Wm Advisors Usa is a investment adviser based in Pinecrest, FL, that holds a 90.0/100 Fidelon TransparencyScore (57th percentile among state-registered advisers), with 3 registered advisors. Score based on public SEC and FINRA filings.
Wm Advisors Usa
Wm Advisors Usa LLC · CRD #323133
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Wm Advisors Usa LLC is a state-registered investment adviser in Pinecrest, FL. It used to be called Highlands Investment Management LLC and Wm Advisors LLC. It has 3 registered advisors. It manages $31.4 million across 45 client accounts. It charges a percentage of the money it manages for you, and it does not report earning commissions. Its services include financial planning and investment newsletters. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
4th of 15,825
state-registered advisers
Top 43%
1st of 1,226
state-registered advisers in FL
#1 ranked
1st of 1
state-registered advisers in Pinecrest, FL
#1 ranked
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Does not earn commissions on product sales
What you’d pay
Your balance falls in the All accounts band, charged at 0.45%–1.25% on the full amount. The brochure files a range for this band, so the exact rate is set in your agreement.
This fee is negotiable
“Our advisory fee is negotiable, depending on individual client circumstances.”
From their Form ADV Part 2A. Most investors never ask.
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| All accounts | 0.45%–1.25% |
Billed quarterly
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Things You Should Know
- Its brochure names the firm's own products as a conflict, but it does not explain what this arrangement tempts the firm to do, say what the firm is paid for it, or say what it can cost you. Ask which products in your account are the firm's own, and how they compare on cost with outside choices.Items 10, 11, 12.B and 14
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
99/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
50/100
Weak
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
Not required
This firm is not required to file a Form CRS.
Without a Form CRS, the score above cannot go over 90. A firm that gives us one is scored on the same yardstick and can earn up to 10 more points.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity100/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
The brochure answers every one of these.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
Our fee for portfolio management services ranges from 0.45% to 1.25% per year of the value of your assets we manage, and/or a performance-based fee discussed below.p. 4
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
Our advisory fee is negotiable, depending on individual client circumstances.p. 5
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
We will send you an invoice for the payment of our advisory fee or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities.p. 5
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
Our discretionary portfolio management fee is generally billed and payable quarterly in arrears, based on the monthly average value of your account calculated on the last day of the quarter.p. 5
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders.p. 7
- Does it say how you get money back if you leave mid-period?CoveredItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
In the event the Adviser bills fees in advance, refunds are given on a prorated basis, based on the number of days remaining in a quarter at the point of termination.p. 5
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity50/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If the firm sells its own products, does it explain how that can shape its advice?
The firm's own products
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Pursuant to the stipulations of the Code, Adviser or a related person may buy or sell for itself securities that it also recommends to clients.p. 14
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk which products in your account are the firm's own, and how they compare on cost with outside choices.
Do they earn commissions on products, and do they say so?Brochure Sales CompensationNot applicable
Not applicable: the brochure describes no product-sales commissions
Do they get free research or services from brokers, and does it affect you?Brochure Soft DollarsNot applicable
Not applicable: the brochure describes no research or services from brokers
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
3 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Cesar Eduardo Miranda | 5934973 | — | — |
| Enrique Roberto Walsh | 6830890 | — | — |
| Alexis Henri Weill | 4973722 | — | — |
Marketing Brands1 brand
Names advisors at this firm use when marketing to clients
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #323133