackstone Administrative Services Partnership L.P.
• Capital Integration Systems LLC (CAIS)
• Charles Schwab & Co., Inc.
• Confluence Technologies Inc.
•
•
Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates)
Fidelity Brokerage Services LLC and Fidelity Distributors Company LLC (includes Fidelity Institutional
Asset Management and FIAM)
Flourish Financial LLC
Franklin Distributors, LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM) and CANVAS)
Salus GRC, LLC
Stone Ridge Asset Management LLC
The Vanguard Group, Inc.
TriState Capital Bank
•
•
• K&L Gates LLP
• Nuveen Securities, LLC
• Orion Advisor Technology, LLC
• Pinegrove Capital Partners LLC (includes Brookfield Oaktree Wealth Solutions)
• Practifi, Inc.
•
•
•
•
• UPTIQ, Inc.
You can access updates to the list of conference sponsors on Focus’ website through the following link:
https://focusfinancialpartners.com/conference-sponsors/
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Item 15 – Custody
All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the custodian to
retain their funds and securities and direct Sound View Wealth to utilize the custodian for the client’s securities
transactions. Sound View Wealth’s agreement with clients and/or the clients’ separate agreement with the B/D
Custodian may authorize Sound View Wealth through such BD/Custodian to debit the client’s account for the amount of
Sound View Wealth’s fee and to directly remit that fee to Sound View Wealth in accordance with applicable custody
rules.
The BD/Custodian recommended by Sound View Wealth 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 Sound
View Wealth. Sound View Wealth encourages clients to review the official statements provided by the custodian, and to
compare such statements with investment reports received from Sound View Wealth. For more information about
Custodians and brokerage practices, see “Item 12 - Brokerage Practices.”
For various clients Sound View is provided authority pursuant to a standing letter of authorization permitting transfers
from the custodian to unaffiliated third parties as designated by the client (“SLOAs”). The SEC has determined that
advisers who can effect transfers pursuant to SLOAs have custody over these client accounts, but granted relief from the
surprise examination requirement in a no-action letter to the Investment Adviser Association dated February 21, 2017,
provided that certain conditions are met.
Item 16 – Investment Discretion
Clients have the option of providing Sound View Wealth with investment discretion on their behalf, pursuant to a grant
of a limited power of attorney contained in Sound View Wealth’s client agreement. By granting Sound View Wealth
investment discretion, a client authorizes Sound View Wealth 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 Sound View Wealth. See also Item 4(C), Client-Tailored Advisory
Services.
Item 17 – Voting Client Securities
A.
Voting Client Securities
Sound View Wealth votes proxies on behalf of our clients who have provided us with written authorization to do so.
Clients may, however, choose to retain proxy voting responsibility and will receive proxies from their custodian.
Sound View Wealth has adopted proxy voting policies, procedures and guidelines designed to vote proxies efficiently
and in the best interest of its clients. Sound View Wealth seeks to identify any material conflicts of interest and to
ensure that any such conflicts do not interfere with voting in clients’ best interests. Sound View Wealth utilizes
Broadridge’s integrated voting platform with Egan Jones (“Proxy Voting System”) to provide access to proxy vote
recommendations and assist with the voting and record-keeping of clients’ proxy ballots through the Proxy Voting
System. Clients may obtain a copy of Sound View Wealth’s proxy voting policies and information about how Sound View
Wealth voted a client’s proxies by contacting Sound View Wealth.
B.
Securities Class Actions and Proofs of Claim
Sound View Wealth is not obligated to file, nor will it act in any legal capacity with respect to class action settlements or
related proofs of claim. However, for clients that would like assistance to help monitor and file class action litigation
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claims, Egan Jones will also assist in the processing and filing of class actions litigations. In the event that underlying
clients are eligible to participate in such claims, Egan Jones will handle all phases of class actions filing, including
distribution of proceeds from class actions litigations. For their services, Egan Jones charges a contingency fee of 20%,
which is subtracted from the client’s award when it is paid.
Item 18 – Financial Information
A.
Balance Sheet
Sound View Wealth does not require prepayment of more than $1,200 in fees per client, six months or more in advance,
and therefore does not need to include a balance sheet with this Brochure.
B.
Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients
Neither Sound View Wealth 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
Sound View Wealth has not been the subject of a bankruptcy petition.
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