A. EisnerAmper Wealth Management & Corporate Benefits, LLC is a limited liability
company formed on May 12, 1999 in the state of New Jersey. EisnerAmper Wealth
Management & Corporate Benefits, LLC became registered as an Investment Adviser Firm
in August 2008. EisnerAmper Wealth Management & Corporate Benefits, LLC is solely
owned by EAG Wealth Management Strategies, LLC. Mr. Scudillo is EisnerAmper Wealth
Management & Corporate Benefits, LLC’s President and Chief Compliance Officer.
B.
PLANNING & INVESTMENT MANAGEMENT SERVICES
EisnerAmper Wealth Management & Corporate Benefits, LLC provides discretionary and
non-discretionary investment advisory and planning services on a fee basis. EisnerAmper
Wealth Management & Corporate Benefits, LLC’s annual fee is generally based upon a
percentage (%) of the market value of the assets placed under management. Prior to
engaging EisnerAmper Wealth Management & Corporate Benefits, LLC to provide
investment advisory services, clients are required to enter into an Investment Advisory
Agreement setting forth the terms and conditions of the engagement (including
termination), describing the scope of the services to be provided, and the fee that is due
from the client. EisnerAmper Wealth Management & Corporate Benefits, LLC shall
provide investment management services specific to the needs of each client. Prior to
providing investment management services, an investment adviser representative will
ascertain each client’s investment objective(s). Thereafter, EisnerAmper Wealth
Management & Corporate Benefits, LLC shall allocate investment assets consistent with
the designated investment objective(s).
EisnerAmper Wealth Management & Corporate Benefits, LLC may use a suite of digitally
powered technology solutions offered by FinLife Partners, a division of Goldman Sachs
Personal Financial Management, (“FinLife Partners”). (See FinLife Partners Service
Offering discussion and conflicts disclosure below).
INVESTMENT MANAGEMENT ONLY SERVICES
Clients may also choose to engage EisnerAmper Wealth Management & Corporate
Benefits, LLC to provide investment management services on a stand-alone basis.
EisnerAmper Wealth Management & Corporate Benefits, LLC provides Investment
Management Only Services on a discretionary basis for an annual fee based upon a
percentage (%) of the market value of the assets placed under management.
To the extent a client who has selected this service offering needs planning services, the
client may choose to engage EisnerAmper Wealth Management & Corporate Benefits,
LLC to provide planning services by entering into a separate Financial Planning and
Consulting Services agreement.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
EisnerAmper Wealth Management & Corporate Benefits, LLC may provide financial
planning and/or consulting services (including investment and non-investment related
matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee
basis. Prior to engaging EisnerAmper Wealth Management & Corporate Benefits, LLC to
provide planning or consulting services, clients are generally required to enter into a
Financial Planning and Consulting Agreement with EisnerAmper Wealth Management &
Corporate Benefits, LLC setting forth the terms and conditions of the engagement
(including termination), describing the scope of the services to be provided, and the portion
of the fee that is due from the client prior to EisnerAmper Wealth Management &
Corporate Benefits, LLC commencing services. If requested by the client, EisnerAmper
Wealth Management & Corporate Benefits, LLC may recommend the services of other
professionals for implementation purposes, including EisnerAmper Wealth Management
& Corporate Benefits, LLC’s representatives in their individual capacities as registered
representatives of DAI Securities, LLC (“DAI”) and/or as licensed insurance agents. (See
disclosures at Item 10.C). The client is under no obligation to engage the services of any
such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from
EisnerAmper Wealth Management & Corporate Benefits, LLC.
EisnerAmper Wealth Management & Corporate Benefits, LLC’s Financial Planning
services may be delivered utilizing a suite of digitally powered technology solutions
offered by FinLife Partners. (See FinLife Partners Service Offering discussion and
conflicts disclosure below).
Goldman Sachs Personal Financial Management - Sub-Advisory Relationship
For certain client assets, EisnerAmper Wealth Management & Corporate Benefits, LLC
may outsource a portion of its investment management responsibilities to Goldman Sachs
Personal Financial Management (“Goldman Sachs”), an unaffiliated investment adviser,
who serves as a sub-adviser. Goldman Sachs is granted limited discretionary investment
authority over assets that EisnerAmper Wealth Management & Corporate Benefits, LLC
directs to Goldman Sachs. For the assets directed to Goldman Sachs for services, its
responsibility includes the authority to:
• exercise discretion to determine the types of securities bought and sold, along with the
percentage allocation
• apply its discretion as to when to buy and sell
• apply its discretion as to the timing of transactions
• select the broker-dealer for execution of securities transactions, if appropriate, and
• take other portfolio management actions EisnerAmper Wealth Management &
Corporate Benefits, LLC delegates or deems appropriate
Goldman Sachs sub-advisory authority applies only to the specific assets within the client’s
custodial account, for which Goldman Sachs has been appointed as the sub-adviser.
Goldman Sachs shall not provide investment advice, or have any advisory responsibility to
the client, beyond the assets for which it is appointed as sub-adviser. The terms of services
provided by Goldman Sachs are directed in accordance with a separate written agreement
entered into between EisnerAmper Wealth Management & Corporate Benefits, LLC and
Goldman Sachs. Goldman Sachs also provides separate services to EisnerAmper Wealth
Management & Corporate Benefits, LLC under its division FinLife Partners, as described
below.
FinLife Partners Service Offering
EisnerAmper Wealth Management & Corporate Benefits, LLC may use a suite of digitally
powered technology solutions offered by FinLife Partners, a division of Goldman Sachs
(“FinLife Partners”). FinLife Partners provides EisnerAmper Wealth Management &
Corporate Benefits, LLC with access to a technology platform that includes certain clerical
document and data compilation services. FinLife Partners is not in any way involved in, or
responsible for, the individual investment management or guidance provided to
EisnerAmper Wealth Management & Corporate Benefits, LLC’s clients. EisnerAmper
Wealth Management & Corporate Benefits, LLC pays FinLife Partners a flat fee for its
technology implementation services and fees calculated per percentage-basis formula in
accordance with the volume of clients for whom EisnerAmper Wealth Management &
Corporate Benefits, LLC utilizes such services and/or products. As the percentage-basis
reduces as volume increases, EisnerAmper Wealth Management & Corporate Benefits,
LLC is financially incentivized to refer clients to Goldman Sachs, thereby creating a
conflict of interest.
No client is under any obligation to utilize Goldman Sachs’ sub-advisory services or
FinLife Partners’ technology solutions. If a client does not want to utilize Goldman Sachs
for sub-advisory services or receive EisnerAmper Wealth Management & Corporate
Benefits, LLC’s Financial Guidance Services that require access to the FinLife platform,
the client is under no obligation to do so.
RETIREMENT PLAN SERVICES
EisnerAmper Wealth Management & Corporate Benefits, LLC also provides retirement
plan consulting/management services, pursuant to which it assists sponsors of self-directed
retirement plans organized under the Employee Retirement Security Act of 1974
(“ERISA”). The terms and conditions of the engagement shall be set forth in the agreement
between EisnerAmper Wealth Management & Corporate Benefits, LLC and the plan
sponsor.
To the extent a plan sponsor has engaged EisnerAmper Wealth Management & Corporate
Benefits, LLC in an ERISA Section 3(21) capacity, EisnerAmper Wealth Management &
Corporate Benefits, LLC shall assist with the selection and/or monitoring of investment
options (generally open-end mutual funds and exchange traded funds) from which plan
participants shall choose in self-directing the investments for their individual plan
retirement accounts. If the plan sponsor chooses to engage EisnerAmper Wealth
Management & Corporate Benefits, LLC in an ERISA Section 3(38) capacity,
EisnerAmper Wealth Management & Corporate Benefits, LLC may provide the same
services as described above, but may also: create specific asset allocation models that
EisnerAmper Wealth Management & Corporate Benefits, LLC manages on a discretionary
basis, which plan participants may choose in managing their individual retirement account;
and/or modify the investment options made available to plan participants on a discretionary
basis.
EISNERAMPER AUTOMATED PORTFOLIO STRATEGY
Clients may choose to engage EisnerAmper Wealth Management & Corporate Benefits,
LLC to provide investment management services utilizing the Institutional Intelligent
Portfolios™ Program, relative to investment accounts with market values of at least $5,000
under the EisnerAmper Automated Portfolio Strategy (“EAPS”). Institutional Intelligent
Portfolios™, is an automated, online investment management platform for use by
independent investment advisors offered by software provider Schwab Performance
Technologies (“SPT”). Through EAPS, EisnerAmper Wealth Management & Corporate
Benefits, LLC offers clients a range of investment strategies we have constructed and
manage. The client’s portfolio is held in a brokerage account opened by the client at SPT’s
affiliate, Charles Schwab & Co., Inc. (“CS&Co”). EisnerAmper Wealth Management &
Corporate Benefits, LLC is independent of and not owned by, affiliated with, or sponsored
or supervised by SPT, CS&Co or their affiliates (together, “Schwab”).
EisnerAmper Wealth Management & Corporate Benefits, LLC, and not Schwab, is the
client’s investment advisor and primary point of contact with respect to EAPS.
EisnerAmper Wealth Management & Corporate Benefits, LLC is solely responsible, and
Schwab is not responsible, for determining the appropriateness of EAPS for the client,
choosing a suitable investment strategy and portfolio for the client’s investment needs and
goals, and managing that portfolio on an ongoing basis.
EisnerAmper Wealth Management & Corporate Benefits, LLC has contracted with SPT to
provide us with the technology platform and related trading and account management
services for EAPS. This platform enables us to make EAPS available to clients online and
includes a system that automates certain key parts of our investment process (the
“System”). The System includes an online questionnaire that helps us determine the client’s
investment objectives and risk tolerance and select an appropriate investment strategy and
portfolio. Clients should note that EisnerAmper Wealth Management & Corporate
Benefits, LLC will recommend a portfolio via the System in response to the client’s
answers to the online questionnaire. The client may then indicate an interest in a portfolio
that is one level less or more conservative or aggressive than the recommended portfolio,
but EisnerAmper Wealth Management & Corporate Benefits, LLC then makes the final
decision and selects a portfolio based on all the information EisnerAmper Wealth
Management & Corporate Benefits, LLC has about the client. The System also includes an
automated investment engine through which EisnerAmper Wealth Management &
Corporate Benefits, LLC manages the client’s portfolio on an ongoing basis through
automatic rebalancing and tax-loss harvesting (if the client is eligible and elects).
EisnerAmper Wealth Management & Corporate Benefits, LLC does not receive a portion
of a wrap fee for our services to clients through EAPS. Clients do not pay fees to SPT in
connection with EAPS, but EisnerAmper Wealth Management & Corporate Benefits, LLC
charges clients a fee for our services as described below under Item 5. EisnerAmper Wealth
Management & Corporate Benefits, LLC’s fees are not set or supervised by Schwab.
Clients do not pay brokerage commissions or any other fees to CS&Co as part of EAPS.
Schwab does receive other revenues in connection with EAPS, which are described in the
“Compensation to Schwab Under EAPS” section below.
EisnerAmper Wealth Management & Corporate Benefits, LLC does not pay SPT fees for
the Platform so long as it maintain $100 million in client assets in accounts at CS&Co that
are not enrolled in EAPS. If EisnerAmper Wealth Management & Corporate Benefits, LLC
does not meet this condition, then it must pay SPT an annual licensing fee of 0.10% of the
value of its clients’ assets in EAPS. This arrangement presents a conflict of interest, as it
provides an incentive for EisnerAmper Wealth Management & Corporate Benefits, LLC
to recommend that clients maintain their accounts at CS&Co. Notwithstanding,
EisnerAmper Wealth Management & Corporate Benefits, LLC may generally recommend
to its clients that they maintain investment management accounts at CS&Co. based on the
considerations discussed in Item 12 below, which mitigates but does not eliminate this
conflict of interest.
Clients enrolled in EAPS are limited in the universe of investment options available to
them. For example, the investment options available are limited to ETFs, whereas
EisnerAmper Wealth Management & Corporate Benefits, LLC recommends various other
types of securities in its other services. EAPS is designed to provide guidance and
professional assistance to individuals who are beginning the process of accumulating
wealth. Clients will have access to their accounts and a financial interface online but will
also have the opportunity to confer with EisnerAmper Wealth Management & Corporate
Benefits, LLC with respect to their account.
Rebalancing
The System will rebalance a client’s account periodically by generating instructions to
CS&Co. to buy and sell shares of funds and depositing or withdrawing funds through the
“Sweep Program”, considering the asset allocation for the client’s investment strategy.
Rebalancing trade instructions can be generated by the System when (i) the percentage
allocation of an asset class varies by a set parameter established by EisnerAmper Wealth
Management & Corporate Benefits, LLC, (ii) EisnerAmper Wealth Management &
Corporate Benefits, LLC decides to change asset allocation percentages for an investment
strategy or (iii) EisnerAmper Wealth Management & Corporate Benefits, LLC decides to
change a client’s investment strategy, which could occur, for example, when a client makes
changes to their investment profile or imposes or modifies restrictions on the management
of their account.
Sweep Program
Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held
in a sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation
will be a minimum of 4% of an account’s value to be held in cash, and may be higher,
depending on the investment strategy chosen for a client. The Cash Allocation will be
accomplished through enrollment in the Sweep Program, a program sponsored by CS&Co.
By enrolling in EAPS, clients consent to having the free credit balances in their brokerage
accounts at CS&Co. swept into deposit accounts (“Deposit Accounts”) at Charles Schwab
Bank (“Schwab Bank”) through the Sweep Program. Schwab Bank is an FDIC-insured
depository institution that is a Schwab affiliate. The Sweep Program is a required feature
of EAPS. If the Deposit Account balances exceed the Cash Allocation for a client’s
investment strategy, the excess over the rebalancing parameter will be used to purchase
securities as part of rebalancing. If clients request cash withdrawals from their accounts,
this likely will require the sale of fund positions in their accounts to bring their Cash
Allocation in line with the target allocation for their chosen investment strategy. If those
clients have taxable accounts, those sales may generate capital gains (or losses) for tax
purposes. In accordance with an agreement with CS&Co., Schwab Bank has agreed to pay
an interest rate to depositors participating in the Sweep Program that will be determined by
reference to an index.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, EisnerAmper Wealth
Management & Corporate Benefits, LLC may provide financial planning and related
consulting services. Neither EisnerAmper Wealth Management & Corporate Benefits,
LLC nor its investment adviser representatives assist clients with the implementation of
any financial plan, unless they have agreed to do so in writing. EisnerAmper Wealth
Management & Corporate Benefits, LLC does not monitor a client’s financial plan, and it
is the client’s responsibility to revisit the financial plan with EisnerAmper Wealth
Management & Corporate Benefits, LLC, if desired.
As indicated above, to the extent requested by a client, EisnerAmper Wealth Management
& Corporate Benefits, LLC may provide financial planning and related consulting services
regarding non-investment related matters, such as estate planning, tax planning, insurance
planning, etc.
EisnerAmper Wealth Management & Corporate Benefits, LLC does not serve as an
attorney or accountant, and no portion of its services should be construed as legal or
accounting services. Accordingly, EisnerAmper Wealth Management & Corporate
Benefits, LLC does not prepare estate planning documents or tax returns. To the extent
requested by a client, we may recommend the services of affiliates or other professionals
for certain non-investment implementation purposes (i.e., attorneys, accountants,
insurance, etc.), including EisnerAmper, LLP or representatives of EisnerAmper Wealth
Management & Corporate Benefits, LLC in their separate individual capacities as
representatives of DAI, a FINRA member broker-dealer and as licensed insurance agents.
Clients are under no obligation to engage the services of any such recommended
professional. Clients retain absolute discretion over all such implementation decisions and
are free to accept or reject any recommendation from EisnerAmper Wealth Management
& Corporate Benefits, LLC and/or its representatives.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional[s]
(i.e., attorney, accountant, insurance agent, etc.), and not EisnerAmper Wealth
Management & Corporate Benefits, LLC, shall be responsible for the quality and
competency of the services provided.
Independent Managers. EisnerAmper Wealth Management & Corporate Benefits, LLC
may allocate (and/or recommend that the client allocate) a portion of a client’s investment
assets among unaffiliated independent investment managers in accordance with the client’s
designated investment objective(s). In such situations, the Independent Managers shall
have day-to-day responsibility for the active discretionary management of the allocated
assets. EisnerAmper Wealth Management & Corporate Benefits, LLC shall continue to
render investment supervisory services to the client relative to the ongoing monitoring and
review of account performance, asset allocation and client investment objectives. Factors
which EisnerAmper Wealth Management & Corporate Benefits, LLC shall consider in
recommending Independent Managers include the client’s designated investment
objective(s), management style, performance, reputation, financial strength, reporting,
pricing, and research. The investment management fee charged by the Independent
Manager(s) is separate from, and in addition to, EisnerAmper Wealth Management &
Corporate Benefits, LLC’s advisory fee as set forth in Item 5.
Schwab’s Product Offering used by EisnerAmper Wealth Management & Corporate
Benefits, LLC: EisnerAmper Wealth Management & Corporate Benefits, LLC uses
Schwab for passive investment management. Schwab provides access to third party money
managers (“TPMMs”) who provide taxable and non-taxable exchange traded fund model
portfolios. Generally, once a quarter, EisnerAmper Wealth Management & Corporate
Benefits, LLC shall give instructions to Schwab to rebalance. The system will generate
the buy/sell instructions that become part of the trade report on a daily basis.
SEI’s Product Offering used by EisnerAmper Wealth Management & Corporate
Benefits, LLC: The Managed Account Program (“MAP”) offers access to TPMMs who
provide specific investment styles and/or asset classes. Brokerage fees are absorbed by the
program and clients will get an account statement from each TPMM.
The Integrated Managed Accounts Program (“IMAP”) is a subset of MAP wherein
TPMMs provide asset management services, but trades are directed to a custodial account
established in the clients’ name. Parametric Portfolio Associates coordinates the securities
transactions instructed by the separate TPMMs for SEI. Clients will get one integrated
account statement. EisnerAmper Wealth Management & Corporate Benefits, LLC can
recommend that clients add a tax sensitivity ‘sleeve’ to the program such that securities
trades are evaluated for tax consequences prior to execution.
The Model Mutual Fund Strategies provide access to SEI’s non-loaded mutual funds which
have stated investment objectives and asset classes. EisnerAmper Wealth Management &
Corporate Benefits, LLC may choose, on behalf of its clients, among SEI’s mutual funds
on a discretionary basis.
Financial Planning Technology Platforms. In conjunction with the services provided by
various financial planning technology platforms, EisnerAmper Wealth Management &
Corporate Benefits, LLC may also provide access to account aggregation services, which
can incorporate all of the client’s investment assets,” including those investment assets that
are not part of the assets that we manage (the “Excluded Assets”). The client and/or their
other advisors that maintain trading authority, and not EisnerAmper Wealth Management
& Corporate Benefits, LLC, shall be exclusively responsible for the investment
performance of the Excluded Assets. EisnerAmper Wealth Management & Corporate
Benefits, LLC does not provide investment management, monitoring or implementation
services for the Excluded Assets. If EisnerAmper Wealth Management & Corporate
Benefits, LLC is asked to make a recommendation as to any Excluded Assets, the client is
under absolutely no obligation to accept the recommendation, and EisnerAmper Wealth
Management & Corporate Benefits, LLC shall not be responsible for any implementation
error (timing, trading, etc.) relative to the Excluded Assets. The client may engage
EisnerAmper Wealth Management & Corporate Benefits, LLC to provide investment
management services for the Excluded Assets pursuant to the terms and conditions of the
Investment Advisory Agreement between EisnerAmper Wealth Management & Corporate
Benefits, LLC and the client.
Retirement Rollovers-Conflict of Interest. A client or prospective client leaving an
employer typically has four options regarding an existing retirement plan (and may engage
in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and
rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv)
cash out the account value (which could, depending upon the client’s age, result in adverse
tax consequences). If EisnerAmper Wealth Management & Corporate Benefits, LLC
provides a recommendation as to whether a client should engage in a rollover or not,
EisnerAmper Wealth Management & Corporate Benefits, LLC is acting as an ERISA
fiduciary, within the meaning of Title I of the Employee Retirement Incomes Security Act
or the Internal Revenue Code. Furthermore, if EisnerAmper Wealth Management &
Corporate Benefits, LLC recommends that a client roll over their retirement plan assets
into an account to be managed by EisnerAmper Wealth Management & Corporate Benefits,
LLC, such a recommendation creates a conflict of interest if EisnerAmper Wealth
Management & Corporate Benefits, LLC will earn new (or increase its current)
compensation as a result of the rollover. No client is under any obligation to roll over
retirement plan assets to an account managed by EisnerAmper Wealth Management &
Corporate Benefits, LLC.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded
funds are available directly to the public. Therefore, a prospective client can obtain many
of the funds that may be utilized by EisnerAmper Wealth Management & Corporate
Benefits, LLC independent of engaging EisnerAmper Wealth Management & Corporate
Benefits, LLC as an investment advisor. However, if a prospective client determines to do
so, he/she will not receive EisnerAmper Wealth Management & Corporate Benefits, LLC’s
initial and ongoing investment advisory services.
In addition to EisnerAmper Wealth Management & Corporate Benefits, LLC’s investment
advisory fee described below, and transaction and/or custodial fees discussed below, clients
will also incur, relative to all mutual fund and exchange traded fund purchases, charges
imposed at the fund level (e.g. management fees and other fund expenses).
Socially Responsible Investing Limitations. Socially Responsible Investing involves the
incorporation of Environmental, Social and Governance considerations into the investment
due diligence process (“ESG). There are potential limitations associated with allocating a
portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to
avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil
drilling, gambling, etc.). The number of these securities may be limited when compared to
those that do not maintain such a mandate. ESG securities could underperform broad
market indices. Investors must accept these limitations, including potential for
underperformance. Correspondingly, the number of ESG mutual funds and exchange
traded funds are few when compared to those that do not maintain such a mandate. As with
any type of investment (including any investment and/or investment strategies
recommended and/or undertaken by EisnerAmper Wealth Management & Corporate
Benefits, LLC), there can be no assurance that investment in ESG securities or funds will
be profitable, or prove successful. EisnerAmper Wealth Management & Corporate
Benefits, LLC does not maintain or advocate an ESG investment strategy but will seek to
employ ESG if directed by a client to do so.
Structured Notes. EisnerAmper Wealth Management & Corporate Benefits, LLC may
purchase structured notes for client accounts. A structured note is a financial instrument
that combines two elements, a debt security and exposure to an underlying asset or assets.
It is essentially a note, carrying counter party risk of the issuer. However, the return on the
note is linked to the return of an underlying asset or assets (such as the S&P 500 Index or
commodities). It is this latter feature that makes structured products unique, as the payout
can be used to provide some degree of principal protection, leveraged returns (but usually
with some cap on the maximum return), and be tailored to a specific market or economic
view. In addition, investors may receive long-term capital gains tax treatment if certain
underlying conditions are met and the note is held for more than one year. Finally,
structured notes may also have liquidity constraints, such that the sale thereof before
maturity may be limited.
Portfolio Activity. EisnerAmper Wealth Management & Corporate Benefits, LLC has a
fiduciary duty to provide services consistent with the client’s best interest. As part of its
investment advisory services, EisnerAmper Wealth Management & Corporate Benefits,
LLC will review client portfolios on an ongoing basis to determine if any changes are
necessary based upon various factors, including, but not limited to, investment
performance, fund manager tenure, style drift, account additions/withdrawals, and/or a
change in the client’s investment objective. Based upon these factors, there may be
extended periods of time when EisnerAmper Wealth Management & Corporate Benefits,
LLC determines that changes to a client’s portfolio are neither necessary nor prudent.
Clients nonetheless remain subject to the fees described in Item 5 below during periods of
account inactivity.
Non-Discretionary Service Limitations. Clients that determine to engage EisnerAmper
Wealth Management & Corporate Benefits, LLC on a non-discretionary investment
advisory basis must be willing to accept that EisnerAmper Wealth Management &
Corporate Benefits, LLC cannot affect any account transactions without obtaining prior
consent to any such transaction(s) from the client. Therefore, in the event that EisnerAmper
Wealth Management & Corporate Benefits, LLC would like to make a transaction for a
client’s account, and client is unavailable, EisnerAmper Wealth Management & Corporate
Benefits, LLC will be unable to effect the account transaction (as it would for its
discretionary clients) without first obtaining the client’s consent.
Cash Positions. EisnerAmper Wealth Management & Corporate Benefits, LLC continues
to treat cash as an asset class. As such, unless determined to the contrary by EisnerAmper
Wealth Management & Corporate Benefits, LLC, all cash positions (money markets, etc.)
shall continue to be included as part of assets under management for purposes of
calculating EisnerAmper Wealth Management & Corporate Benefits, LLC’s advisory fee.
At any specific point in time, depending upon perceived or anticipated market
conditions/events (there being no guarantee that such anticipated market conditions/events
will occur), EisnerAmper Wealth Management & Corporate Benefits, LLC may maintain
cash positions for defensive purposes. In addition, while assets are maintained in cash, such
amounts could miss market advances. Depending upon current yields, at any point in time,
EisnerAmper Wealth Management & Corporate Benefits, LLC’s advisory fee could exceed
the interest paid by the client’s money market fund.
Cash Sweep Accounts. Account custodians generally require that cash proceeds from
account transactions or cash deposits be swept into and/or initially maintained in the
custodian’s sweep account. The yield on the sweep account is generally lower than those
available in money market accounts. To help mitigate this issue, EisnerAmper Wealth
Management & Corporate Benefits, LLC generally purchases a higher yielding money
market fund available on the custodian’s platform with cash proceeds or deposits, unless
EisnerAmper Wealth Management & Corporate Benefits, LLC reasonably anticipates that
it will utilize the cash proceeds during the subsequent 30-day period to purchase additional
investments for the client’s account. Exceptions and/or modifications can and will occur
with respect to all or a portion of the cash balances for various reasons, including, but not
limited to, the amount of dispersion between the sweep account and a money market fund,
an indication from the client of an imminent need for such cash, or the client has a
demonstrated history of writing checks from the account. As a reminder, clients
participating in EAPS are required to retain a certain percentage of cash in a related sweep
account. EisnerAmper Wealth Management & Corporate Benefits, LLC will not be able to
allocate cash in EAPS accounts to money market accounts.
Client Obligations. In performing its services, EisnerAmper Wealth Management &
Corporate Benefits, LLC shall not be required to verify any information received from the
client or from the client’s other professionals, and is expressly authorized to rely thereon.
Moreover, each client is advised that it remains their responsibility to promptly notify
EisnerAmper Wealth Management & Corporate Benefits, LLC if there is ever any change
in their financial situation or investment objectives for the purpose of reviewing, evaluating
or revising EisnerAmper Wealth Management & Corporate Benefits, LLC’s previous
recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Registrant
and its third-party service providers use to provide services to Registrant’s clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in Registrant’s
operations and result in the unauthorized acquisition or use of clients’ confidential or non-
public personal information. Clients and Registrant are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur losses, including for
example: financial losses, cost and reputational damage to respond to regulatory
obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although Registrant has established its systems to reduce the risk
of cybersecurity incidents from coming to fruition, there is no guarantee that these efforts
will always be successful, especially considering that Registrant does not directly control
the cybersecurity measures and policies employed by third-party service providers. Clients
could incur similar adverse consequences resulting from cybersecurity incidents that more
directly affect issuers of securities in which those clients invest, broker-dealers, qualified
custodians, governmental and other regulatory authorities, exchange and other financial
market operators, or other financial institutions.
Disclosure Statement. A copy of EisnerAmper Wealth Management & Corporate
Benefits, LLC’s written Brochure and Client Relationship Summary, as set forth on Parts
2 of Form ADV and Form CRS respectively, shall be provided to each client prior to, or
contemporaneously with, the execution of the Investment Advisory Agreement, Financial
Planning and Consulting Agreement or a Retirement Plan Services Agreement.
C. EisnerAmper Wealth Management & Corporate Benefits, LLC shall provide investment
advisory services specific to the needs of each client. Prior to providing investment
advisory services, an investment adviser representative will ascertain each client’s
investment objective(s). Thereafter, EisnerAmper Wealth Management & Corporate
Benefits, LLC shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on EisnerAmper Wealth Management & Corporate
Benefits, LLC’s services.
D. EisnerAmper Wealth Management & Corporate Benefits, LLC does not offer a wrap fee
program for its investment advisory services. However, EisnerAmper Wealth Management
& Corporate Benefits, LLC is a participating investment adviser in certain unaffiliated
wrap account fee programs. The programs for which EisnerAmper Wealth Management &
Corporate Benefits, LLC manages investment advisory accounts on a discretionary basis
are sponsored by Goldman Sachs and SEI Investments (“SEI”). With respect to the wrap-
fee programs in which EisnerAmper Wealth Management & Corporate Benefits, LLC is a
participating investment adviser, clients pay their fees directly to the wrap fee
sponsor/manager, who in turn remits a portion of that fee to EisnerAmper Wealth
Management & Corporate Benefits, LLC.
E. As of December 31, 2022, EisnerAmper Wealth Management & Corporate Benefits, LLC
had $1,326,263,936 in assets under management on a discretionary basis and $19,202,236
in assets under management on a non-discretionary basis.