EVOKE ADVISORS

Evoke Wealth, LLC d/b/a Evoke Advisors (“EVOKE” or the “Firm”) is a limited liability company organized in Delaware. EVOKE is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). EVOKE is owned by Evoke Holdings, LLC with a 1% minority interest held by passive estate planning entities owned by Mr. David Hou and Mr. Mark Sear through their trusts. The principal owner of Evoke Holdings, LLC as of the time of this Brochure filing is David Hou. 

Types of Advisory Services 

EVOKE provides holistic and personalized financial planning and discretionary and non-discretionary investment advisory services to individuals, including high and ultra-high net worth individuals, and entities, including, but not limited to, family offices, trusts, and estates. EVOKE also offers consulting and advisory services to pension and retirement/profit-sharing plans, pooled investment vehicles, foundations, endowments, charitable organizations, guilds and health plans, investment companies, family offices, corporations, and other business entities. 

Financial Planning and Consulting Services 

EVOKE provides a variety of comprehensive financial planning and consulting services to clients. Such engagements may be part of the investment advisory engagement, or pursuant to a written Family Office Services Agreement (“FOSA”), or pursuant to a separate engagement. Generally, such financial planning services will involve preparing a financial plan or rendering a 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, cash flow analysis, investment planning, retirement planning, estate planning, personal savings, educational savings, and other areas of a client’s financial situation. 

This planning or consulting may encompass one or more areas of need, including but not limited to the following: 

-Tax planning 

-Estate planning 

-Philanthropic planning 

-Generational involvement and planning 

-Risk management & insurance coverages 

-Cash flow planning & management 

-Business management and consulting services 

A financial plan developed for, or financial consultation rendered to, a client will typically 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. EVOKE may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if EVOKE recommends its own services, as such a recommendation may increase the advisory fees paid to EVOKE. The client is under no obligation to act upon any of the recommendations made by EVOKE under a financial planning or consulting engagement to engage the services of any such recommended professional, including EVOKE itself. 

Investment Management Services 

EVOKE seeks to tailor its investment management services to meet the needs of its individual clients and seeks to manage client portfolios in a manner consistent with those needs and objectives. EVOKE consults with clients on an initial and periodic basis to assess their specific risk tolerance, time horizon, liquidity constraints, and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify EVOKE if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if EVOKE determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to EVOKE’s management efforts. 

In designing and implementing customized models and portfolio strategies, EVOKE can manage, on a discretionary or non-discretionary basis, a broad range of investment strategies and vehicles. EVOKE primarily allocates client assets among various investment managers’ mutual funds, exchange-traded funds (“ETFs”), closed-end funds (“CEFs”), structured products, options, debt securities, and alternative investments in accordance with clients’ stated investment objectives, risk profile and financial condition. 

EVOKE may recommend to clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated or affiliated money managers or investment platforms (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. In addition to this Brochure, clients may also receive the written disclosure documents of the respective External Managers engaged to manage their assets. EVOKE generally renders services to the client relative to the discretionary selection of External Managers. EVOKE also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, advisory fees charged by EVOKE. EVOKE evaluates a variety of information about External Managers, which may include the External Managers’ public disclosure documents, materials supplied by the External Managers themselves and other third-party analyses it believes are appropriate and reputable. To the extent possible, EVOKE seeks to assess the External Managers’ investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and risk exposure. EVOKE also takes into consideration each External Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. 

EVOKE may also recommend that clients invest in unaffiliated or affiliated private investment vehicles whose interests are not publicly offered under the Securities Act of 1933 (“Private Funds”). Such Private Funds may be structured as fund of funds or as access vehicles to underlying funds or portfolios managed by third-party investment advisors. EVOKE will, from time to time and as appropriate, solicit clients to invest in such vehicles, and EVOKE will decide which clients to approach for some or all of these investments at its own discretion. All relevant information pertaining to Private Fund recommendations, including the compensation received by EVOKE (if any) or an EVOKE affiliate or related person (as applicable), and by the third-party manager resulting from a client’s investment in a Private Fund, other fees and expenses paid by the respective Private Fund, withdrawal rights, minimum investments, qualification requirements, suitability, risk factors, and potential conflicts of interest is set forth in the respective Private Fund’s disclosure documents, governing documents and other offering materials pertaining to such interests (the “Offering Materials”). Each investor is required to receive, review, and execute (as applicable) the Offering Materials prior to being accepted as an investor in any such Private Fund. It is important to note that any EVOKE advisory fee charged to clients for investing in a Private Fund is in addition to the fees charged by the Private Funds to investors. This is a conflict of interest with the multiple fees charged because EVOKE affiliates may serve as general partners of affiliated Private Funds and will receive multiple forms of compensation. It should also be noted that certain members of EVOKE may directly participate in any of the investment opportunities described for which an affiliated Private Fund is established and/or may participate through the Private Fund itself for the purposes of investing. This right to participate and any corresponding economic interest therefrom will likely mean that certain members of EVOKE will derive a direct or indirect benefit from their direct participation and may also receive management fees, carried interest, and other fees that a Private Fund charges to investors and clients for their participation in the respective investment opportunity. As such, a conflict of interest arises between the presentation of a private market investment opportunity to EVOKE clients and prospective clients, and those members of EVOKE who will have an interest in the alternative investment opportunity and who, through an affiliated Private Fund, may also be charging clients and investors a variety of fees for investment in the respective investment opportunity. Therefore, it should be understood that members of EVOKE may be highly incentivized to recommend an alternative investment opportunity to clients. Clients are strongly advised and encouraged to discuss this conflict of interest with their advisors and to assess the risks, merits, charges, suitability, and appropriateness of the opportunity prior to making any investment decision. 

Sub-Advisory Services 

Evoke provides the above-mentioned Investment Management Services as contracted with one or more established insurance carriers for the purpose of supporting certain benefits payable under one or more variable life insurance, variable annuity, or other variable insurance policies as characterized under Section 817(d) of the U.S. Internal Revenue Code of 1986, as amended (the “Code”) as a “variable contact” (each a “Contract”) issued by the Carriers to the Contract owners (each, a “Contract Owner”). These services are provided pursuant to Investment Policy Statements as agreed upon with each carrier. 

ERISA Services 

EVOKE can provide either discretionary or non-discretionary, fiduciary, and non-fiduciary advisory services to the sponsors of defined contribution, defined benefit and non-qualified deferred compensation plans, who in certain circumstances have ultimate authority to direct the investing and reinvesting of plan assets as they deem appropriate, considering each plan’s stated objective, liquidity needs, stated policies and guidelines. Providing investment services to plans under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), means that the ERISA plan client retains and exercises the final decision-making authority for implementing or rejecting EVOKE’s recommendations. Certain of the foregoing services are provided by EVOKE as a fiduciary. When EVOKE provides investment advice for a fee to an ERISA plan or ERISA plan participant, it is a fiduciary under ERISA. In addition, EVOKE is a fiduciary under the Internal Revenue Code when it provides investment advice to an ERISA plan, ERISA plan participant, an IRA, or an IRA owner (collectively, a “Retirement Account Client”). EVOKE is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from engaging in specified conflicts of interest. 

Retirement Plan and Investment Consulting Services 

EVOKE also offers clients a broad range of retirement plan and investment consulting services, which may include advice regarding asset allocation, manager selection, and investment risk management, among other areas. 

EVOKE may recommend clients engage the Firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage EVOKE or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by EVOKE under a retirement plan or investment consulting engagement. In performing these services, EVOKE is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising EVOKE’s’ recommendations and/or services. 

Evoke engages with retirement plan Clients in a wide range of capacities. For plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), this could include serving as an ERISA Section 3(21) fiduciary providing investment recommendations to the plan sponsor and/or plan trustee, or as an ERISA Section 3(38) “investment manager” with discretionary authority to make investment decisions on behalf of the plan. In addition to allocating plan assets and portfolio management, these services can include assistance in setting up an Investment Policy Statement for the portfolio, managing cash and liquidity needs, selecting professional record‐keepers, administrators and custodians, and providing in depth quarterly or annual review with the portfolio’s performance and our outlook on financial market conditions. In addition, Evoke has adopted policies and procedures designed to comply with the ERISA fiduciary standards when advising retirement asset rollovers as set forth in the Department of Labor Fiduciary Rule (“DOL PTE Rule”). Clients will be presented with disclosure documents as prescribed by the DOL PTE Rule.

Advisory Services to Proprietary Funds 

EVOKE has entered into an investment management agreement with Advanced Research Alpha Fund, L.P. and Advanced Research Alpha Fund, Ltd. in addition to certain feeder fund vehicles for which Evoke’s affiliate, EVOKE GP, LLC serves as the general partner. EVOKE provides investment management and advisory services to these funds through their investment in other privately offered investment funds. 

Affiliated Sponsor and Index Provider for the RPAR Risk Parity ETF 

In December 2019, Tidal ETF Services launched the RPAR Risk Parity ETF (“RPAR”) with EVOKE’s affiliate, Advanced Research Investment Services, LLC (“ARIS”) serving as fund sponsor. While EVOKE does not manage, advise, or sub-advise RPAR, EVOKE’s affiliate, RPAR, LLC, currently serves as the fund sponsor and manages the Advanced Research Risk Parity Index (“RPARTR”) which RPAR seeks to replicate. As such, RPAR, LLC is considered an affiliated index provider to RPAR. To mitigate any potential for conflicts with respect to its affiliated Index Provider, EVOKE has retained a separate, unaffiliated, and independent third party to serve as calculation agent to RPAR (the “Calculation Agent”). EVOKE has no affiliation with RPAR’s Calculation Agent, RPAR’s adviser, RPAR’s sub-adviser, RPAR’s distributor, nor any of their respective affiliates. The Calculation Agent, using the applicable rules-based methodology, calculates, maintains, and disseminates RPARTR on a daily basis. RPAR, LLC monitors the results produced by the Calculation Agent to help ensure that RPARTR is being calculated in accordance with the applicable rules-based methodology. In addition, EVOKE has established policies and procedures designed to prevent non-public information about pending changes to RPARTR from being used or disseminated in an improper manner. Furthermore, EVOKE has established policies and procedures designed to prevent improper use and dissemination of non-public information about RPAR’s portfolio strategy. 

It is important to note that as EVOKE’s affiliate RPAR, LLC is the sponsor of RPAR, EVOKE receives a portion of the fees collected, and therefore, is incentivized to market RPAR to EVOKE clients and prospective investors. This inherently creates a conflict of interest that both EVOKE clients and prospective investors should carefully consider when deciding whether to invest in RPAR. To the extent that EVOKE invests advisory client assets in RPAR, EVOKE or its related persons may charge management fees both at the RPAR level and client account level; however, we or our related persons may also waive management fees (or certain portions thereof) on client assets invested in RPAR, credit or rebate a client account for the fees paid by RPAR to us or our related persons, or otherwise avoid or limit the payment of duplicative fees to us and our related persons. 

Affiliated Sponsor and Index Provider for the UPAR Ultra Risk Parity ETF 

In January 2022, Tidal ETF Services launched the UPAR Ultra Risk Parity ETF (“UPAR”) with EVOKE’s affiliate, Advanced Research Investment Services, LLC (“ARIS”) serving as fund sponsor. While EVOKE does not manage, advise, or sub-advise UPAR, EVOKE’s affiliate, RPAR, LLC, currently serves as the fund sponsor and manages the Advanced Research Ultra Risk Parity Index (“UPARTR”) which UPAR seeks to replicate. As such, RPAR, LLC is considered an affiliated index provider to UPAR. To mitigate any potential for conflicts with respect to its affiliated Index Provider, EVOKE has retained a separate, unaffiliated, and independent third party to serve as calculation agent to UPAR (the “Calculation Agent”). EVOKE has no affiliation with UPAR’s Calculation Agent, UPAR’s adviser, UPAR’s sub-adviser, UPAR’s distributor, nor any of their respective affiliates. The Calculation Agent, using the applicable rules[1]based methodology, calculates, maintains, and disseminates UPARTR on a daily basis. RPAR, LLC monitors the results produced by the Calculation Agent to help ensure that UPARTR is being calculated in accordance with the applicable rules-based methodology. In addition, EVOKE has established policies and procedures designed to prevent non-public information about pending changes to UPARTR from being used or disseminated in an improper manner. Furthermore, EVOKE has established policies and procedures designed to prevent improper use and dissemination of non-public information about UPAR’s portfolio strategy. It is important to note that as EVOKE’s affiliate RPAR, LLC is the sponsor of UPAR, EVOKE receives a portion of the fees collected, and therefore, is incentivized to market UPAR to EVOKE clients and prospective investors. This inherently creates a conflict of interest that both EVOKE clients and prospective investors should carefully consider when deciding whether to invest in UPAR. To the extent that EVOKE invests advisory client assets in UPAR, EVOKE or its related persons may charge management fees both at the UPAR level and client account level; however, we or our related persons may also waive management fees (or certain portions thereof) on client assets invested in UPAR, credit or rebate a client account for the fees paid by UPAR to us or our related persons, or otherwise avoid or limit the payment of duplicative fees to us and our related persons. 

Client-Tailored Advisory Services 

Financial counsel and investment advice is customized and tailored to the unique goals, objectives, and needs of each client. The planning process begins with an in-depth discovery of the client’s goals, objectives, and attitudes toward risk and reward. The goals and objectives for each client are documented in writing and approved by the client. The stated goals and objectives for each client are reflected in the client’s overall recommended financial and investment program and advice that we provide on an ongoing basis. 

Donor Advised Fund Services 

Certain EVOKE clients will establish donor advised funds through various third-party charitable programs, including the Fidelity Charitable Gift Fund Program and the Schwab Charitable Fund (each, a “Charitable Platform”), in which funds will be managed in accordance with the specific investment policies and guidelines of the applicable the Charitable Platform. Clients will establish a donor advised account, transfer funds earmarked for charitable donation and recognize a tax deduction in the year that funds are transferred into an account opened on a Charitable Platform. The funds remain in such account until the client designates a charity, an amount, and a date to donate to such charity. Under independent advisor programs established within each Charitable Platform, donors nominate an independent investment adviser, including EVOKE, to manage accounts established on the Charitable Platforms. If nominated, EVOKE will manage the donor's account pursuant to investment guidelines established by each Charitable Platform.

Tax Compliance, Planning, Preparation and Consulting 

To the extent specifically requested by a client, we provide coordinated tax compliance, planning, preparation, and consulting services (collectively referred to as “tax services”) to investment advisory clients as an integrated part of our investment advisory services. We also provide tax services on a stand[1]alone basis, pursuant to a separate tax engagement agreement, to individuals, businesses, and family offices. The Firm’s tax planning practice includes employees who are certified public accountants (CPAs) with backgrounds in complex tax matters as well as enrolled agents (EAs), who are federally authorized tax practitioners with technical expertise in the field of taxation and are qualified to represent taxpayers before all administrative levels of the Internal Revenue Service for audits, collections, and appeals. 

Although the Firm is a registered investment adviser under the Investment Advisers Act of 1940 (“Advisers Act”), the Firm is not serving in a fiduciary capacity in its provision of stand-alone tax services and will not provide ongoing investment advisory services with respect to stand-alone tax clients’ assets or accounts. For clients who receive tax services on a stand-alone basis, we may recommend the Firm be retained as their investment adviser pursuant to a separate investment advisory agreement; however, such clients are under no obligation to do so. The Firm may also recommend the services of other, nonaffiliated professionals to provide tax services. Our clients are under no obligation to engage the services of any such recommended professional. It is solely up to our clients as to whether they accept or reject any recommendation made by the Firm. 

Please Note: Our clients agree that, if any dispute arises between our client and any other professional recommended by the Firm, they will seek recourse exclusively from and against the engaged qualified professional. 

Please Note: While certain investment adviser representatives of the Firm are licensed CPAs or EAs, they are not responsible for providing tax services unless the client’s Agreement with the Firm specifically sets forth that such tax services will be provided. The Firm typically charges an additional or separate fee for tax services. 

Material Conflicts of Interest: Tax compliance, planning, preparation, and consulting service recommendations as described herein may pose a conflict between the interests of the Firm and the interests of clients. For example, a recommendation by Firm personnel to engage the Firm for these services poses a conflict, as it would increase the total fees paid to the Firm. Clients are not obligated to implement any recommendations made by the Firm or maintain an ongoing tax services relationship with the Firm. 

Administrative Services 

As an accommodation, EVOKE may provide administrative services to certain of its clients ranging from client reporting, asset allocation, back-office functions, and consolidated reporting on client non-advisory assets (“Administrative Services”). Non-advisory assets are assets independently owned by clients and not included as assets under management by EVOKE. These non-advisory assets will not be subject to EVOKE’s portfolio diversification review and no investment advice will be provided with respect to such non-advisory assets. EVOKE will report the value of each non-advisory asset to the client, based solely on the valuations received by EVOKE from the third-party managers of the non-advisory assets, the clients themselves, or other third parties, but EVOKE will not have any obligation to independently examine, confirm, or review non-advisory asset valuations. These Administrative Services are in addition to other advisory services and are offered and may be performed at an additional charge. 

IRA Rollover Recommendations 

Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to clients and prospective clients. 

When we provide investment advice regarding a client’s or prospect’s retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with a client’s interests, so we operate under a special rule that requires us to act in a client’s best interest and not put our interest ahead of our clients. Under this special rule’s provisions, we must: 

-Meet a professional standard of care when making investment recommendations (give prudent advice). 

-Never put our financial interests ahead of yours when making recommendations (give loyal advice). 

-Avoid misleading statements about conflicts of interest, fees, and investments. 

-Follow policies and procedures designed to ensure that we give advice that is in your best interest. 

-Charge no more than is reasonable for our services. 

-Give you basic information about conflicts of interest. 

We benefit financially from the rollover of a client’s assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. A conflict of interest exists if EVOKE recommends a rollover of retirement accounts, as such a recommendation may increase advisory fees paid to EVOKE. While EVOKE may educate clients as to investment options available to them in rolling over their assets, EVOKE has adopted a policy of not recommending such rollovers and clients are advised to carefully review their options before choosing to roll over their retirement assets to EVOKE’s management. As a fiduciary, we only recommend a rollover on an exception basis when we believe it is in a client’s best interest. 

Assets Under Management 

As of December 31, 2024, EVOKE manages approximately $12,453,071,296in assets on a discretionary basis and $15,242,414,286 on a non-discretionary basis.