EWM is an investment adviser providing financial planning and investment management
services. Prior to engaging EWM to provide any of the foregoing investment advisory services,
the client is required to enter into one or more written agreements with EWM setting forth the
terms and conditions under which EWM renders its services (collectively the “Agreement”).
Neither EWM nor the client may assign the Agreement without the consent of the other party.
A transaction that does not result in a change of actual control or management of EWM is not
considered an assignment.
EWM, a limited liability company organized under the laws of the State of North Carolina, is a
registered investment adviser primarily based in Southern Shores, NC. We became registered
with the Securi�es and Exchange Commission (the “SEC”) on April 29, 2022, as a registered
investment adviser and are principally owned by Steward Partners Management Holdings, LLC
(“SPMH”).
As of December 31, 2023, EWM had approximately $134,975,700 in assets under management,
all of which was managed on a discretionary basis.
This disclosure brochure describes the business of EWM. Certain sections will also describe the
activities of Supervised Persons. Supervised Persons are any of EWM’s officers, partners,
directors (or other persons occupying a similar status or performing similar functions), or
employees, or any other person who provides investment advice on EWM’s behalf and is
subject to EWM’s supervision or control.
Financial Planning and Investment Consulting Services
Financial Planning Services. EWM may be engaged to provide clients with a broad range of
comprehensive financial planning services, which may include drafting a formal financial plan
and/or advising on various financial matters.
Investment Consulting Services. EWM may also be engaged to consult and advise on outside
investments and securities holdings, such as those held in client-directed accounts and
accounts managed by other financial professionals. In instances where EWM has been engaged
by the sponsor of a qualified retirement plan, EWM may provide advisory and consultative
services related to plan design, strategy, fee analysis and participant education, amongst other
such functions.
The above-described services are generally rendered pursuant to specialized engagements
individually tailored to accommodate the needs of a particular client. In certain circumstances,
EWM may agree to provide a combination of both financial planning and investment consulting
services, as memorialized in the Agreement. These services may address a variety of topics
including, but not limited to asset allocation, cash flow analysis, retirement planning,
educational planning, estate planning, insurance planning, legacy planning and charitable
giving, amongst others.
In performing its services, EWM is not required to verify any information received from the
client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly
authorized to rely on such information. EWM may recommend the services of itself and/or
other professionals to implement its recommendations. Clients are advised that a conflict of
interest exists if EWM recommends its own services. The client is under no obligation to act
upon any of the recommendations made by EWM under a financial planning or consulting
engagement or to engage the services of any such recommended professional, including EWM
itself. The client retains absolute discretion over all such implementation decisions and is free
to accept or reject any of EWM’s recommendations. Clients are advised that it remains their
responsibility to promptly notify EWM if there is ever any change in their financial situation or
investment objectives for the purpose of reviewing, evaluating, or revising EWM’s previous
recommendations and/or services.
Investment Management Services
Clients can engage EWM to manage all or a portion of their assets on a discretionary or non-
discretionary basis. EWM primarily allocates clients’ investment management assets on a
discretionary and/or a non- discretionary basis among Independent Managers (as defined
below), mutual funds, as well as the securities components of variable annuities and variable
life insurance contracts in accordance with the investment objectives of the client. EWM also
provides advice
about any type of investment held in clients' portfolios.
EWM also may render non-discretionary investment management services to clients relative to
variable life/annuity products that they may own and/or their individual employer-sponsored
retirement plans, or other products that may not be held by the client’s primary custodian. In
so doing, EWM either directs or recommends the allocation of client assets among the various
investment options that are available with the product. Client assets are maintained at the
specific insurance company or custodian designated by the product.
EWM tailors its advisory services to the individual needs of clients. EWM ensures that clients’
investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients
are advised to promptly notify EWM if there are changes in their financial situation or
investment objectives or if they wish to impose any reasonable restrictions upon EWM’s
management services.
Use of Independent Managers
As mentioned above, EWM recommends that certain clients authorize the active discretionary
management of a portion of their assets by and/or among certain independent investment
managers (“Independent Managers”), based upon the stated investment objectives of the
client. The terms and conditions under which the client engages the Independent Managers are
set forth in a separate written agreement between EWM or the client and the designated
Independent Managers. EWM renders services to the client relative to the discretionary
selection of Independent Managers. EWM also monitors and reviews the account performance
and the client’s investment objectives. EWM receives an annual advisory fee which is based
upon a percentage of the market value of the assets being managed by the designated
Independent Managers.
When selecting an Independent Manager for a client, EWM reviews information about the
Independent Manager such as its disclosure statement and/or material supplied by the
Independent Manager or independent third parties for a description of the Independent
Manager’s investment strategies, past performance and risk results to the extent available.
Factors that EWM considers in recommending an Independent Manager include the client’s
stated investment objectives, management style, performance, reputation, financial strength,
reporting, pricing, and research. The investment management fees charged by the designated
Independent 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, EWM’s
investment advisory fee set forth above. As discussed above, the client may incur additional
fees than those charged by EWM, the designated Independent Managers, and corresponding
broker-dealer and custodian.
In addition to EWM’s written disclosure statement, the client also receives the written
disclosure statement of the designated Independent Managers. Certain Independent Managers
may impose more restrictive account requirements and varying billing practices than EWM. In
such instances, EWM may alter its corresponding account requirements and/or billing practices
to accommodate those of the Independent Managers.
If EWM refers a client to an Independent Manager where EWM’s compensation is included in
the advisory fee charged by such Independent Manager and the client engages the Independent
Manager, EWM shall be compensated for its services by receipt of a fee to be paid directly by
the Independent Manager to EWM in accordance with the requirements of Rule 206(4)-3 of the
Investment Advisers Act of 1940, as amended, and any corresponding state securities laws,
rules, regulations, or requirements. Any such fee is paid solely from the Independent Manager’s
investment management fee and does not result in any additional charge to the client.
Additions and Withdrawals to Accounts
Clients may make additions to and withdrawals from their account at any time, subject to
EWM’s right to terminate an account. Clients may withdraw account assets on notice to EWM,
subject to the usual and customary securities settlement procedures. However, EWM designs
its portfolios as long-term investments, and the withdrawal of assets may impair the
achievement of a client’s investment objectives.