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Cove Wealth Management
a Registered Investment Adviser
710 N. Post Oak Rd., Suite 420 Houston, TX
77024
713-821-2343
www.covewm.com
March 6, 2025
This brochure provides information about the qualifications and business practices of Cove Wealth
Management, a dba of Valued Retirements, Inc.
If you have any questions about the contents of this brochure, please contact us at 713-821- 3243 and/or
cco@covewm.com. The information in this brochure has not been approved or verified by the Securities and
Exchange Commission or by any state securities authority.
Additional information about Cove Wealth Management also is available on the SEC’s website at
www.adviserinfo.sec.gov.
Disclosure Brochure
Item 2. Material Changes
Since our update filed in August 2024, there have been the following material changes.
• Cory A. Mizell was elected as Chairman of the Board and Vice President of the Corporation
in September 2024
• Sarah A. Mizell was elected as President of the Corporation in September 2024
• Kathy Kuria was engaged as the Chief Compliance Officer in February of 2025
We will provide you with a new Brochure as necessary based on material changes, new or updated
information, or upon request at any time, at no cost to you.
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Disclosure Brochure
Item 3. Table of Contents
Contents
Item 2. Material Changes .................................................................................................................................................................................................................. 2
Item 3. Table of Contents .................................................................................................................................................................................................................. 3
Item 4. Advisory Business ................................................................................................................................................................................................................... 4
Item 5. Fees and Compensation ...................................................................................................................................................................................................... 6
Item 6. Performance-Based Fees and Side-by-Side Management ...................................................................................................................... 8
Item 7. Types of Clients ........................................................................................................................................................................................................................ 8
Item 9. Disciplinary Information ................................................................................................................................................................................................ 10
Item 10. Other Financial Industry Activities and Affiliations ................................................................................................................................ 10
Item 11. Code of Ethics ........................................................................................................................................................................................................................ 10
Item 12. Brokerage Practices ........................................................................................................................................................................................................ 11
Item 13. Review of Accounts ......................................................................................................................................................................................................... 14
Item 14. Client Referrals and Other Compensation .................................................................................................................................................. 14
Item 15. Custody .................................................................................................................................................................................................................................... 14
Item 16. Investment Discretion .................................................................................................................................................................................................. 15
Item 17. Voting Client Securities ................................................................................................................................................................................................ 15
Item 18. Financial Information ...................................................................................................................................................................................................... 16
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Disclosure Brochure
Item 4. Advisory Business
Cove Wealth Management offers a variety of advisory services, which include investment management
supported by financial planning, and wealth coordination services with a proprietary process designed to
mitigate information overload and create clarity. Prior to CWM providing any advisory service, clients must
complete written contracts with CWM setting forth an advisory relationship (“Advisory Agreement”).
CWM is owned by Cory & Sarah Mizell and Malcolm Morris. As of December 31, 2024, CWM had
$166,632,928 in total assets under management all on a discretionary basis.
While this brochure generally describes the business of Cove Wealth Management, certain sections also
discuss the activities of its Supervised Persons, which refer to CWM’s officers, partners, directors (or other
persons occupying a similar status or performing similar functions), employees or other persons who
provide investment advice on the Advisor’s behalf and are subject to CWM’s supervision or control.
investment management supported by financial planning, and advice
CWM provides fee-only
characterized by excellence for the purpose of creating a meaningful impact for our clients and the
communities in which we operate. We measure impact by meeting the goal that every family we serve
will be able to articulate their driving values, priority relationships, and one part of life for which they are
grateful. As fiduciaries, we are obligated to act in the best interests of our clients.
Financial Planning and Investment Management Services
CWM offers clients fee-only investment management services which include any or all of the following:
Overview of Client’s Financial Situation
Tax Strategy and Planning
•
•
Long-Term Financial Projections and Scenarios
Continuity Planning
•
•
Retirement Planning
Family Education
•
•
Trust and Estate Planning
Risk Management
•
•
Charitable Giving Strategy and Execution
Insurance Review and Planning
•
•
We tailor each financial plan, our
investment management recommendations and our Wealth
Coordination services to you. You can customize which services we provide. Clients are advised that a
conflict of interest exists for CWM to recommend that clients engage CWM or its affiliates to provide (or
continue to provide) additional services for compensation, including investment management services.
Clients are under no obligation to act upon any of the recommendations made by CWM under a financial
planning or consulting engagement. Clients are advised that it remains their responsibility to promptly
notify CWM of any change in their financial situation or investment objectives for the purpose of reviewing,
evaluating, or revising Advisors’ recommendations and/or services.
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Disclosure Brochure
We tailor our advisory services to the unique needs of our clients by initially gathering client details and
priorities. We gather data, including risk tolerance, and create a customized Investment Policy Statement
(IPS). The IPS sets investment parameters that guide us as we make decisions about each client’s portfolio.
As Investment Managers, CWM primarily allocates client assets among various mutual funds, exchange-
traded funds (“ETFs”), individual debt and equity securities (stocks and bonds), and additional outside
independent investment managers as needed in accordance with stated investment objectives. CWM
consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, cash
constraints and other related factors relevant to the management of their portfolios.
Clients can engage CWM to advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored
retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, CWM directs or recommends
the allocation of client assets among the various investment options available with the product. These
assets are generally maintained at the underwriting insurance company or the custodian designated by
the product’s provider.
Wealth Coordination Services
In addition to financial planning and investment management, we provide individualized consultations on
selective financial matters. CWM provides clients with Wealth Coordination Services (WCS) which include
complex synchronization services to engage ultra-high net worth families through intentional and
structured collaboration with other professional service providers (accountants/ CPAs, bookkeepers,
attorneys, other investment professionals, etc.). We collaborate with outside professionals in a range of
industries to support families with a net worth between $20 million and $500 million. Professional
collaborations are a key component of Wealth Coordination Services. Our role is not to supplant these
services, but to coordinate and support them. CWM’s Wealth Coordination services help you execute a plan
that brings everything together under one cohesive umbrella.
By focusing on the big picture, we assist you in making the fundamental decisions that seek to put you on
a path to achieving your goals. This unique approach surrounds you with a dedicated team of skilled
professionals that can integrate all of your financial professionals and decisions.
Use of Independent Managers
CWM selects certain Independent Managers to actively manage a portion of its clients’ assets when that
manager is deemed appropriate for a portion of a client’s portfolio. There is a separate written agreement
with the designated Independent Manager. That agreement can be between CWM and the Independent
Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a
separate account manager). In addition to this brochure, clients will typically also receive the written
disclosure documents of any Independent Managers engaged to manage their assets.
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Disclosure Brochure
CWM continues to provide services relative to the discretionary or non- discretionary selection of the
Independent Managers. On an ongoing basis, CWM monitors the performance of those accounts being
managed by Independent Managers.
Item 5. Fees and Compensation
CWM is a fee-only firm and receives no compensation for the sale of any product.
Financial Planning & Consulting Fees
CWM charges a fixed fee for providing financial planning and consulting services under a stand-alone,
separate contract. The fees, terms and conditions of financial planning services are set forth in the Advisory
Agreement and range from $4,000 to $10,000. Financial Planning fees are separate from other CWM
services and are negotiable depending upon the scope and complexity of the services and the professional
rendering the financial planning and/or the consulting services. The fee can be for a defined project, such as
a comprehensive financial plan, or for ongoing services. CWM reserves the right to waive the Financial
Planning and Consulting fees at its sole discretion. You may pay an initial Financial Planning fee in addition
to the ongoing investment management fee if you also engage us for Investment Management Services or
you may pay for a stand-alone financial plan.
For project-based services, CWM requires one-half of the fee (estimated hourly or fixed) payable upon
execution of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan
or completion of the agreed-upon services.
Investment Management Fees
The terms and conditions of Investment Management services are set forth in the Advisory Agreement
with CWM and will be customized per the individual Agreement with the client and calculated based on a
percentage of the value of assets under management. Investment Management services are charged
separate from other CWM services or per the signed Advisory Agreement. The minimum annual
Investment Management fee is $4,000.
Investment Assets Under Management
The first $5 million
The next $5 million
The next $10 million
More than $20 million
Annual Rate
1.0%
0.80%
0.60%
Negotiated
This is a blended fee schedule, meaning different asset levels are assessed different fees, as shown above.
Your assets will be assessed a fee at each level, then those fees are combined for your overall fee. The
annual fee is prorated and charged quarterly, in arrears, based upon the market value of the assets as of
the last business day of the preceding calendar quarter. Fees are deducted from the accounts unless the
clients have requested separate billing. For the initial period of an engagement, the fee is prorated.
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Disclosure Brochure
In the event the advisory agreement is terminated, the fee for the final billing period is prorated through
the effective date of the termination and the outstanding or unearned portion of the fee is charged or
refunded to the client, as appropriate.
The annual fee can be negotiable based upon certain criteria (e.g., historical relationship, type of assets,
anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be
managed, related accounts, account composition, negotiations with Clients, etc.). The amount and method
by which fees are charged is established in each client’s written Agreement with CWM.
Not all of our clients are on the same fee schedule, as our fees, and the assets we bill on, have changed the
life of the firm. Additionally, our fees are negotiable, and we reserve the right to negotiate or waive any
fees based on numerous factors. Therefore, some clients pay more or less than others for similar services.
Additionally,, asset management services CWM provides with respect to certain client holdings (e.g., held-
away assets, accommodation accounts, alternative investments, etc.), CWM can negotiate a fee rate that
differs from the range set forth above. Clients are advised that a conflict of interest exists for CWM to
recommend that clients engage CWM for additional services for compensation, including rolling over
retirement accounts or moving other assets to CWM’s management.
Clients retain absolute discretion over all decisions regarding engaging CWM and are under no obligation
to act upon any of the recommendations.
A portion of the revenue earned by CWM is intentionally used by the partners and team to create a positive
impact in our communities. We support many organizations with a particular focus on orphans and the
disadvantaged. We invite clients to join in generosity by recommending favorite charitable organizations.
Wealth Coordination Fees
Wealth Coordination fees are structured as a monthly flat fee charged in addition to investment
management or financial planning fees. The fees for Wealth Coordination range from $1,000 to $20,000
monthly based on complexity/client needs, and they are typically billed quarterly or monthly, in arrears.
Clients engage and pay third-party professional collaborators directly for services rendered. We are only
paid by the client and do not ever pay or receive “referral payments” or other compensation from the
collaborative partners.
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Disclosure Brochure
Additional Fees and Expenses
In addition to the advisory fees paid to CWM, clients also incur certain charges imposed by other third
parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
(collectively “Financial Institutions”). These additional charges include commissions, transaction fees,
custodial fees, fees charged by the Independent Managers, margin and other borrowing costs, charges
imposed directly by a mutual fund or ETF such as an expense ratio or marketing fee, as disclosed in the
fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. CWM’s brokerage practices are described at length in Item 12, below.
Direct Fee Debit
Clients provide CWM and/or certain Independent Managers with the authority to directly debit their
accounts for payment of the investment advisory fees. The Financial Institutions that act as qualified
custodian(s) for client accounts, from which CWM retains the authority to directly deduct fees, are
obligated to send statements to clients not less than quarterly detailing all account transactions, including
any amounts paid to Cove Wealth Management.
Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time subject to cash availability.
Additions can be in cash or securities. CWM and/or the custodian reserves the right to liquidate any
transferred securities or decline to accept particular securities into a client’s account. Clients can withdraw
account assets on notice to Cove Wealth Management, subject to the usual and customary securities
settlement procedures. However, CWM designs its portfolios as long-term investments, and the
withdrawal of assets may impair the achievement of a client’s investment objectives.
Item 6. Performance-Based Fees and Side-by-Side Management
CWM does not provide any services for a performance-based fee (i.e., an additional fee based on an
increase in capital gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
CWM offers services to individuals, trusts, estates, charitable organizations, businesses, pension and
profit-sharing plans.
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Disclosure Brochure
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
Investing differs from saving in one main way. Money designated as “savings” generally is held so that the
balance is fully protected, with some small amount of interest earned each year. Investing carries with it the
potential for greater rewards, but also the potential for loss of principal (principal refers to the amount
invested). To repeat: investing involves the risk of loss of principal. Clients need to realize this, and to be aware
that this risk is theirs to bear. Investing is for the long term. Before anyone invests, there are other issues that
it is wise to address such as a savings cushion, current levels of debt and spending, and emotional tolerance
for investing and market movement.
As an investment advisory firm, we use methods of analysis such as charting the movements of the markets
or securities within those markets; fundamental strengths of companies; technical price movements based on
the market or responses to outside events; cyclical movements of stocks within their industries; and
momentum issues with respect to securities (short-term performance that is stronger relative to comparable
assets). Occasionally, our research into the US and world economies may lead us to hold a significant cash
allocation temporarily. Because the initial and internal costs of any security can significantly affect its
performance, we try to be aware of those expenses as a part of the process of maximizing returns. We do not
consider our investment strategies to be under the “frequent trading” classification, which to us means holding
securities for days or weeks only. However, we are not enamored of “buy and hold” either, except when it
comes to fixed income securities. Accordingly, in taxable accounts there may be taxable gains on a yearly
basis because securities were sold for a gain. Obviously, there can also be losses, which may also affect a
client’s tax situation.
Investment Philosophy:
CWM recognizes its fiduciary responsibility and willingly assumes the role of a steward on behalf of CWM’s
clients. CWM designs portfolios for client objectives using a diversified mix of publicly traded investments as
the portfolio core with focused investments or private placements as additional diversifiers.
Client Families:
Analysis of Client Family Desires - CWM asks clients about their hopes, dreams, and priorities. One process
used to explore this topic is Life Planning. Client responses to these topics help CWM better understand the
desires of their hearts and how CWM may or may not be able to help meet those desires.
Balance Sheet Analysis - CWM analyzes a client’s existing assets, liabilities and the details of their current
allocation of risk and resources in order to provide appropriate recommendations.
Cash Flow Analysis - CWM analyzes a client’s expected income and expenses in order to understand their
true investing time horizon and need for cash movement into or out of their investment portfolio.
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Disclosure Brochure
Risk Tolerance Analysis - CWM asks clients questions to understand their comfort level with risk and how
they might respond to different investment experiences. This helps CWM understand their likely behavior
and build an appropriate investment portfolio to match their comfort level.
Investments:
CWM uses fundamental, technical, and valuation analysis. CWM primarily uses publicly traded low-cost
exchange traded funds, mutual funds, and Independent Managers that use individual equities and bonds.
Given CWM’s view that markets are generally efficient, CWM expects to hold most of its investments long-
term. Most accounts will hold a combination of cash, equities and fixed income in varying percentages
according to the appropriate level of risk.
Risk of Loss
All investing involves risk, and we discuss specific risks such as credit, market, cash management, inflation,
volatility, headline, social media, interest-rate AND pandemic risk with our clients during an initial
appointment. We also discuss how non-correlated assets can reduce risk to a portfolio. We do not believe
our investment strategies involve an unusual amount of risk, especially given that many of our clients are
fairly conservative in their investment styles.
Item 9. Disciplinary Information
CWM has not been involved in any legal or disciplinary events.
Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations. CWM
does not have any other professional financial industry activities or affiliations that need to be disclosed.
Our advisors serve in local community organizations where they provide periodic pro bono financial
education.
Item 11. Code of Ethics
We have adopted a Code of Ethics which describes the general standards of conduct that we expect of all
Firm personnel (collectively referred to as “employees”). This code of ethics focuses on three specific areas
where employee conduct has the potential to adversely affect you:
• misuse of confidential information
• personal securities trading and
• outside business activities
Failure to uphold the Code of Ethics will result in disciplinary sanctions, including possible termination of
employment with us. All employees are required to review and acknowledge the Code of Ethics on an
annual basis. You may request a copy of the Firm’s Code of Ethics which will be provided to you at no cost.
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Disclosure Brochure
The following basic principles guide all aspects of our business and represent the minimum requirements
to which we expect employees to adhere. Your interests come before the employees’ personal interests
and before the firm’s. We must fully disclose all material facts about conflicts between our interests, our
employees’ interests, and your interests. Employees must operate on our behalf and on their own behalf
consistently with our disclosures and to manage the impacts of any conflicts of interest. We must not take
inappropriate advantage of our position of trust or responsibility to you. We must always comply with all
applicable securities laws.
Misuse of Non-Public Information:
The Code of Ethics contains a policy against the use of non-public information in the conduct of our business.
Employees may not convey non-public information nor use it in placing personal securities trades or any
trades for our clients.
Personal Securities Trading:
Our personnel may buy, sell, or hold in their personal accounts the same securities we buy, sell, or hold for
you. Employees must obtain pre-approval from the Chief Compliance Officer before purchasing any IPO or
investing in a private partnership fund for any personal account.
To mitigate conflicts of interest, we have established the following policies to ensure our fiduciary
responsibilities and to place your interests first:
• An officer, director or employee shall not buy or sell securities for a personal portfolio when the
decision to purchase is substantially derived, in whole or in part, by reason of employment with us
unless the information is also available to the investing public on reasonable inquiry.
•
• Compliance reviews all personal trades considering our code of ethics and client trades on at least
a quarterly basis. Reports of personal securities holdings are filed with the Compliance Team (which
is led by the CCO) by all personnel and are reviewed at least annually.
Infractions of our personal trading policies will be grounds for disciplinary action, including possible
termination.
Outside Business Activities:
Employees are required to report on any outside business activities. If any such activities are deemed to
conflict with clients, such conflicts will be fully disclosed, or the employee will be required to cease such
activity.
Item 12. Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
CWM recommends that clients utilize the custody, brokerage and clearing services of Charles Schwab &
Co, Inc. through its Schwab Advisor Services division (“Schwab”) for investment management accounts. Our
process for selecting brokerages relies more on their capabilities as CUSTODIANS than as BROKERS. Since
2018, there has been increased consolidation in available custodians which limits our choices as well. If a
client has a preference, this is always taken into consideration first.
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Disclosure Brochure
We also examine:
• whether the client is best served by having all accounts with one custodian (very often, this is a result
of a client’s desire to “simplify,” “track fewer accounts,” etc.);
• whether there is a custodian that is more suitable for the client based on unique circumstance; and
• what provides the lowest transaction costs across the client’s portfolio.
We generally choose discount brokerages due to the lower cost of transactions. In recent years, ease of
website use has also been a factor. For additional information, we would be happy to copy the applicable
pages from our compliance manual. Incidental benefits from any custodian, such as a discounted rate on
partner/vendor software, do not affect our choice of custodian. Nor are we particularly interested in what
the custodian provides to us as a firm, especially since most research is widely available. We will use the
resources available to make intelligent choices, but it has no bearing on our custodian of choice.
The final decision to custody assets with Custodians is at the discretion of the client, including those
accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan
sponsor or IRA accountholder. CWM is independently owned and operated and not affiliated with
Custodians. Custodians provide CWM with access to institutional trading and custody services, which are
typically not available to retail investors. CWM periodically and systematically reviews its policies and
procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best
execution.
Software and Support Provided by Financial Institutions
CWM may receive the following benefits from Custodians through its registered investment adviser
division: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading
desk that exclusively services its Registered Investment Adviser participants; access to block trading which
provides the ability to aggregate securities transactions and then allocate the appropriate shares to client
accounts; and access to an electronic communication network for client order entry and account
information. CWM also has the ability to deduct advisory fees directly from client accounts; access to an
electronic communications network for client order entry and account information; access to mutual funds
with no transaction fees and to certain institutional money managers; and discounts on compliance,
marketing, research, technology, and practice management products or services provided to CWM by third
party vendors. Custodians may fund business consulting and professional services received by Advisors’
related persons.
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Disclosure Brochure
Custodians’ services include brokerage services that are related to the execution of securities transactions,
custody, research, including that in the form of advice, analysis and reports, and access to mutual funds
and other investments that are otherwise generally available only to institutional investors or would
require a significantly higher minimum initial investment.
Trade Aggregation
Transactions for each client will be affected independently, unless CWM decides to purchase or sell the
same securities for several clients at approximately the same time. CWM may (but is not obligated to)
combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or
to allocate equitably among CWM’s clients differences in prices and commissions or other transaction
costs that might not have been obtained had such orders been placed independently. Under this
procedure, transactions will be averaged as to price and allocated among Cove Wealth Management’
clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that
CWM aggregates client orders for the purchase or sale of securities, including securities in which Cove
Wealth Management’ Supervised Persons may invest, CWM does so in accordance with applicable rules
promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities
and Exchange Commission. CWM does not receive any additional compensation or remuneration as a
result of the aggregation.
In the event that CWM determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only
a small percentage of the order is executed, shares may be allocated to the account with the smallest
order or the smallest position or to an account that is out of line with respect to security or sector
weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account
when one account has limitations in its investment guidelines which prohibit it from purchasing other
securities which are expected to produce similar investment results and can be purchased by other
accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation,
shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s
assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts
low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis
allocation in one or more accounts, CWM may exclude the account(s) from the allocation; the transactions
may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small
proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a
random basis.
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Disclosure Brochure
Item 13. Review of Accounts
Account Reviews
CWM monitors client portfolios on a continuous and ongoing basis. Regular account reviews are conducted
annually at a minimum by CWM personnel. All investment advisory clients are encouraged to discuss their
needs, goals and objectives with CWM and to keep CWM informed of any changes.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Custodians. Clients may also receive quarterly written or electronic reports from CWM
and/or an outside service provider, which contain certain account and/or market-related information, such
as an inventory of account holdings or account performance. Clients should compare the account
statements they receive from their custodian with any documents or reports they receive from CWM or
an outside service provider.
Item 14. Client Referrals and Other Compensation
CWM does not currently provide compensation to any third-party solicitors for client referrals. In the event
a client is introduced to CWM by either an unaffiliated or an affiliated solicitor, CWM will not pay nor
accept a referral fee.
Item 15. Custody
Custody is the ability to take possession of or gain access to your money. CWM is deemed to have custody
of client funds and securities only to the extent the client grants CWM authority to direct the custodian to
debit client accounts for payment of CWM’s fees. As such, client funds and securities are maintained at
one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such
qualified custodians will send account statements to clients at least once per calendar quarter that
typically detail any transactions in such account for the relevant period.
In addition, as discussed in Item 13, CWM will also send, or otherwise make available, periodic
supplemental reports to clients. Clients should carefully review the statements sent directly by the
Financial Institutions and compare them to those received from Cove Wealth Management. Any other
custody disclosures can be found in CWM’s Form ADV Part 1.
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Disclosure Brochure
Standing Letters of Authorization
In special circumstances, CWM has custody due to clients giving CWM limited power of attorney in a
standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically
designated by the client. In such circumstances, CWM will consider the “SEC’s NO ACTION LETTER DATED
FEBRUARY 21, 2017”. The steps in the SEC’s no-action letter include (in summary): i) client will provide
instruction for the SLOA to the custodian; ii) client will authorize CWM to direct transfers to the specific
third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer
of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or
change the instruction; v) CWM will have no authority or ability to designate or change the identity or any
information about the third party; vi) CWM will keep records showing that the third party is not a related
party of CWM or located at the same address as CWM; and vii) the custodian will send the client an initial
and annual notice confirming the SLOA instructions.
Item 16. Investment Discretion
CWM has discretion over its client’s accounts. This means that CWM does not seek a client’s consent first
when buying or selling securities. The client gives CWM this authority through a limited power-of- attorney
included in the agreement between CWM and the client included in initial account paperwork. Clients may
request a limitation on this authority (such as certain securities not to be bought or sold). CWM has
discretion over the following:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The Independent Managers to be hired or fired.
Item 17. Voting Client Securities
Proxy Voting Authority
CWM will not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients will receive
their proxies or other solicitations directly from their custodian or a transfer agent (by email or US mail) for
actions by the client. Clients may contact CWM with questions about a particular solicitation, but we do not
suggest that much time be spent by the client on this activity, unless they desire an active role.
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Disclosure Brochure
Item 18. Financial Information
Cove Wealth Management is not required to disclose any financial information listed in the
instructions to Item 18 because:
• CWM does not require or solicit the prepayment of more than $1,200 in fees six months or more
in advance of services rendered;
• CWM does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• CWM has not been the subject of a bankruptcy petition at any time during the past ten years.
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