Part 2A of Form ADV: Spire Wealth Management, LLC

[Pages:27]Part 2A of Form ADV: Firm Brochure

Spire Wealth Management, LLC 1840 Michael Faraday Dr. Suite 105 Reston, VA 20190

Telephone: 703-657-6060 Email: info@ Web Address:

March 2019

This brochure provides information about the qualifications and business practices of Spire Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at 703-657-6060 or info@. 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. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. Additional information about Spire Wealth Management, LLC also is available on the SEC's website at adviserinfo.. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 113908.

Item 2 Material Changes

This Firm Brochure, dated March 2019 provides you with a summary of Spire Wealth Management, LLC's ("Spire") advisory services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. This Item is used to provide our clients with a summary of new and/or updated information; we will inform of the revision(s) based on the nature of the information as follows. 1. Annual Update: We are required to update certain information at least annually, within 90 days of our firm's fiscal year end (FYE) of December. We will provide you with either a summary of the revised information with an offer to deliver the full revised Brochure within 120 days of our FYE or we will provide you with our revised Brochure that will include a summary of those changes in this Item. 2. Material Changes: A disclosure was added in Item 9 (disciplinary information) to reflect that Spire consented to the entry of an order instituting proceedings by the U.S. Securities and Exchange Commission. The order alleges that Spire, did not sufficiently disclose that it had a conflict of interest because of the 12b-1 fee compensation received from certain mutual funds by our affiliated broker-dealer while the firm's advisory representatives failed to select a more appropriate share class. The order alleges that the failure to select the most appropriate share class was inconsistent with Spire's duty to seek best execution for those transactions and Spire failed to implement its policies and procedures. Spire has enhanced its Form ADV and Investment Advisory disclosures and implementation process of its policies and procedures. In addition, Spire has converted advisory clients' mutual funds to another share class, where appropriate and available. Spire continues to ensure that all the firm's advisory clients are invested in the most appropriate share class. Please contact your advisor or Spire at 703-657-6060 to request a copy of the entire brochure. Spire's brochure is also available via the SEC website at adviserinfo..

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Item 3 Table of Contents

Item 1 Cover Page

1

Item 2 Material Changes

2

Item 3 Table of Contents

3

Item 4 Advisory Business

4

Item 5 Fees and Compensation

11

Item 7 Types of Clients

14

Item 8 Methods of Analysis, Investment Strategies and Risk of Loss

14

Item 9 Disciplinary Information

17

Item 10 Other Financial Industry Activities and Affiliations

18

Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal

Trading

19

Item 12 Brokerage Practices

19

Item 13 Review of Accounts

24

Item 14 Client Referrals and Other Compensation

25

Item 15 Custody

26

Item 16 Investment Discretion

26

Item 17 Voting Client Securities

27

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Item 4 Advisory Business

Spire Wealth Management, LLC is a SEC registered investment adviser with its principal place of business located in Virginia. Spire Wealth Management, LLC began conducting business in 2001. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). Spire Investment Partners, LLC, Owner In addition, the following information identifies those parties that indirectly own 25% or more of our firm: David L Blisk, CEO

Spire Wealth Management, LLC offers the following advisory services to our clients:

INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT

Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker/dealer or insurance company and will generally include advice regarding the following securities: Exchange-listed securities Securities traded over-the-counter Corporate debt securities (other than commercial paper) Municipal securities Mutual fund shares

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 United States governmental securities

Options contracts on securities

Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability.

Best Execution: Our responsibility in acting as fiduciaries to our clients is to place the client's interests ahead of ours. This includes finding best solutions to the investment needs as well as the most favorable pricing/lowest cost available.

INVESTMENT SUPERVISORY SERVICES ("ISS") MODEL PORTFOLIO MANAGEMENT

Our firm, through our Investment Advisor Representatives (IAR) provides portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal.

We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., capital appreciation, growth, income, or growth and income), as well as tax considerations.

Through personal discussions with the client in which the client's goals and objectives are established, we determine if the model portfolio is suitable to the client's circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities.

Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will generally include advice regarding the following securities:

Exchange-listed securities

Securities traded over-the-counter

Corporate debt securities (other than commercial paper)

Municipal securities

Mutual fund shares

United States governmental securities

Options contracts on securities

Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability.

To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will:

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1. at least annually, attempt to contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 2. be reasonably available to consult with the client; and 3. maintain client suitability information in each client's file.

Proprietary Model Portfolio Strategies

Within Spire's RIA we offer proprietary model portfolio strategies managed by our Investment Advisor Representatives. Corbett Road is a DBA for one of our investment advisor representatives operating under Spire Wealth Management's RIA. Corbett Road Opportunity Strategy

Investment Objective

The Corbett Road Opportunity Strategy seeks long-term growth of capital. The strategy primarily invests in a concentrated portfolio of individual equities of any market capitalization. In may also invest in, and may shift frequently among different asset classes such as fixed income, precious metals, commodities, developed and emerging international securities, and cash and cash equivalents.

Investment Strategy

Within the Opportunity Strategy, Corbett Road implements both a "top-down" and "bottom up" approach to research and investment. The "top down" macro analysis determines the percentage of the investment allocated to equity securities based on economic conditions and the overall position of the business cycle, while bottom-up analysis focuses on fundamental research and individual companies. Through our dual approach, economic events can be recognized for their potential to affect the overall performance of the market (top down) and analysis of individual investment values within the macroeconomic overlay (bottom up) can add to potential returns.

The Strategy's Goals Include:

Long term growth of capital

Maximize returns or mitigate losses through top down economic overlay

Maximize returns through bottom up analysis

Mitigate losses using the internal sell discipline

Opportunity Strategy:

Invests primarily in individual equities and occasionally ETF's The strategy can invest in any exchange traded asset class, any market cap, foreign

and domestic Top down and bottom up investment selection

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 The strategy can go to cash, short term fixed income, and other defensive assets in times of market stress

$100,000 minimum

Corbett Road Core Demand Strategy

Investment Objective

The Corbett Road Core Demand Strategy seeks long term growth of capital as its primary goal and capital preservation as its secondary goal.

Investment Strategy

Corbett Road's Core Demand Strategy is a combination individual stock and ETF strategy. This mainly value oriented strategy invests in company's whose demand is largely inelastic. The strategy also places emphasis on consistent earning and higher than normal dividend payouts.

Core Demand also utilizes a peak return sell discipline whereby risk is reduced at different loss levels from peak strategy return. Risk is then added back to the portfolio based increases in market returns from the market trough.

Uses ETF's and individual stocks Core ETF sector exposure Alpha producing stock exposure Low $50,000 minimum Unique "peak return" sell discipline to strategy

Corbett Road Dynamic Strategy

Investment Objective

The Corbett Road Dynamic ETF Strategy seeks long term growth of capital as its primary goal and capital preservation as its secondary goal. The strategy invests exclusively in exchange traded funds (ETF's).

Investment Strategy

Corbett Road's Dynamic ETF Strategy is a flexible all ETF strategy. Through a proprietary research process, the portfolio is allocated across various asset classes to maximize risk adjusted returns. Dynamic uses both strategic and tactical "Stratical" allocation using a core/satellite approach in order to adjust the exposure to riskier assets depending on market conditions.

Uses ETF's exclusively Core/Satellite approach is driven by over and underweighting specific indices/sectors Uses "MVM" (macro, value and momentum) for satellite investment selection $100,000 minimum Unique sell discipline to strategy

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 Best used in Qualified accounts

Corbett Road EDGE Strategy

Investment Objective

The Corbett Road EDGE Strategy seeks to primarily generate above average income using both the equity and fixed income markets with some potential for capital appreciation over the long term.

Investment Strategy

Corbett Road EDGE Strategy is an ETF strategy that invests in the equity, convertible and preferred issues, MLP's and fixed income. Used as a compliment to produce income to low yielding fixed income strategies.

Uses ETF's exclusively $100,000 minimum High Income with Capital Appreciation potential

Corbett Road MyPath Strategies

Investment Objective

The Corbett Road MAAPTM Strategies (MyPath Asset Allocation Portfolios) offer 7 different allocations from aggressive to conservative. At its most aggressive the strategy seeks to achieve long-term growth through asset class, sector and geographic diversification. At its most conservative the strategy can provide income and capital preservation through borrower, quality, duration and geographic diversification.

Investment Strategy

All MAAPTM strategies use Corbett Road's MACROCASTTM analysis to signal an appropriate time to shift asset classes and/or exercise a portfolio level rebalance. This strategic initiative can occur proactively or reactively up to 3x per year and can also trigger investments beyond traditional asset classes in times of economic stress.

The MAAPTM strategies can be utilized as a stand alone solution or in conjunction with the firm's tactical asset strategies as a Core/ Satellite approach to investing.

Model allocations will range from 100% Equity with focus on long term growth to a 30% Equity 70% Fixed Income model for those clients that are looking for higher emphasis on preservation of capital and income.

Uses ETF's exclusively Low $50,000 minimum Reduces Investment cost and greater tax efficiency Ongoing investment monitoring and rebalancing Complements Corbett Road's SmartTacticalTM Strategies

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