A. Firm Information
Aspire Wealth Management Corporation (“AWM”, “we”, “us” or the “Adviser”) is a registered investment
adviser with the U.S. Securities and Exchange Commission (“SEC”). AWM is organized as a corporation
under the laws of Massachusetts. AWM has been in business since July 2012 and is owned and operated by
Mark Khozozian, Founder and Chief Executive Officer. AWM’s professionals have been in the business of
providing investment advice to Clients for collectively over 36 years.
B. Advisory Services Offered
AWM provides personalized financial planning and/or investment management services. Clients advised
may include individuals, high net worth individuals, trusts, estates, foundations, corporations, and retirement
plans (each herein a “Client” or “you”).
Financial Planning Services
AWM also offers financial planning and consulting services, as described below. These services may be
provided as a stand-alone service or may be coupled with ongoing portfolio management.
Financial planning may include advice that addresses one or more areas of a Client’s financial situation, such
as estate planning, risk management, budgeting and cash flow controls, retirement planning, education
funding, and investment portfolio design and ongoing management. Depending on a Client’s particular
situation, financial planning and consulting may include some or all of the following:
• Gathering factual information concerning the Client’s personal and financial situation;
• Assisting the Client in establishing financial goals and objectives;
• Analyzing the Client’s present situation and anticipated future activities in light of the Client’s
financial goals and objectives;
• Identifying problems foreseen in the accomplishment of these financial goals and objectives and
offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the Client;
• Estate planning strategies;
• Assessing risk and reviewing basic health, life and disability insurance needs; or
• Reviewing goals and objectives and measuring progress toward these goals.
Once financial planning or consulting advice is given, the Client may choose to have the Adviser implement
the Client’s financial plan and manage the investment portfolio on an ongoing basis. However, the Client is
under no obligation to act upon any of the recommendations made by the Adviser under a financial planning
engagement and/or engage the services of any recommended professional.
Each Client’s portfolio will be invested according to that Client’s investment objectives. We determine these
objectives by interviewing the Client and/or asking the Client to put these objectives in writing. Once we
ascertain your objectives for each account, we will develop a set of asset allocation strategy. An asset
allocation strategy is a percentage-based allocation to different investment types. The percentages in each
type that we recommend are based on the typical behavior of that security type, current market conditions,
your current financial situation, your financial goals, and the timeline to get you to those goals. AWM will
develop a strategy based on the Client’s risk tolerance, time horizon, and investment goals and will assist the
Client in implementing the strategy to achieve their goals.
We may periodically recommend securities transactions in your portfolio to meet the guidelines of the asset
allocation strategy. It is important to remember that because market conditions can vary greatly, your asset
allocation guidelines are not necessarily strict rules. Rather, we review accounts individually, and may
deviate from the guidelines, as we believe necessary.
The specific securities we recommend for your account[s] will depend on market conditions and our research
at the time. We primarily recommend a mix of mutual funds and exchange-traded funds (“ETFs”). AWM
may also utilize and assist in the management of individual securities, as necessary. Specific investments are
chosen based on where its investment objective fits into the asset allocation recommended by AWM, its risk
parameters, past performance, peer rankings, fees, expenses, and any other aspects of the fund AWM deems
relevant to that investment.
To implement the Client’s investment plan, the Adviser will manage the Client’s investment portfolio on a
discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the Client. As
a discretionary investment adviser, the Adviser will have the authority to supervise and direct the portfolio
without prior consultation with the Client. Clients who choose a non-discretionary arrangement must be
contacted prior to the execution of any trade in the account(s) under management. This may result in a delay
in executing recommended trades, which could adversely affect the performance of the portfolio. This delay
also normally means the affected account(s) will not be able to participate
in block trades, a practice designed
to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-
discretionary arrangement, the Client retains the responsibility for the final decision on all actions taken with
respect to the portfolio.
Notwithstanding the foregoing, Clients may impose certain written restrictions on the Adviser in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of investments
in an investment portfolio or prohibiting the sale of certain investments held in the account at the
commencement of the relationship. Each Client should note, however, that restrictions imposed by a Client
may adversely affect the composition and performance of the Client’s investment portfolio. Each Client
should also note that his or her investment portfolio is treated individually by giving consideration to each
purchase or sale for the Client’s account. For these and other reasons, performance of Client investment
portfolios within the same investment objectives, goals and/or risk tolerance may differ and Clients should
not expect that the composition or performance of their investment portfolios would necessarily be consistent
with similar Clients of the Adviser.
Annuities and Insurance Products
As part of AWM’s Asset-Management Services, AWM may recommend fixed or variable annuity or life
insurance product to its Clients , depending on the Client’s investment objectives, risk tolerance, and other
factors specific to the Client’s investments or strategies.
AWM is able to offer Clients a fixed or variable annuity or life insurance product under an Annuity Contract
through a third-party insurance company. These Annuity Contracts offered by AWM are purchased through
a third-party carrier and are only available to advisory Clients of AWM.
The third-party carrier will establish a separate account (the “Annuity Account”) to hold assets allocated to
investment options by owners of the Annuity Contracts. The Annuity Account is divided into separate sub-
accounts (each, a sub-account), each of which invests in a separate mutual fund (each, a Fund and
collectively, the Funds).
In conjunction with the purchase of the Annuity Contract, AWM provides investment advisory services with
respect to the Funds available under the Annuity Contract. The Client account will invest any Annuity
Contract assets across each selected asset class into one or more Funds made available under the Annuity
Contract with the advice of AWM.
Pension Consulting Services
A special type of investment consulting that we provide is our advice to participant directed retirement plans,
such as 401(k) and 403(b) plans. Our approach, as well as the steps in the process, is very similar to those in
our other consulting services; but differences result from the fact that there often are hundreds of participants
in a plan, each of which has different goals and needs. Differences also result from the application of federal
pension laws to these plans. The fiduciary responsibilities of plan sponsors, trustees, and investment advisers
are great. It is crucial that all fiduciaries understand their responsibilities. We help educate fiduciaries and
share ERISA 3(21) responsibility with the plan sponsors and trustees. However, AWM does not assume a
higher level of fiduciary responsibility as a 3(38) plan fiduciary.
In summary, our goal is to give prudent, expert advice to participant directed retirement plans. In providing
investment consulting advice we share ERISA 3(21) fiduciary status with plan sponsors and trustees but do
not assume a higher level of fiduciary responsibility as a 3(38) plan fiduciary.
C. Client Account Management
AWM’s services are tailored to the individual needs of each Client based on their financial goals and
investment objectives. Clients may impose reasonable restrictions on the management of their assets.
D. Wrap Fee Programs
AWM no longer offers a Wrap Fee Program to new Clients, however, the Adviser has certain legacy Clients
where securities transaction fees remain combined with investment advisory fees. Including these fees into a
single asset-based fee is considered a “Wrap Fee Program”. The Adviser manages wrap fee accounts in a the
same manner as non-wrap fee accounts and customizes its investment management services for each Client
in accordance with the Client’s financial goals and investment objectives. The Adviser provides the AWM
Wrap Fee Program Brochure solely as a supplemental disclosure regarding the combination of fees.
Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay
more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 –Wrap Fee
Program Brochure, which is separate from this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2023, AWM manages $379,473,717 in Client assets, $375,919,044 of which are
managed on a discretionary basis and $3,554,673 on a non-discretionary basis.