A. General Description of Advisory Firm
Stewart Wealth Management, Inc. (“SWM,” the “firm” or “we”) is an SEC-registered investment
adviser with its principal place of business located in California. SWM’s registration was
effective March 20, 2007. The firm’s principal shareholder (i.e., those individuals and/or entities
controlling 25% or more of this company) is Benjamin Stewart, Chief Executive Officer and
Chief Compliance Officer.
B. Description of Advisory Services (including any specializations)
We provide financial planning and investment advisory services to individual clients, as well as
trusts, endowments, qualified retirement plan sponsors, and business entities.
INVESTMENT ADVISORY SERVICES
Regular and continuous advice is provided through consultation with you and may include the
following: determination of financial objectives, identification of financial problems, cash flow
management, tax planning, insurance review, investment management, education funding,
retirement planning and estate planning.
We manage securities accounts on your behalf on either a discretionary or non-discretionary
basis. When we have the authority to determine, without obtaining your specific consent, the
securities to be bought or sold, this is discretionary authority. We do not act as a custodian of
your assets. You always maintain asset control. We place trades for you under a limited power of
attorney. For non-discretionary accounts, we will obtain your approval prior to execution of any
trades.
We provide investment supervisory services, also known as asset management services; manage
investment advisory accounts not involving investment supervisory services; and, furnish
investment advice through consultations.
We generally recommend institutional-class stock mutual funds with low annual expense ratios
and low internal transaction costs. At times we may recommend other low cost investment
solutions, such as ETFs, low cost bond funds, individual fixed income securities, and other
products. For more on our investment philosophies, and the risks of our strategies and/or specific
investments recommended, please refer to Item 8.
Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds,
usually through discount brokers or fund companies. Fund companies charge each fund
shareholder an investment management fee that is disclosed in the fund prospectus. Discount
brokerages may charge a transaction fee for the purchase of some funds.
Stocks and bonds may be purchased or sold through a brokerage account when appropriate.
The brokerage firm charges a fee for stock and bond trades. We do not receive any
compensation, in any form, from fund companies.
Investments may also include the following: equities (stocks), warrants, corporate debt securities,
commercial paper, certificates of deposit, municipal securities, investment company securities
(variable life insurance, and mutual funds shares), U. S. government securities, options contracts,
futures contracts, interests in partnerships, and alternative investments when suitable for clients.
We do not invest in Initial public offerings (IPOs).
As noted above, we may recommend unaffiliated, third-party alternative investments when
suitable and based on the client’s investment objectives. Such alternatives include, but are not
limited to, liquid alternatives such as business development companies and exchange-traded
REITS and illiquid alternatives, including, but not limited to, real estate private placements or
limited partnership. These investments are recommended and offered to clients who meet the
definition of an accredited investor as defined in Regulation D of the Securities Act of 1933.
Clients are under no obligation to make an investment in any alternative investment. Please see
Item 8 (Material Risks of Methods of Analysis and Investment Strategies) of this Brochure for
information regarding risks
FINANCIAL PLANNING
Investment advice is an integral part of financial planning. In addition, we advise you regarding
cash flow, college planning, retirement planning, tax planning and estate planning. On more than
an occasional basis, we furnish advice to you on matters not involving securities, such as
financial planning matters, taxation issues, and trust services that often include estate planning.
PENSION CONSULTING SERVICES
We also provide several advisory services separately or in combination. While the primary
clients for these services will be pension, profit sharing and 401(k) plans, we offer these services,
where appropriate, to individuals and trusts, estates and charitable organizations. Pension
Consulting Services are comprised of four distinct services. Clients may choose to use any or all
of these services.
Investment Policy Statement Preparation (hereinafter referred to as ''IPS''):
We will meet with the client (in person or over the telephone) to determine an appropriate
investment strategy that reflects the plan sponsor's stated investment objectives for management
of the overall plan. Our firm then prepares a written IPS detailing those needs and goals,
including an encompassing policy under which these goals are to be achieved. The IPS also lists
the criteria for selection of investment vehicles as well as the procedures and timing interval
for
monitoring of investment performance.
Selection of Investment Vehicles:
We assist plan sponsors in constructing appropriate asset allocation models. We will then review
various mutual funds (both index and managed) to determine which investments are appropriate
to implement the client's IPS. The number of investments to be recommended will be determined
by the client, based on the IPS.
Monitoring of Investment Performance:
We monitor client investments continually, based on the procedures and timing intervals
delineated in the Investment Policy Statement. Although our firm is not involved in any way in
the purchase or sale of these investments, we supervise the client's portfolio and will make
recommendations to the client as market factors and the client's needs dictate.
Employee Communications:
For pension, profit sharing and 401(k) plan clients with individual plan participants exercising
control over assets in their own account (''self-directed plans''), we also provide educational
support and investment workshops designed for the plan participants when the plan sponsor
engages our firm to provide these services. The nature of the topics to be covered will be
determined by us and the client under the guidelines established in ERISA Section 404(c). The
educational support and investment workshops will NOT provide plan participants with
individualized, tailored investment advice or individualized, tailored asset allocation
recommendations.
CONSULTING SERVICES
Clients can also receive investment advice on a more focused basis. This may include advice on
only an isolated area or areas of concern such as estate planning, retirement planning, investment
specific advice or any other specific topic. We also provide specific consultation services
regarding investment and financial concerns of the client.
PRIVATE PLACEMENT CONSULTING
We may provide investment advice and due diligence regarding certain privately-issued
securities for accredited investors as part of a separate consulting agreement for non-investment
advisory clients. This service, may include the following:
• Discovery call with client to assess scope and viability of such transactions;
• Introduce or present clients to the Qualified Intermediary and Investment Sponsors of
such opportunities suitable to your needs;
• Assist clients in assessing and selecting each opportunity presented;
• Coordinate with Qualified Intermediary and Escrow Agent as necessary;
• Compile and prepare the required opportunity documents;
• Submit completed documents executed by you and confirm funding has been received by
the Investment Sponsor; and/or
• Final confirmation with client.
Because investment in these types of entities may involve certain additional degrees of risk, they
will only be recommended when consistent with the client's investment objectives, tolerance for
risk, liquidity and suitability. This service is separate and distinct from other services provided
by us to clients. Specific terms and services to be provided are detailed in your Consulting
Agreement.
OTHER INFORMATION
SWM and its associated persons are neither an attorney, Certified Public Accountant nor a
licensed tax preparer. Clients should consult with their attorney(s) and tax preparer about any
discussions that relate to estate or tax planning before implementing any actions in those areas.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by
you on an as-needed basis. Conflicts of interest will be disclosed to you in the unlikely event
they should occur.
The initial meeting, which may be by telephone, is free of charge and is considered an
exploratory interview to determine the extent to which financial planning and investment
management may be beneficial to the you.
C. Availability of Tailored Services for Individual Clients
In general, our advisory services are tailored to meet your needs. While model portfolios may be
utilized for some where appropriate, most clients’ investment portfolio is individually designed
based on their situation. Additionally, financial planning, estate planning, tax planning, and risk
management planning services are generally delivered upon your engaging us for such services.
As appropriate, you will have a conference with your advisor at least annually to review any
changes to your financial situation, the investment portfolio upon which advice is provided by
us, and planning issues.
After consultation with us, you may impose restrictions on investing in certain securities or types
of securities. This most often occurs when you request certain social investing needs be
addressed, such as through the use of mutual funds which avoid investments in certain
companies. Other restrictions may be imposed by you with respect to the (average or longest)
maturity or credit quality of fixed income investments.
Our Agreement with you may not be assigned without your consent.
D. Wrap Fees
We do not invest in wrap fee programs or manage assets for any wrap fee accounts.
E. Client Assets Under Management
As of December 31, 2023, the Adviser had $438,089,550 of client assets under management. As
of that date, the Adviser managed $377,777,446 on a discretionary basis and $60,312,104 on a
non-discretionary basis.