A. Wolf Money Management, Inc. is a SEC registered boutique investment advisory firm
primarily catering to the investment needs of individuals. Our company has been operating
for twenty years. Our principal owners are Steven A. Wolf, and Paul B. Wolf.
B. We give advice on — but do not necessarily recommend — all types of securities, such as
mutual funds, stocks, bonds, and commodities. We employ both technical and fundamental
securities analysis. Our technical analysis combines Dow Theory and other weekly/ monthly
chart analysis to determine the primary trend (whether a rising “bull market” or declining
“bear market”) of each asset class. Fundamental research sources include financial periodicals,
research materials prepared by others, corporate rating services, annual reports and company
press releases. Our investment strategies are focused on the long-term, but we do pay
attention to volatility and endeavor to reduce risk through inclusion of alternative mutual funds
and ETF’s. These strategies may include merger arbitrage, market neutral funds, convertible
bond arbitrage, hard assets, long-short funds, and Master Limited Partnership funds.
We feel these strategies complement our core traditional diversified stock and bond portfolios
since the additional asset classes often have a lower correlation to stocks or bonds. We
specialize in the use of mutual funds and exchange-traded mutual funds (ETFs), though our
advice is not limited to these. We employ tactical asset allocation, which involves
overweighting asset classes determined to be in rising trend (“bull market”) and
underweighting asset classes determined to be in a declining trend (“bear market”), while
remaining in a portfolio framework determined to be appropriate for the account owner.
We also provide financial planning services. We will give you advice based on your financial
concerns including but not limited to investments, insurance, retirement, education, and estate
planning. The hours of financial counseling required will vary depending on whether the plan
is comprehensive or more narrowly focused on a topic of particular interest to you.
OPTIONAL ADVISORY SERVICES FOR EMPLOYER BASED NON-ERISA 403B
PLANS AND INDIVIDUAL VARIABLE ANNUITIES.
We manage several 403b accounts for individual participants. Since these are employer-based
accounts, the employee must choose a vendor from their districts’ participating service
providers. In some districts, we are able to use a Fidelity 403b plan and at other times Aspire
Financial/MG Trust. When using these platforms, we can only use mutual funds that the plan
allows. Since 403b plans only allow the use of mutual funds and/or annuities, we are not able to
use ETFs, individual stocks, bonds, or options. Generally, we employ the same basic investment
strategy as our normal advisory accounts except that we are limited to using plan allowed mutual
funds.
In rare instances, we function as investment advisor for clients’ variable annuities held through
Fidelity’s Insurance arm and/or another insurance company. Even though we employ the same
basic investment strategy as our normal advisory accounts, we are limited to using the sub-
accounts available within that platform. In general, these contracts tend to offer fewer alternative
investment strategy sub-accounts, so we rely more heavily on a traditional stock and bond sub-
account asset allocation.
OPTIONAL UMA PROGRAM. We offer discretionary investment management services in a
managed account program through an Overlay Manager (the “UMA Program”). This UMA
Program may consist of using model portfolio advisers, model portfolios or other investment
options such as mutual funds and/or exchange-traded funds (“ETFs”) to represent different
investment strategies for managing your account. Each of these investment strategies is designed
to meet a specific goal.
Prior to investing in the UMA Program, you will execute a discretionary investment
management agreement with us. Depending on the management services the client selects,
the client will grant us limited discretionary
authority to manage the client account through
selection of an overlay manager (“Overlay Manager”), third party strategist (“Strategist”)
and/or third-party managers (“Managers”; collectively, “Third-Party Service Providers”). In
addition, the client will authorize the custodian to follow our instructions as well as
instructions given by Overlay Manager to effect transactions, deliver securities, deduct fees
and take other actions with respect to the client account. The client will not have a direct
contractual relationship with the Overlay Manager or any other Third-Party Service
Provider.
The timing of trades in the client account will primarily depend upon the model or changes in the
model and, generally, will not take into consideration how long a client may have held the position
indicated by the model.
We will retain the right to replace any Strategist or Manager on a discretionary basis. Depending
on the service a client has selected, we will separately provide the client with the firm brochure
(Part 2 of Form ADV) for the applicable Third-Party Service Provider(s) which includes
information about their services, model portfolios, and investment strategies at or before the
execution of our discretionary investment management agreement.
Optional Tax Overlay Manager Services
Tax overlay management services are available as an option for accounts utilizing the UMA
Program through the Overlay Manager. If you elect tax overlay management services, the portion
of your fee paid as the management fee on your account will increase. The Overlay Manager will
develop a tax strategy for your account based on the information and instructions provided by us
on your behalf. Tax overlay management services in an investment account offer benefits and
limitations, as described below. The tax strategy developed for you by the Overlay Manager is
provided solely in connection with your account and the Overlay Manager does not provide
general tax planning services. If you do elect the tax overlay management services option, please
consider the following:
• The Tax Overlay Manager will implement tax overlay management services based on the
information and instructions provided for your account(s).
• The Tax Overlay Manager does not provide general tax advice, tax return preparation or tax
planning services.
• The Tax Overlay Manager will seek to reduce the overall tax burden of the account while
seeking to maintain the risk and return characteristics of the model portfolios received from
Strategists and/or Managers.
• When providing tax overlay management services to the account, short-term gains are
avoided where possible, but long-term gains are not limited unless you have requested a
mandate to limit realized long-term gains.
The Overlay Manager will provide tax overlay management services with the assumption that the
Overlay Manager will continue to provide services to the account for an entire tax year. The
termination or removal of the overlay management services before the completion of an entire tax
year may result in adverse tax consequences, including without limitation realization of short-
term capital gains. Regardless of your account size or any other factors, we strongly recommend
that you continuously consult with a tax professional prior to and throughout the investing of
your assets. The Tax Overlay Management Services are offered at an additional cost to you.
C. We tailor our advisory services to the individual needs of our clients. For instance, we have
different model portfolios based on the risk level the client is willing to accept, time horizon,
objectives, and the type of account-, i.e., Qualified retirement account vs. non-qualified
account. We are willing to exclude certain securities or types of securities based on a client-
imposed restriction.
D. We do not participate in wrap fee programs. Not Applicable
E. As of March 3, 2023, we manage client assets on a discretionary basis of $50,294,417.
We currently don’t manage any accounts in a non-discretionary manner.