Form ADV2A-2B and Table of Fees for Service
Reconstructing Wealth, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: March 12, 2024
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Reconstructing Wealth, LLC (“Reconstructing Wealth” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (843) 214-2775 or by email at matt@reconstructingwealth.com.
Reconstructing Wealth is a registered investment advisor located in the State of South Carolina. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Reconstructing Wealth to assist you in determining whether to retain the Advisor.
Additional information about Reconstructing Wealth and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 328284.
Reconstructing Wealth, LLC
186 Seven Farms Dr. Suite F, Box 216, Daniel Island, SC 29492
Phone: (843) 214-2775
http://www.reconstructingwealth.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the “Disclosure Brochure”) and Part 2B (the “Brochure Supplement”). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Reconstructing Wealth. For convenience, the Advisor has combined these documents into a single disclosure document.
Reconstructing Wealth believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Reconstructing Wealth encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last filing and distribution to Clients.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 328284. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (843) 214-2775 or by email at matt@reconstructingwealth.com.
Item 3 – Table of Contents
Item 1 – Cover Page 1
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Services
A. Firm Information
B. Advisory Services Offered
C. Client Account Management
D. Wrap Fee Programs
E. Assets Under Management
Item 5 – Fees and Compensation
A. Fees for Advisory Services
B. Fee Billing
C. Other Fees and Expenses
D. Advance Payment of Fees and Termination
E. Compensation for Sales of Securities
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
B. Risk of Loss
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
B. Personal Trading with Material Interest
C. Personal Trading in Same Securities as Clients
D. Personal Trading at Same Time as Client
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
B. Aggregating and Allocating Trades
Item 13 – Review of Accounts
A. Frequency of Reviews
B. Causes for Reviews
C. Review Reports
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Reconstructing Wealth
B. Compensation for Client Referrals
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Item 19 – Requirements for State Registered Advisors
A. Educational Background and Business Experience of Principal Officer
B. Other Business Activities of Principal Officer
C. Performance Fee Calculations
D. Disciplinary Information
E. Material Relationships with Issuers of Securities
Form ADV Part 2B – Brochure Supplement
Item 2 – Educational Background and Business Experience
Item 3 – Disciplinary Information
Item 4 – Other Business Activities
Item 5 – Additional Compensation
Item 6 – Supervision
Item 7 – Requirements for State Registered Advisors
Privacy Policy
Item 4 – Advisory Services
A. Firm Information
Reconstructing Wealth, LLC (“Reconstructing Wealth” or the “Advisor”) is a registered investment advisor located in the State of South Carolina. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of South Carolina. Reconstructing Wealth was founded in August 2023 and became a registered investment advisor in January 2024. The Advisor is owned by Wild Faith, LLC and operated by Mr. Matthew Morizio (CEO and Chief Compliance Officer). Mr. Morizio is the Owner of Wild Faith, LLC. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Reconstructing Wealth.
B. Advisory Services Offered
Reconstructing Wealth offers investment advisory services to individuals and high net worth individuals (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Reconstructing Wealth’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Investment Management Services
Reconstructing Wealth provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Reconstructing Wealth works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Reconstructing Wealth will then construct an investment portfolio consisting of individual stocks to achieve the Client’s investment goals. The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations.
Reconstructing Wealth’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Reconstructing Wealth will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Reconstructing Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Reconstructing Wealth may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Reconstructing Wealth may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement.
Reconstructing Wealth may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Reconstructing Wealth accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor.
Financial Planning Services
Reconstructing Wealth will provide a variety of financial planning and consulting services to Clients pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific 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, investment planning, retirement planning, personal savings, education savings, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs.
Reconstructing Wealth may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor.
C. Client Account Management
Prior to engaging Reconstructing Wealth to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
- Establishing an Investment Strategy – Reconstructing Wealth, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
- Asset Allocation – Reconstructing Wealth will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
- Portfolio Construction – Reconstructing Wealth will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
- Investment Management and Supervision – Reconstructing Wealth will provide investment management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Reconstructing Wealth does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Reconstructing Wealth.
E. Assets Under Management
Reconstructing Wealth is a newly established advisor. Assets under management shall be reported with the Advisor’s next filing of this Disclosure Brochure. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, in advance of each quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior quarter. Investment advisory fees are based on the following schedule:
Assets Under Management ($) | Annual Rate (%) |
Up to $1,000,000 | 2.00% |
$1,000,001 to $2,000,000 | 1.75% |
$2,000,001 to $3,000,000 | 1.50% |
$3,000,001 to $4,000,000 | 1.25% |
$4,000,001 to $5,000,000 | 1.00% |
$5,000,001 and up | 0.75% |
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by Reconstructing Wealth will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs.
Financial Planning Services
Reconstructing Wealth offers financial planning services at an hourly rate of $300. An estimate for total hours and overall costs will be provided to the Client prior to engaging for these services.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Reconstructing Wealth at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. In addition, the Advisor will provide the Client a report itemizing the fee, including the calculation period covered by the fee, the account value and the methodology used to calculate the fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Reconstructing Wealth to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian.
Financial Planning Services
Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s].
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Reconstructing Wealth, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor’s recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client’s account, provided that the account meets the terms and conditions of the Custodian’s brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by Reconstructing Wealth are separate and distinct from these custody and execution fees.
In addition, all fees paid to Reconstructing Wealth for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Reconstructing Wealth, but would not receive the services provided by Reconstructing Wealth which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Reconstructing Wealth to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Investment Management Services
Reconstructing Wealth may be compensated for its investment management services in advance of the quarter in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent.
Financial Planning Services
Reconstructing Wealth is compensated for its financial planning services upon completion of the engagement deliverable[s]. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Reconstructing Wealth does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
Reconstructing Wealth does not charge performance-based fees for its investment advisory services. The fees charged by Reconstructing Wealth are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client.
Reconstructing Wealth does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
Reconstructing Wealth offers investment advisory services to individuals and high net worth individuals. Reconstructing Wealth generally does not impose a minimum relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Reconstructing Wealth primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from Reconstructing Wealth are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Reconstructing Wealth will be able to accurately predict such a reoccurrence.
As noted above, Reconstructing Wealth generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Reconstructing Wealth will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Reconstructing Wealth 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.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Reconstructing Wealth will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client’s account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets.
Equity (Stock) Risks
Common stocks are susceptible to general stock market fluctuations and to volatile increases or decreases in value as market confidence in and perceptions of their issuers change. If an investor held common stock or common stock
equivalents of any given issuer, they may be exposed to greater risk than if they held preferred stocks and debt obligations of the issuer. Preferred stocks can be affected by interest rate and liquidity risks (described in adjacent paragraphs). Also note that their dividend payment is not guaranteed; some are subject to a call provision, meaning the issuer can redeem its preferred shares on demand, and usually when interest rates have fallen.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Reconstructing Wealth or Mr. Morizio. Reconstructing Wealth values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Mr. Morizio are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 328284.
In addition, Clients may also obtain information relating to the disciplinary history of any investment advisor representative conducting business in Massachusetts by contacting the Commonwealth of Massachusetts Securities Division at (617) 727-3548.
Item 10 – Other Financial Industry Activities and Affiliations
The sole business of Reconstructing Wealth and Mr. Matthew Morizio is to provide investment advisory services to its Clients. Neither Reconstructing Wealth nor its Advisory Persons are involved in other business endeavors. Reconstructing Wealth does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Reconstructing Wealth has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Reconstructing Wealth (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Reconstructing Wealth and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Reconstructing Wealth’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (843) 214-2775 or via email at matt@reconstructingwealth.com.
B. Personal Trading with Material Interest
Reconstructing Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Reconstructing Wealth does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Reconstructing Wealth does not have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Reconstructing Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Reconstructing Wealth conducting a coordinated review of personal accounts and the accounts of the Clients. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Reconstructing Wealth allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Reconstructing Wealth, or any Supervised Person of Reconstructing Wealth, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Reconstructing Wealth does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the “Custodian”) to safeguard Client assets and authorize Reconstructing Wealth to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Reconstructing Wealth does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis.
Where Reconstructing Wealth does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Reconstructing Wealth. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Reconstructing Wealth may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Reconstructing Wealth will generally recommend that Clients establish their account[s] at Altruist Financial LLC (“Altruist”), a FINRA-registered broker-dealer and member SIPC. Altruist will serve as the Client’s “qualified custodian”. Reconstructing Wealth maintains an institutional relationship with Altruist, whereby the Advisor receives economic benefits.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Reconstructing Wealth does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below.
2. Brokerage Referrals – Reconstructing Wealth does not receive any compensation from any third party in connection with the recommendation for establishing an account.
3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis”, where Reconstructing Wealth will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Reconstructing Wealth will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Reconstructing Wealth will execute its transactions through the Custodian as authorized by the Client. Reconstructing Wealth may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Mr. Matthew Morizio, Chief Compliance Officer of Reconstructing Wealth. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Reconstructing Wealth if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the 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]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Reconstructing Wealth
Reconstructing Wealth is a fee-only advisory firm, that is compensated solely by its Clients and not from any investment product. Reconstructing Wealth does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. Reconstructing Wealth may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Reconstructing Wealth may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform
Reconstructing Wealth has established an institutional relationship with Altruist to assist the Advisor in managing Client account[s]. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Altruist The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a potential conflict of interest since these benefits may influence the Advisor’s recommendation of this Custodian over one that does not furnish similar software, systems support, or services.
B. Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals.
Item 15 – Custody
Reconstructing Wealth does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Reconstructing Wealth to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by Reconstructing Wealth to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices.
Item 16 – Investment Discretion
Reconstructing Wealth generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Reconstructing Wealth. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client’s execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Reconstructing Wealth will be in accordance with each Client’s investment objectives and goals.
Item 17 – Voting Client Securities
Reconstructing Wealth does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Reconstructing Wealth nor its management, have any adverse financial situations that would reasonably impair the ability of Reconstructing Wealth to meet all obligations to its Clients. Neither Reconstructing Wealth, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Reconstructing Wealth is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $500 or more for services to be performed six months or more in the future.
Item 19 – Requirements for State Registered Advisors
A. Educational Background and Business Experience of Principal Officer
The Principal Officer of Reconstructing Wealth is Mr. Matthew Morizio. Information regarding the formal education and background of Mr. Morizio is included the Form ADV 2B – Brochure Supplement below.
B. Other Business Activities of Principal Officer
Mr. Morizio is dedicated to the investment advisory activities of Reconstructing Wealth’s Clients. Mr. Morizio does not have any other business activities.
C. Performance Fee Calculations
Reconstructing Wealth does not charge performance-based fees for its investment advisory services. The fees charged by Reconstructing Wealth are as described in Item 5 – Fees and Compensation above and are not based upon the capital appreciation of the funds or securities held by any Client.
D. Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Reconstructing Wealth or Mr. Matthew Morizio. Neither Reconstructing Wealth nor Mr. Morizio have ever been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Reconstructing Wealth or Mr. Morizio.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Reconstructing Wealth or Mr. Morizio.
E. Material Relationships with Issuers of Securities
Neither Reconstructing Wealth nor Mr. Morizio have any relationships or arrangements with issuers of securities.
Form ADV Part 2B – Brochure Supplement
for
Matthew P. Morizio
CEO and Chief Compliance Officer
Effective: March 12, 2024
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Matthew P. Morizio (CRD# 6793999) in addition to the information contained in the Reconstructing Wealth, LLC (“Reconstructing Wealth” or the “Advisor”, CRD# 328284) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Reconstructing Wealth Disclosure Brochure or this Brochure Supplement, please contact us at (843) 214-2775 or by email at matt@reconstructingwealth.com.
Additional information about Mr. Morizio is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6793999.
Item 2 – Educational Background and Business Experience
Matthew P. Morizio, born in 1983, is dedicated to advising Clients of Reconstructing Wealth as the CEO and Chief Compliance Officer. Mr. Morizio earned a Bachelor’s Degree from Northeastern University in 2012. Additional information regarding Mr. Morizio’s employment history is included below.
Employment History:
CEO and Chief Compliance Officer, Reconstructing Wealth, LLC | 01/2024 to Present |
Financial Advisor, Beck Bode LLC | 01/2017 to 01/2024 |
Market Manager, Kforce Inc. | 04/2012 to 01/2017 |
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Morizio. Mr. Morizio has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Morizio.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Morizio.
However, we do encourage you to independently view the background of Mr. Morizio on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6793999.
Item 4 – Other Business Activities
Mr. Morizio is dedicated to the investment advisory activities of Reconstructing Wealth’s Clients. Mr. Morizio does not have any other business activities.
Item 5 – Additional Compensation
Mr. Morizio is dedicated to the investment advisory activities of Reconstructing Wealth’s Clients. Mr. Morizio does not receive any additional forms of compensation.
Item 6 – Supervision
Mr. Morizio serves as the CEO and Chief Compliance Officer of Reconstructing Wealth. As a result, no other individual of the Advisor supervises the activities of Mr. Morizio. Mr. Morizio can be reached at (843) 214-2775.
Reconstructing Wealth has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Reconstructing Wealth. Further, Reconstructing Wealth is subject to regulatory oversight by various agencies. These agencies require registration by Reconstructing Wealth and its Supervised Persons. As a registered entity, Reconstructing Wealth is subject to examinations by regulators, which may be announced or unannounced. Reconstructing Wealth is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Item 7 – Requirements for State Registered Advisors
A. Arbitrations and Regulatory Proceedings
State regulations require disclosure if any Supervised Person of the Advisor is subject to:
- An award or otherwise being found liable in an arbitration claim alleging damages in excess of $2,500, involving any of the following:
- an investment or an investment-related business or activity;
- fraud, false statement(s), or omissions;
- theft, embezzlement, or other wrongful taking of property;
- bribery, forgery, counterfeiting, or extortion; or
- dishonest, unfair, or unethical practices.
- An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following:
- an investment or an investment-related business or activity;
- fraud, false statement(s), or omissions;
- theft, embezzlement, or other wrongful taking of property;
- bribery, forgery, counterfeiting, or extortion; or
- dishonest, unfair, or unethical practices.
Mr. Morizio does not have any disclosures to make regarding this Item.
B. Bankruptcy
If a Supervised Person has been the subject of a bankruptcy petition, that fact and the details must be disclosed.
Mr. Morizio does not have any disclosures to make regarding this Item.
Table of Fees for Services
Reconstructing Wealth, LLC (CRD# 328284)
Effective Date: March 12, 2024
Reconstructing Wealth, LLC (the “Advisor”) provides this Table of Fees for Services as a supplemental disclosure to its Form ADV Part 2A (“Disclosure Brochure”). Please reference Items 4 and 5 of the Disclosure Brochure, which contains important details about the Advisor’s services and fees. Fees are negotiable at the sole discretion of the Advisor. The fees below will only apply to you when you request the services listed.
Fees Charged by Advisor | Fee Amount | Frequency Fee is Charged | Services | |
A percentage of assets under management | Up to $1,000,000 | 2.00% | Quarterly in advance | Portfolio Management for individuals and/or small businesses |
$1,000,001 to $2,000,000 | 1.75% | |||
$2,000,001 to $3,000,000 | 1.50% | |||
$3,000,001 to $4,000,000 | 1.25% | |||
$4,000,001 to $5,000,000 | 1.00% | |||
$5,000,001 and up | 0.75% | |||
Hourly charges | $300 | Invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s]. | Financial Planning Services | |
Subscription fees | $0 | n/a | n/a | |
Fixed fees | $0 | n/a | n/a | |
Commissions | $0 | n/a | n/a | |
Performance-based fees | $0 | n/a | n/a | |
Other:____________ | $0 | n/a | n/a | |
Fees Charged by Third Parties | Fee Amount | Frequency Fee is Charged | Services | |
Independent Manager Fees | $0 | n/a | n/a | |
Robo-Advisor Fee | $0 | n/a | n/a | |
Please talk to the Advisor about fees and costs applicable to you |
Additional Fees/Costs | Yes/No |
Securities Transaction Fees* | Yes |
Commissions | $0 |
Custodian Fees** | $0 |
Mark-ups | $0 |
Mutual Fund/ETF Fees and Expenses | Mutual Funds: $0 ETFs: $0 |
* No transaction fees will be assessed for Exchange -traded funds or domestic equity securities traded online. Other types of securities subject to fees.
** The Custodian does not charge a custody fee, but fee may include wire transfer fees, paper statement fees etc.