Wpm Wealth Advisors is a investment adviser based in Saratoga Springs, NY, that holds a 86.8/100 Fidelon TransparencyScore (58th percentile among SEC-registered advisers), with 3 registered advisors. Score based on public SEC and FINRA filings.
Wpm Wealth Advisors
Wpm Wealth Advisors LLC · CRD #316722
A registered investment adviser held to a fiduciary standard.
Fidelon Fact Sheet
Wpm Wealth Advisors LLC is an SEC-registered investment adviser in Saratoga Springs, NY. It used to be called Wcm Wealth Advisors LLC. It has 3 registered advisors. It manages $72.4 million across 353 client accounts. It charges a yearly percentage of your account, and it does not report earning commissions. Its services include financial planning and portfolio management. Its filing reports disclosures.
Peer Context
4,538th of 10,815
SEC-registered advisers
Top 42%
468th of 1,070
SEC-registered advisers in NY
Top 44%
6th of 14
SEC-registered advisers in Saratoga springs, NY
Top 43%
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 0.00%–3.00% 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
“These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, fees associated with “step out” transactions if the account uses different custodians or broker-dealers, 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.
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 | 0.00%–3.00% |
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
- Transparent fee structure — charges advisory fees, no commissions
- TransparencyScore in the top 42% of SEC-registered advisers
Things You Should Know
- Has regulatory disclosures on file — count not available yet
- Its brochure says it receives research or services from brokers, but it does not say those perks can shape which broker it picks for you, whether every client benefits or only some, or whether those perks stay within what the law allows. Ask how the firm chooses the broker for your trades and whether perks play any part.Item 12.A.1
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“Additionally, the amount of assets in your account affects our advisory fee; the more assets you have in your advisory account, the more you will pay us and thus we have an incentive to increase those assets in order to increase our fee.”
Source: the firm’s own Form CRS, filed 2024-03-25 — quoted directly
Regulatory Track Record
On file
Disclosures
Count not available
—
Total Fines
Not available
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
98/100
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.
92/100
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.
55/100
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?
- Does it include everything the SEC requires?
- Required sections
- 83/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
- 83/100
- Can you tell what you would pay?
- What you pay
- 95/100
- Is it written in plain English?
- Plain language
- 96/100
This firm's Form CRS averages 89 out of 100. It adds 7.31 points once the firm's filings and record score 90 on their own; they score 86.79 today.
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 ClarityNot applicable
Not applicable: fee terms are in a wrap-fee appendix, which this check does not read
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity60/100
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 gets research or services from a custodian or broker, does it explain them?
Research or services received from a custodian or broker (soft dollars)
- 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.
Charles Schwab & Co., Inc. Advisor Services also makes available to WPM other products and services that benefit WPM but may not benefit its clients’ accounts.p. 16
- 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?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
These benefits may include national, regional or WPM specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services.p. 16
- 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?CoveredStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
Charles Schwab & Co., Inc. Advisor Services also makes available to WPM other products and services that benefit WPM but may not benefit its clients’ accounts.p. 16
- 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 what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.
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 Dollars41/100
When brokers give the firm research or services in return for your trades, the SEC asks the brochure to say what the firm gets and what it may cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it list what the firm gets from brokers for free?CoveredItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market datap. 16
- Does it say the firm benefits by not paying for those things?CoveredItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
Charles Schwab & Co., Inc. Advisor Services also makes available to WPM other products and services that benefit WPM but may not benefit its clients’ accounts.p. 16
- Does it say those perks can shape which broker it picks for you?Not found in the brochureItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
What to askAsk how the firm chooses the broker for your trades and whether perks play any part.
- Does it say whether those perks stay within what the law allows?Not found in the brochureItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
What to askAsk whether everything the firm receives from brokers is research the law lets it take in return for your trades.
- Does it say whether you pay more in trading costs because of those perks?Does not applyItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
- Does it say whether every client benefits or only some?Not found in the brochureItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
What to askAsk whether the research your trades help pay for is used for your account.
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 |
|---|---|---|---|
| Sandy Sau Fan Moi | 3070347 | — | — |
| William Paul Gamello | 1722812 | — | — |
| Manuel Nmn Choy | 4464917 | — | — |
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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 #316722