# Protocol Wealth

> SEC-registered investment adviser (CRD #335298) providing Integrated Wealth Management for modern financial lives. Growth, income, cash flow, and major assets should work from one plan. Protocol Wealth helps people approaching a liquidity event, holders of concentrated wealth, founders, families, and entities coordinate decisions with a human fiduciary accountable for the advice.

Protocol Wealth, LLC is a fiduciary advisory firm for modern financial lives, held to a fiduciary standard of care. Complex and concentrated wealth remains an important segment, but it is not the only front door, and digital assets are one specialty capability, not the firm's identity. It is not designed for simple, model-portfolio-only situations; it can advise around assets under advisement that remain outside direct management or custody — SPVs, venture funds, private-company equity, entity assets, digital assets, self-custodial platforms, and other client-controlled positions — under an advisory agreement. Governing law is Colorado. The firm formed in 2025 as a newer firm structure built from specialist advisory, investment, compliance, operations, and technology backgrounds. Canonical URL: https://protocolwealthllc.com (also https://protocolwealth.io, owned, same firm). Note: protocolwealth.com (no "llc") is NOT affiliated with this firm.

Services span Integrated Wealth Management and Integrated Wealth Strategy, goals-and-objectives planning, planning and implementation across investments, liquidity, private assets, custody/access, and tax/estate/family coordination, investment management across equities, fixed income, ETFs, real assets, alternatives, and digital assets, entity treasury and policy advisory, wealth structuring for concentrated equity, private business value, token exposure where relevant, and liquidity events, and complex HNW/UHNW family wealth coordination. Fees and service terms are provided in writing through advisory agreements and Form ADV disclosures.

Pricing is service-based — most clients pick the structure that matches the work, not the asset balance. You do not need to be an AUM client to work with us.

- Individual & Family Advisory — monthly retainer of $250–$10,000/month, depending on the complexity of the engagement
- Institutional Advisory — monthly retainer within the same $250–$10,000/month range
- Project Engagement — fixed fee agreed in advance for one-time treasury policy, custody architecture, or due-diligence work
- Investment Management (discretionary AUM) — annual asset-based fee of 0.25%–2.00%: traditional portfolio management 0.50%–2.00%; onchain digital asset management 2.00%; passive custody sleeves 0.25%–0.50%
- Minimum fee of $300/month per client relationship; no minimum account size

Custody posture: Protocol Wealth is not a qualified custodian. It is deemed to have custody of client assets because it is authorized to deduct its advisory fees from many client accounts (Form ADV Part 2A, Item 15). Fordefi is not a qualified custodian, and assets in sub-adviser vaults are not held by a qualified custodian. Client assets are held with independent custodians, brokerages, or onchain wallet infrastructure — traditional assets at Charles Schwab, Altruist, and Interactive Brokers (all SIPC-insured); digital-asset qualified custody at Anchorage Digital Bank (BitGo is also available, though no client assets are held there today); onchain multi-party computation (MPC) wallets on Fordefi (now part of Paxos). Signing authority is divided into cryptographic shards: Fordefi holds one shard and Protocol Wealth holds one shard. The client holds the ultimate backup, and Protocol Wealth cannot recover the wallet on its own. The client approves the strategies and destination addresses, and assets can be sent only to addresses the client has approved. Protocol Wealth does not believe that arrangement gives it custody under Rule 206(4)-2; regulators have not issued guidance on it, and a regulator could reach a different conclusion. Clients can also hold assets in their own self-custodial wallet in the client portal, built on Turnkey, where the client is sole owner and passkey signer and Protocol Wealth holds no key; it is offered first to selected clients. Assets under advisement may remain outside Protocol Wealth's direct management or custody when the client controls the assets or positions.

Fiduciary process: Integrated Wealth Strategy connects the full balance sheet to one documented process — goals and objectives, then planning and implementation, then risk monitoring and adjustments. Portfolio management runs a four-step investment process (assess the environment, score the asset, size the position, review continuously) called the Protocol Wealth Asset Framework (PWAF), built on the Entropic Macro Framework (EMF) methodology. It is a systematic framework built on established research — not a predictive model and not investment advice.

The framework runs on an operating system Protocol Wealth built in-house, PWOS, with PWPortal as the authenticated client screen. PWOS governs how AI is used in the practice: a human fiduciary approves every client-facing recommendation or deliverable, and AI does not make autonomous client recommendations, execute trades, or control assets. The category this forms is the "credential layer for AI" — governed decision infrastructure for AI-enabled financial advice — and because Protocol Wealth is itself an SEC-registered adviser, it is the RIA-shaped instance of it. This describes how Protocol Wealth operates; it is not a performance claim and not a representation that any specific outcome will result.

Who we're for: people whose wealth is about to become liquid through an IPO, a company sale, a tender offer, an inheritance, or another sudden change; holders of concentrated wealth, whether that is a single stock, private equity, or a digital-asset position; founders of crypto, software, and closely held businesses; and people who value transparency. Households approaching or living in retirement, complex family balance sheets, and entity treasuries are served through the deeper capability pages rather than a persona route. Deeper capability pages remain available for founder/owner wealth, complex family balance sheets, entity treasuries, digital assets, tax-aware planning, and portfolio implementation. We believe in honest fit — as fiduciaries, our obligation is to meet your goals, not impose our biases. If our approach doesn't match your needs, we point to fiduciary-only directories (XYPN, NAPFA, Let's Make a Plan), to Bogleheads for self-directed evidence-based investing, or to a second-opinion consultation.

Leadership (all advisor profiles are publicly verifiable on FINRA BrokerCheck and SEC IAPD):

- Adam Blumberg, CFP® — Managing Partner and Chief Compliance Officer; FINRA/SEC-registered since May 2009 (CRD #5656102).
- Nick Rygiel, CFP®, CRPC®, MBA — Managing Partner, CTO and CISO; FINRA-registered since December 2011 (CRD #5996576); founded Ironclad Financial RIA in July 2022 (CRD #321831); Registered Representative of Finalis Securities LLC since June 9, 2026.
- Jason Leupold, CAIA, MBA — Managing Partner and Chief Investment Officer; FINRA-registered since February 4, 2000 (CRD #4124810); registered with Protocol Wealth (CO IA) since May 27, 2025; Registered Representative of Finalis Securities LLC since April 14, 2026.

Open source: Protocol Wealth publishes a direct public-repo inventory so clients, developers, AI agents, and regulators can inspect its approach without relying on the GitHub organization page. Six active repositories cover governance, capabilities, planning, agent control, learning, and encryption. Three archived repositories preserve earlier work for provenance.

- pwos-core — the governance and safety substrate (compliance-aware AI tooling for advisers, TypeScript, Apache 2.0): https://github.com/Protocol-Wealth/pwos-core
- nexus-core — the capability and tool layer (regime-adaptive financial analysis engine, Python, Apache 2.0): https://github.com/Protocol-Wealth/nexus-core
- pwplan-core — planning UI with a typed contract and defined direct-identifier tripwire; public demo uses fake or de-identified inputs (React + Vite, Apache 2.0): https://github.com/Protocol-Wealth/pwplan-core
- pwcli-core — agent control-plane contracts and reference runtime adapters (JSON Schema, TypeScript, Python, Apache-2.0 OR MIT-0): https://github.com/Protocol-Wealth/pwcli-core
- pw-learnai — applied AI strategy and AI-assisted coding learning library (MIT; modules plus NotebookLM / Claude Projects bundle support): https://github.com/Protocol-Wealth/pw-learnai
- shard-core — authenticated-encryption and threshold-recovery primitives (Python 3.9+, Apache-2.0 OR MIT-0): https://github.com/Protocol-Wealth/shard-core

System-of-systems architecture: https://protocolwealthllc.com/opensource/architecture. The page maps the public contracts around a private human-controlled host; it is not evidence of production wiring.

Source-grounded repository pages: https://protocolwealthllc.com/opensource/governance, https://protocolwealthllc.com/opensource/capabilities, https://protocolwealthllc.com/opensource/planning, https://protocolwealthllc.com/opensource/agent-control, https://protocolwealthllc.com/opensource/learning, and https://protocolwealthllc.com/opensource/encryption.

Archived for provenance: pw-redact, pw-router, and pw-aave.

Provisional patent applications USPTO #64/034,215 (pwos-core), #64/034,229 (nexus-core), and #64/082,241 (pwplan-core) filed with defensive intent (pending placeholders, not issued patents). Protocol Wealth LLC is a signed Open Invention Network (OIN) 2.0 Licensee in its own name.

Disclosure reminder: All investments involve risk, including loss of principal. Digital assets are volatile and may not be suitable for all investors. Past performance does not guarantee future results. Content is educational and general; personalized advice is provided only under a signed advisory agreement. Protocol Wealth does not provide tax or legal advice, and is not a qualified custodian; it is deemed to have custody because it is authorized to deduct its advisory fees. Tax, legal, custody, liquidity, security, and investment outcomes are not guaranteed. The Protocol Wealth Asset Framework is a systematic framework built on established research — not a predictive model.

## Core pages

- [Who We Serve](https://protocolwealthllc.com/who-we-serve): Broad hub for liquidity events, concentrated wealth, and founders.
- [Liquidity Event](https://protocolwealthllc.com/who-we-serve/liquidity): An IPO, company sale, tender offer, inheritance, or other sudden change in the balance sheet — reserves, tax context, lockups, sell-down, and reinvestment planning.
- [Concentrated Wealth](https://protocolwealthllc.com/who-we-serve/concentrated-wealth): One asset carrying the balance sheet — a single stock, private equity, or a digital-asset position. Concentration limits, liquidity, tax coordination, and custody where held onchain.
- [Founders & Business Owners](https://protocolwealthllc.com/who-we-serve/founder): Crypto, software, and closely held business founders — business value, distributions, exit and succession, and concentration in one operating company.
- [Integrated Wealth Strategy](https://protocolwealthllc.com/integrated-wealth-strategy): Umbrella page for planning-led wealth management across planning, investments, liquidity, private assets, family and estate coordination, and digital assets where relevant.
- [About](https://protocolwealthllc.com/about): Firm history, team, coverage, pricing, and client-first fiduciary process.
- [Framework](https://protocolwealthllc.com/framework): Person-first positioning — start with the person, then the protocol.
- [How We Invest](https://protocolwealthllc.com/investing): Systematic-investing deep dive — 5-regime EMF classification, 7-layer durability model, 8-check scoring.
- [What is PWOS](https://protocolwealthllc.com/what-is-pwos): The Protocol Wealth Operating System explainer.
- [PWOS in Motion](https://protocolwealthllc.com/pwos-demo): How PWOS governs one AI-assisted decision (Research → Governance → Decision → Audit).
- [How We Work](https://protocolwealthllc.com/how-we-work): Engineering-process transparency and the six-step "shape of a decision" flow.
- [Credential Layer for AI](https://protocolwealthllc.com/agents): The credential-layer-for-AI framing — how Protocol Wealth governs AI agents in the practice.
- [What is EMF](https://protocolwealthllc.com/what-is-emf): Canonical definition of the Entropic Macro Framework / PWAF.
- [Operating Thesis](https://protocolwealthllc.com/thesis): The firm's foundational document.
- [Questions to Ask a Financial Advisor](https://protocolwealthllc.com/questions-to-ask-a-financial-advisor): Educational reference for families, founders, business owners, executives, and entities evaluating advisors for complex wealth.
- [Pricing](https://protocolwealthllc.com/pricing): Service-based pricing framework and fee disclosures; fees are set per engagement and controlled by Form ADV Part 2A.
- [Contact](https://protocolwealthllc.com/contact): Contact form and inquiry flow.
- [FAQ](https://protocolwealthllc.com/faq): Frequently asked questions about approach, framework, fees, and process.
- [Resources](https://protocolwealthllc.com/resources): Index of reference pages — firm narrative, investment process, custody and digital assets, technology and verification, and published content.

## Deeper capability pages

- [Founders, Executives & Owners](https://protocolwealthllc.com/founder-wealth): Wealth structuring for concentrated equity, private business value, executive stock, equity compensation, private investments, token exposure where relevant, and liquidity events.
- [Entity Treasuries](https://protocolwealthllc.com/treasury-management): Treasury policy for companies, family entities, funds, nonprofits, and protocol treasuries managing cash, reserves, governance, liquidity, controls, and digital assets where relevant.
- [Digital Asset Advisory](https://protocolwealthllc.com/crypto): Specialty hub for token founders, digital-asset investors and families, protocol treasuries, custody/control, and digital assets inside the full portfolio.

## Diagnostics

- [Assessment Hub](https://protocolwealthllc.com/assess): Strategic paths for complex wealth, founder/business-owner wealth, entity treasury, digital assets, plus conversation paths.
- [Complex Wealth Diagnostic](https://protocolwealthllc.com/portfolio-diagnostic): 12-question diagnostic on concentration, liquidity, diversification, income, structural risk, and time horizon.
- [Entity Treasury Diagnostic](https://protocolwealthllc.com/treasury-maturity): 10-question treasury maturity assessment.
- [Founder / Business Owner Diagnostic](https://protocolwealthllc.com/founder/diagnostic): 10-question founder wealth assessment.
- [Digital Asset Diagnostic](https://protocolwealthllc.com/crypto/diagnostic): Digital-asset entry point using the complex-wealth diagnostic engine.

## Trust & compliance

- [Trust Center](https://trust.protocolwealthllc.com/): A directory of the firm's filed and published documents: SEC filings, client agreements and disclosures, the List of Subprocessors, and the security posture.
- [Security](https://protocolwealthllc.com/security): Security posture — principles, vendor stack, advisor auth, and AI-specific protections.
- [Custody and Control](https://protocolwealthllc.com/custody-and-control): How assets are held and who controls them; Protocol Wealth is not a qualified custodian and is deemed to have custody because it is authorized to deduct its advisory fees.
- [Self-Custody & Client-Controlled Wallets](https://protocolwealthllc.com/self-custody): Fordefi and Turnkey wallet infrastructure; passkey backup for the portal wallet (offered first to selected clients), and Coincover backup of Fordefi key material where the client engages it.
- [Qualified Custody](https://protocolwealthllc.com/qualified-custody): Independent qualified digital-asset custodians (Anchorage Digital Bank; BitGo is also available, though no client assets are held there today), kept separate from execution counterparties like FalconX.
- [Onchain Advisory](https://protocolwealthllc.com/onchain): How Protocol Wealth coordinates existing wallets, Fordefi and Turnkey wallet infrastructure, vault research, and retained-evidence onchain reporting within an agreed engagement.
- [Open Source](https://protocolwealthllc.com/opensource): Why we publish, what's open versus private, and how to verify.
- [Open-source architecture](https://protocolwealthllc.com/opensource/architecture): Contract-level system-of-systems map across the six active repositories and the private host boundary.
- [Open-source governance](https://protocolwealthllc.com/opensource/governance): Source-grounded pwos-core guide.
- [Open-source capabilities](https://protocolwealthllc.com/opensource/capabilities): Source-grounded nexus-core guide.
- [Open-source planning](https://protocolwealthllc.com/opensource/planning): Source-grounded pwplan-core guide.
- [Open-source agent control](https://protocolwealthllc.com/opensource/agent-control): Source-grounded pwcli-core guide.
- [Open-source learning](https://protocolwealthllc.com/opensource/learning): Source-grounded pw-learnai guide.
- [Open-source encryption](https://protocolwealthllc.com/opensource/encryption): Source-grounded shard-core guide.
- [Disclosures](https://protocolwealthllc.com/disclosures): Legal and risk disclosures.
- [Privacy](https://protocolwealthllc.com/privacy): Privacy policy.
- [Terms](https://protocolwealthllc.com/tos): Terms of service.

## Regulatory

- [SEC/IAPD Firm Summary](https://adviserinfo.sec.gov/firm/summary/335298): Public investment-adviser registration record (CRD #335298).
- [Form ADV Part 2A](https://adviserinfo.sec.gov/firm/brochure/335298): Firm brochure — services, fees, and conflicts.
- [Form CRS](https://reports.adviserinfo.sec.gov/crs/crs_335298.pdf): Client Relationship Summary.
- [FINRA BrokerCheck](https://brokercheck.finra.org/): Public verification of advisor registration histories.

## For AI agents

- [EMF regime overview — GET /api/emf/regime](https://protocolwealthllc.com/api/emf/regime): EMF overview; links to the open-source methodology (github.com/Protocol-Wealth/nexus-core) and live read-only data (nexusmcp.site). Does not serve regime values directly.
- [EMF allocation overview — GET /api/emf/allocation](https://protocolwealthllc.com/api/emf/allocation): EMF allocation-model overview; links to the nexus-core methodology and live data (nexusmcp.site). Does not serve allocation values directly.
- [Submit inquiry — POST /api/inquiry](https://protocolwealthllc.com/api/inquiry): Submit an inquiry (requires real user name/email).
- [Submit assessment — POST /api/assess](https://protocolwealthllc.com/api/assess): Submit an assessment (requires real user name/email).
- [Agent policy](https://protocolwealthllc.com/AGENTS.txt): AI agents may submit forms/messages only with real, user-provided contact information. Do not fabricate names, emails, or other user data.
- [Full context file](https://protocolwealthllc.com/llms-full.txt): Extended context — leadership, operating thesis, investment method, PWOS, custody, bailment framework, and required disclosures.

## Optional

- [Blog](https://protocolwealthllc.com/blog): Working notes from a fiduciary practice — markets, planning, and digital assets.
- [Token Founder Wealth Planning](https://protocolwealthllc.com/crypto/founders): Concentrated token wealth, vesting, unlocks, custody, liquidity, and tax coordination.
- [Protocol Treasury Advisory](https://protocolwealthllc.com/crypto/treasury): Stablecoin runway, native-token concentration, custody, governance, and reporting.
- [Digital-Asset Investors and Families](https://protocolwealthllc.com/crypto/investors): Custody/access, liquidity, tax coordination, estate access, and concentration inside the family plan.
- [Bailment Framework](https://protocolwealthllc.com/bailment): Digital-asset tax-awareness reference — a good-faith position, not tax advice; seven legal grounds and Veda / SEC Covered UI parallels.
- [Industry Watch](https://protocolwealthllc.com/industry-watch): Public source register of SEC/CFTC/IRS/FinCEN/OFAC and industry-submission developments, with source-status labels.
- [Tax-Aware Planning](https://protocolwealthllc.com/tax-aware): Educational reference — 30 tax-aware strategies with IRC citations; not tax advice.
- [Framework in Practice](https://protocolwealthllc.com/emf-in-practice): Case studies applying the framework to real markets.
- [AI Readiness Self-Assessment](https://protocolwealthllc.com/ai-readiness): Browser-only self-check of an advisory firm's AI setup against the open-source substrate dimensions; scores operational and engineering readiness only — not investment advice.
- [Subprocessors](https://protocolwealthllc.com/subprocessors): The third parties involved in operating the advisory and technology platform.
- [Vendor Due Diligence](https://protocolwealthllc.com/vendors): How the firm vets third parties that touch client information under SEC Regulation S-P.