Wakeful

Wakeful provides discretionary and non‑discretionary portfolio management, financial planning, pension consulting, and third‑party manager selection to individuals (including high‑net‑worth clients), trusts, estates, corporations, and employer‑sponsored retirement plans, managing approximately $54.7 million for about 250 clients through a single IAR supported by a compliance officer. The firm also offers a mobile application for account access and client onboarding and states that it generally does not impose a formal account minimum.

The firm customizes portfolios to each client’s objectives, risk tolerance, time horizon and liquidity needs and applies fundamental, technical, macroeconomic and quantitative screening in portfolio construction, using strategies that range from long‑term buy‑and‑hold to tactical allocation, income‑oriented and hedging techniques. Wakeful conducts ongoing reviews (at least quarterly) with supervisory oversight by its CCO and documents investment restrictions and discretionary authority in client agreements.

Wakeful’s brochure highlights several features that differ from many peers: Item 7 discloses a substantial majority of clients are non‑U.S. persons, primarily residing in Argentina, and Item 2 documents a recent material increase in assets under management (from roughly $22.7 million to $54.7 million). The filing also discloses the IAR’s dual registration with ACP Securities and outside roles in Argentina (Items 10 and 19), solicitor/promoter compensation arrangements with required disclosures (Item 14), and marketing practices that the firm reports include predecessor and hypothetical performance and the use of endorsements/testimonials, all of which raise specific disclosure and supervisory considerations described in the brochure.