A. Firm Information Axxcess Wealth Management, LLC (“AWM” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State of Delaware. AWM was founded in 2012 and is owned and operated by Michael Seid, Chief Executive Officer and Chief Compliance Officer and Jonathan Brackmann, Chief Operating Officer. This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by AWM.
B. Advisory Services Offered AWM is an independent investment advisory firm that is Client-centered in its mission. AWM’s Client base includes individuals, high-net-worth individuals, trusts, estates, businesses, charitable organizations, retirement plans, other investment advisors, and state/municipal government entities (each referred to as a “Client”). Other investment advisors, broker-dealers, and financial professionals can use AWM’s services, described below, for their Clients through AWM’s Third-Party Asset Management Platform (”TAMP”). AWM has developed a wide array of services dedicated to meeting the distinct needs of each Client. AWM works with Clients on a per-project/hourly basis or on an asset-based relationship described in Item 5 below.
Advice is provided through consultation with the Client and may include the determination of financial objectives, risk assessment, risk management, capital allocation and budgeting, identification of financial problems, cash flow management, strategic planning, insurance review, investment management, retirement plan design, installation, and management.
Each of AWM’s services is unified by the Advisor’s overall mission to meet the distinct needs of each type of Client and their investment advisor representative (“IAR”): ●Retain AWM’s Client relationships by putting their interests first; ●Invite collaboration and partnership with the Client’s existing advisors; ●Ensure clear, transparent communication; and ●Mandate the highest standard of professional conduct, Advisor ethics, and Client privacy.
AWM’s services require the Advisor’s advice to be objective. AWM’s open architecture allows the Advisor to pick and choose products and services that are aligned with AWM’s Client’s best interests.
Tailored Relationships AWM makes a point to know its Clients’ circumstances in order to implement individually tailored financial solutions. Meeting the needs of each Client in order to sustain a relationship that creates value for the Client requires a depth of knowledge, routine contact, and a requirement to collaborate with a Client's existing advisors. Client interviews, analysis of current and projected financial requirements, risk tolerance, and portfolio goals are established at the beginning and throughout the Client relationship.
The goals, objectives, and financial profile for each Client are documented in AWM’s Client relationship management system (“CRM”). Investment policy statements (“IPS”) are created for certain Clients and reflect the stated goals and objectives of those Clients. Clients may impose restrictions on investing in certain securities or types of securities.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith toward each Client and seeks to mitigate potential conflicts of interest. AWM's fiduciary commitment is further described in the Advisor’s Code of Ethics.
For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Core Services: Wealth Management Services AWM provides Clients with wealth management services, which generally include discretionary management of investment portfolios in connection with a broad range of comprehensive financial planning and consulting services. These services are described below.
Internal Investment Management Services – AWM’s core services are focused on wealth management. AWM provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. AWM works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy.
Most Clients choose to have AWM advise them on matters related to their wealth management and the implementation of their investment strategy. Prior to providing advisory services, AWM’s Clients enter into an advisory services agreement known as the AWM Engagement Agreement. Core services are highly tailored to each Client, as the Advisor does not manage a “one size fits all” model portfolio. AWM’s Client accounts are monitored on at least a monthly basis and focused on meeting current and evolving financial needs. AWM’s IARs assist the Client’s investment decisions by endeavoring to understand the Client’s financial goals and objectives in the areas of investment allocation, retirement planning, estate planning, and corporate planning.
AWM will review the Client’s current financial position, taking into account the stated financial goals and objectives of the Client. AWM will frequently establish and formalize a customized IPS for each Client or account being managed. Portfolios are designed and managed using a mix of investments, including stocks, bonds, low-cost, diversified mutual funds, third-party managers, exchange-traded funds (“ETFs”), structured notes, real estate investment trusts (“REITs”), business development companies, and alternative investments such as hedge funds and private equity. The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations. Clients have the option of granting either fully discretionary authority or limited discretionary authority to AWM regarding their investment accounts. Certain third-party managers are only available on a fully discretionary basis. AWM also provides other advisory consulting services, which include financial planning, capital allocation, and advisement on financial matters to businesses, high-net-worth individuals, family offices, and retirement plans.
AWM provides investment advisory services to its Clients on a discretionary or non-discretionary basis on both taxable and tax-deferred accounts. The advisory services include, among other things, providing advice regarding both tactical and strategic asset allocation and the selection of investments. AWM’s advisory services are guided by the stated objectives provided for in a Client profile or IPS. AWM considers the Client’s risk tolerance and financial status prior to making any recommendations.
AWM’s investment strategies are designed to reflect the needs of its Clients. The Advisor may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. AWM will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
AWM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. AWM may recommend, on occasion, rebalancing or reallocating the investment allocations.
AWM may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as part of a target allocation.
AWM may recommend or sell positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
AWM selects, recommends, and/or retains mutual funds on a fund-by-fund basis and seeks to use non-retail or institutional classes when possible. Due to specific custodial or mutual fund company constraints, material tax considerations, and/or systematic investment plans, AWM may select, recommend, and/or retain a mutual fund share class that has a higher expense ratio than an equivalent share class. AWM will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and stated investment guidelines.
AWM also may render non-discretionary investment management services to Clients relative to (1) variable life/annuity products that they may own and/or (2) their individual employer-sponsored retirement plans. In so doing, AWM either directs or recommends the allocation of Client assets among the various mutual fund subdivisions that comprise the variable life/annuity product or the retirement plan. The Client assets shall be maintained at either the specific insurance company that issued the variable life/annuity product, which is owned by the Client, or at the custodian designated by the sponsor of the Client’s retirement plan.
At no time will AWM accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Use of Third-Party Managers – AWM may recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “TPMs”) for all, or a portion of a Client’s investment portfolio based on the Client’s needs and objectives. In such instances, the Client will be required to authorize and enter into an investment management agreement with a TPM that defines the terms in which the TPM will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each TPM to ensure the strategy remains aligned with the Client's investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the TPM’s Form ADV Part 2A – Disclosure Brochure (or a brochure that makes the appropriate disclosures) prior to entering into an agreement with a TPM. Please see the Sleeve Manager Platform and TPMs and Wrap Fee Programs sections below for additional information.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to the Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction, including rollovers from one ERISA-sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new (or increases its current) advisory fee as a result of the transaction. No Client is under any obligation to roll over a retirement account to an account managed by the Advisor.
Participant Account Management – As part of the Advisor’s investment management services, when appropriate, the Advisor will use a third-party platform to facilitate the management of held-away assets, such as defined contribution plan participant accounts, with investment discretion. The platform allows the Advisor to avoid being considered to have custody of Client funds since the Advisor does not have direct access to Client log-in credentials to affect trades. AWM is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the Client, allowing the Client to connect an account[s] to the platform. Once the Client’s account[s] is connected to the platform, the Advisor will review the current account allocations. When deemed necessary, the Advisor will rebalance the account considering the Client’s investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account[s] will be reviewed at least quarterly, and allocation changes will be made as deemed necessary.
Advisory Services: Financial Planning and Consulting Services – AWM provides advisory services to Clients, included as a component of its wealth management services or pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific 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 investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
As part of AWM’s financial planning and consulting services, AWM also furnishes advice to Clients on matters such as capital formation, investment structure, financial risk management, business planning matters, and succession planning and may include estate and insurance planning services. Capital placement activities are not handled by AWM.
Services also focus on areas that Clients typically won’t see on a Custodian’s statement, such as real estate, business interests, or diligence activities. Many of AWM’s Clients rely on the Advisor for advice in a variety of financial decisions with respect to their family office establishment and governance, purchasing or selling businesses, raising capital, negotiating, and structuring financial transactions. AWM will endeavor to provide reporting of positions and performance using AWM’s Private Asset Platform (“PAP”). PAP is an AWM reporting service that integrates directed investments such as real estate, private equity, or private credit in a consolidated manner. AWM makes no representations or guarantees about the accuracy of the information contained in its PAP reports. AWM specifically discloses in its PAP enrollment forms that there can be no guarantee that PAP reports are accurate as of the date received or that they will continue to be accurate in the future. The data contained in AWM’s PAP comes from the administrator, sponsor, sponsors administrator, and or auditor/accountant. AWM does not provide valuation or pricing services.
A financial plan developed for, or financial consultation rendered to the Client will usually 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, and establish education savings and/or charitable giving programs.
AWM may also refer Clients to an accountant, attorney, or other specialists as appropriate for their unique situation. The Advisor may also leverage a third party for estate planning services under a separate agreement.
For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of the contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor.
Customized Portfolio Platform: Available Internally and Externally through AWM’s TAMP AWM provides investment advisory services under a program called the Axxcess Customized Portfolio Platform (“ACPP”). ACPP is a discretionary investment management process designed to assist Clients with their financial goals and objectives. ACPP uses a multi-step process implemented by the Advisor and is based on the individual needs of the Client. An initial interview and data-gathering questionnaire are undertaken to determine the Client’s financial situation and investment objectives. The ACPP process includes a thorough review and analysis of the Client’s current asset allocation and portfolio objectives. The Advisor will review the recommended custom allocation with Clients. Clients will work with the Advisor to create a written plan in the form of an IPS or a Client Investment Guidelines (“CSA”), which will identify asset allocation classes, investment styles, tax policy income preferences, and other trading guidelines. It is the Client’s responsibility to notify the Advisor at any time if there are any changes. Client funds and securities are held by a qualified custodian in a separate account under the Client’s name. The Client retains rights of ownership of all securities and funds in the account to the same extent as if the Client held the securities and funds outside the program.
Sleeve Manager Strategy Services: Available Internally and Externally through AWM’s TAMP Sleeve Manager Platform – AWM has developed a comprehensive system of model, sleeve, and portfolio management services relating to the maintenance and administration of investment advisory accounts, which it makes available to its Clients and the Clients of third-party investment advisors. The sleeve portfolio management services may be provided to AWM Advisory Persons and to third-party investment advisory firms, with AWM acting as a sub-advisor or TAMP. The TAMP Platform assists AWM’s Advisory Persons and third-party RIA and Broker-Dealer firms with middle, back office, and operational

services and provides investment management solutions such as Unified Managed Accounts (“UMAs”) and Unified Managed Household Services (“UMHs”) focused on high-net-worth clients and the advisors that serve them. Details of these services are described on AWM’s website for IARs and other investment professionals at www.axxcessplatform.com.
AWM has developed this platform to create a unique Client experience by lowering the cost and complexity of building portfolios using TPMs with advisor-directed solutions. Portfolios are optimized using equity, fixed income, ETFs, and mutual funds in a single brokerage account. AWM’s technology enables TPMs to manage their strategies in a “sleeve” that compartmentalizes the securities in the TPMs model strategy. The TPM's trading, performance, reporting, and billing are separated from the other assets in the Client’s portfolio without the need to open separate accounts at the custodian. AWMs sleeve manager reporting system provides the Client with comprehensive reporting at the Client’s household, registration, account, and sleeve manager level.
The custodial account can be “sleeved” to enable TPMs to manage strategies alongside alternative investments such as private equity and hedging strategies, resulting in both the core strategic and tactical investment strategies.
AWM may provide administrative “middle” and/or “back office” services to third parties, other investment advisors, and broker-dealers and may make available billing, reporting, and investment and operational services. The Client of a third-party investment advisor or broker-dealer (herein “Primary Advisor”) will sign a program agreement that describes the relationship between the Client (herein “Investor”), their Primary Advisor, and AWM. The program agreement is called a Client Services Agreement (“CSA”) and is a tri-party agreement wherein the investor delegates authority to their Primary Advisor to choose various sleeve managers on the AWM Platform or to direct investment allocation decisions to AWM to execute on behalf of the investor. AWM will provide trading services to the investor and their Primary Advisor through a Limited Power of Attorney form, typically supplied by the investor’s custodian. AWM acts as a fiduciary to the investor on the account sleeves managed by sleeve managers working on the AWM Platform. AWM will either serve as a Sub-Advisor or Co-Advisor, depending on the preference of the investor and the Primary Advisor. AWM may also allow the Primary Advisor to act as a solicitor and introduce investors to the AWM platform, where AWM will act as fiduciary to the entire Client account associated with the AWM Platform.
Sleeve Portfolio Management Services – When the AWM Investment Oversight Committee (“IOC”) is interested in allocating part of a portfolio to a TPM who is in the business of providing sub-advisory services in regard to the formation and management of model portfolios to investment advisors and is registered as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended, (“Advisers Act”) or under the corresponding regulations of the states or other jurisdictions in which it conducts such business, AWM may engage the TPM to design, monitor on a daily basis, and, as necessary, update the strategy(ies) directly with AWM. This component of AWM’s platform is called Sleeve Portfolio Management Services. The TPM is called a “sleeve strategy manager.” The intent of this service is to reduce the number of separate accounts the Client would otherwise need in order to implement an investment strategy with multiple TPMs. AWM will enter into a sub-advisory or signals-based relationship with the TPM. AMW is responsible for trade order management and execution with the Client’s custodian, collecting the Sleeve Manager Fee, and remitting a portion of that fee to the TPM. The sleeve strategy managers update their investment models directly in the AWM portfolio management system. In addition to reducing the number of accounts for the Client, this arrangement typically results in a lower fee and/or lower minimum investment to the Client than if they otherwise engaged the TPM directly. AWM will provide sleeve strategy management services directly to Clients who have signed an AWM EA and sign an additional addendum that identifies the sleeve strategy manager and the fee to be billed for the sleeve strategy. Sleeve strategy services will not be rendered without the Client receiving the most recent copy of the sleeve strategy manager’s Form ADV Part 2A – Disclosure Brochure (or a brochure that makes the appropriate disclosures).
The Client’s investment instructions are generally communicated to AWM in the form of asset allocation strategies (“Strategies”). The strategy creator may either be the investor’s Primary Advisor or the AWM IOC. In many cases, the Primary Advisor will create the Strategy for the investor’s account[s]. Alternatively, the Primary Advisor may elect to employ a Strategy from a third-party strategist, also a registered investment advisor, for the investor’s account[s]. Strategies are comprised of a model portfolio (“Model”), or a weighted combination of multiple Models called a model aggregate. A Model or model aggregate represents the investment recommendations of the Primary Advisor or the AWM IOC in the form of a list of securities to hold and the relative weight of each. The Primary Advisor may be one of the managers providing one or more of the Models for the account’s Strategy. Additionally, the Models of TPMs, themselves registered investment advisors, may be included in the investor’s account’s Strategy. The Primary Advisor or the AWM IOC is responsible for researching and evaluating managers and selecting the specific Models or model aggregates employed in the investor’s account’s Strategy.
The responsibilities of the third-party Strategists and TPMs who have signed sub-advisory agreements with AWM with respect to investor’s accounts are limited to providing generalized, non-discretionary investment advice. The Primary Advisor remains solely responsible for understanding the investor’s financial situation, investment goals and objectives, qualification, time horizon, portfolio liquidity and concentration, and tolerance for risk, as well as any investment limitations and reasonable restrictions for the investor’s account. Based upon this knowledge, the Primary Advisor selects a suitable Strategy for the investor’s account[s]. The Primary Advisor is solely responsible for maintaining communication with investors to monitor the investor’s investment objectives and any changes in the investor’s individual circumstances and for communicating any changes in the investor’s situation to AWM in the form of a suitable Strategy selected for the investor’s account. Any questions investors may have regarding the Strategy employed for their account, the manager Models comprising the Strategy, or their suitability for their individual financial situation should be directed solely to the investor’s Primary Advisor.
AWM sleeve strategy services require discretionary authority to implement the investment instructions specified by the investor’s Primary Advisor via the purchasing and selling of securities. This authority is in addition to the investor’s Primary Advisor, who maintains at all times full discretionary authority over the investor’s accounts.
The investor grants AWM this discretionary authority through the custodian or broker-dealer who holds the investor’s account. Through the custodial paperwork, the investor designates AWM to be the “manager” or “sub-advisor” for accounts. With this authority, AWM monitors investors’ accounts to assess ongoing conformity to the Strategy selected by the investor’s Primary Advisor. If the account varies from the Strategy beyond a tolerance specified by the strategist, AWM will make appropriate and necessary adjustments to bring the account back into tolerance.
The portfolio is monitored on a continuous basis. The AWM IOC, led by Jon Brackmann, MBA, Certified Investment Management Analyst™(“CIMA®”), will periodically rebalance the portfolio back within the asset allocation range as needed without contacting the investor. Investors have the choice to receive either electronic or paper confirmations and statements from the custodian containing a description of all transactions and all account activity. In addition to custodial statements, AWM produces quarterly performance reports available to investors upon request.
TPMs and Wrap-Fee Programs AWM does not provide portfolio management services to a wrap-fee program. Under a wrap fee program, advisory services (which may include portfolio management or advice concerning the selection of other investment advisors) and transaction services (e.g., execution of trades) are provided for one fee. This is different from AWM’s traditional investment management programs, whereby advisory services are provided for a fee, but transaction services are billed separately on a per-transaction basis and typically paid to the Client’s custodian, as discussed in Items 12 and 14 below.
AWM may, however, recommend TPMs and/or wrap-fee programs that have full investment discretion and trading authority and are not engaged as a sub-advisor on AWM’s Sleeve Manager Platform. These TPMs have sole responsibility for the implementation of the investment program with respect to the Client’s account, for which investment discretion has been delegated by the Client and accepted by the TPM. AWM does not place orders for transactions in the Client’s account or otherwise exercise trading authority over an account managed by a TPM or wrap-fee program sponsor. TPMs and wrap-fee program sponsors recommended by AWM to its Clients are subject to a rigorous due diligence process. Factors considered by AWM in its determination of whether to recommend a TPM or wrap-fee program include but are not limited to regulatory compliance, reputation, performance record, philosophy, continuity of management, service to Clients, awareness of after-tax performance objectives, minimum dollar investment requirements and fees. Information about TPMs and wrap-fee program sponsors (e.g., performance figures, investment style, etc.) is obtained from tracking organizations, business publications, money managers, personal interviews, and other sources that AWM believes are reliable. AWM may also consider other criteria, including, but not limited to, the administration, recordkeeping, and reporting services provided by a manager or sponsor. AWM may also retain outside consultants to assist in preparing TPM search lists. In the event that AWM retains an outside consultant, AWM will make the final determination regarding which TPM, or wrap-fee program sponsors are made available to Clients.
The terms and conditions under which the Client shall engage a TPM, or wrap-fee program sponsor shall be set forth in separate written agreements between (1) the Client and AWM and (2) the Client and the designated TPM and/or wrap-fee program sponsor. AWM shall continue to render advisory services to the Client relative to the ongoing monitoring and review of account performance, for which AWM shall receive an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated TPM and/or wrap-fee program sponsor. Factors that AWM shall consider in recommending TPMs and/or wrap fee program sponsors include the Client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated TPM and/or wrap-fee program sponsor and the corresponding designated custodian or broker-dealer of the Client’s assets may be exclusive of and in addition to AWM’s investment advisory fee set forth in Item 5 below. In addition to this Disclosure Brochure, the Client shall also receive the written disclosure statement of the designated TPM[s] and wrap-fee program sponsor[s]. Certain TPMs and wrap-fee program sponsors may impose more restrictive account requirements and varying billing practices than AWM. In such instances, AWM may alter its corresponding account requirements and/or billing practices to accommodate those of the TMP(s) or wrap-fee program sponsor(s).
AWM may also refer Clients to certain TPMs or wrap-fee programs where AWM’s compensation is included in the advisory fee charged by the TPM. In such cases, AWM will be compensated for its services by receipt of a fee to be paid directly by the TPM to AWM 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 shall be paid solely from the TPM’s investment management fee or the program fee of the wrap-fee program (as appropriate) and shall not result in any additional charge to the Client.
Corporate Services: Retirement Plan Advisory Services AWM provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ●Vendor Analysis ●Plan Participant Enrollment and Education Tracking ●Investment Policy Statement Design and Monitoring ●Performance Reporting ●Investment Oversight Services (ERISA 3(21)) ●Investment Management Services (ERISA 3(38)) ●Ongoing Investment Recommendations and Assistance ●ERISA 404(c) Assistance ●Benchmarking Services These services are provided by AWM serving in the capacity of a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of AWM’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Advisory Teams AWM offers services through the Advisor’s network of IARs. IARs may have their own legal business entities or trade names. The IARs' trade names may be used for marketing purposes and appear on marketing materials or Client statements. The Client should understand that the businesses are legal entities of the IARs and not of AWM. The IARs are under the supervision of AWM, and the advisory services of the IARs are provided through AWM. The Advisor has the arrangement described above with the following IARs: Advisory Team Name Representative Names Advisory Team Focus Core Services Financial Planning Corporate Services Alta PrivateAlan GrismoreWealthYesYesYes WealthManagement, Family Office, Advisory Asset Preservation Strategies John Jenkins,AEP®, CFP®, BPC, Certified Financial Fiduciary® Greg Banner,CFP ®, CLU ®, CRTP Monica Szakos, CFP®, CEPA, BFA™, Certified Financial Fiduciary® Timothy Figueroa Comprehensive Financial Planning, Wealth Management, Investment Advisory YesYesYes Collier Sustainable Wealth Management Meris Collier, CFP®Financial Planning, Investment Management, Investment Advisory YesYesYes Advisory Team Name Representative Names Advisory Team Focus Core Services Financial Planning Corporate Services Donahugh Wealth Christopher DonahughRetirement Planning, Wealth Planning, Investment Advisory YesYesYes E and E Financial Eric SamsRetirement Planning, Wealth Planning, Investment Advisory YesYesYes Jennifer P. Easley, CFP® Jennifer P. Easley, CFP® Financial Planning, Investment Management, Investment Advisory YesYesYes LA Wealth Advisors Richard (Alex) Leu Jaime Hefner Wealth Management, Financial Planning, Investment Advisory YesYesYes Magnolia Capital Management Andrew ThomasWealth Management, Family Office, Investment Advisory YesYesYes Providence Wealth Management Joshua KhokharComprehensive Financial Planning, Wealth Management, Investment Advisory YesYesYes Route 20 Private Wealth Albert Nassar Peter Weitz Financial Planning, Investment Management, Investment Advisory YesYesYes Sewalson & Milazzo Mark Sewalson James Milazzo Financial Planning, YesYesYes Management, Advisory Silverstone Private Wealth Todd QuinnWealth Management, Family Office, Advisory YesYesYes The Zandbergen Group Bart Zandbergen, CFP® Letitia Berbaum Timothy Rickey, CFP® Jonathan Lugo Scott Heinila Wealth Management, Family Office, Financial Planning, Investment Management, Investment Advisory, Reporting YesYesYes Vandalia Wealth Management Caleb Casto Ian McIlvaine John M. Jones Kathryn Lester Lois A. Crichton Michael Cavendish Justin Bonavitacola Julie Sowards Financial Planning, Investment Management, Investment Advisory YesYesYes C. Client Account Management Prior to engaging AWM to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: ●Establishing an Investment Strategy – AWM, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
●Asset Allocation – AWM will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
●Portfolio Construction – AWM will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
●Investment Management and Supervision – AWM will provide investment management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs AWM does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by AWM.
E. Assets Under Management As of December 31, 2023, AWM manages $6,470,763,788 in Client assets, $5,371,230,552 of which are managed on a discretionary basis and $1,099,533,236 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.
In addition, as of December 31, 2023, AWM also has $4,360,722,887 of Assets Under Administration (“AUA”).
As a TAMP, the Advisor provides a variety of investment services where it does not directly have discretion but provides other investment operations, reporting, and investment management services. The Advisor calculates AWM’s AUA as household investment accounts that are on AWM’s Platform that require reporting or other middle or back-office services. AWM’s total Platform assets are the sum of AWM’s regulatory AUM and AWM’s AUA, which is approximately $10.8 billion.