Noble Wealth Management, Inc. is a registered investment adviser based in Aliso Viejo, California. We
are organized as a corporation under the laws of the State of California. We have been providing
investment advisory services since 2014. Alan J. Schryer is our principal owner, Anthony J. DiLiberto is
the Chief Compliance Officer. Currently, we offer the following investment advisory services, which are
personalized to each individual client:
• Portfolio Management Services
• Financial Planning Services
• Investment Consulting and Portfolio Review Services
• Pension Consulting Services
• Selection of Other Advisers
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to your
individual needs. As used in this brochure, the words "we", "our" and "us" refer to, and the words "you",
"your" and "client" refer to you as either a client or prospective client of our firm.
We are not a publicly held company and no part of us is owned by an individual or company through any
subsidiaries or “intermediate subsidiaries.”
Types of Advisory Services Offered
Portfolio Management Services
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. If you retain our firm for portfolio management services, we will
meet with you to determine your investment objectives, risk tolerance, and other relevant information at
the beginning of our advisory relationship. We will use the information we gather to develop a strategy
that enables our firm to give you continuous and focused investment advice and/or to make investments
on your behalf. As part of our portfolio management services, we will determine to allocate your assets in
among various individual debt and/or equity securities and/or mutual funds in accordance with your
investment objective(s) using one or more of our own proprietary model portfolios, one or more of SEI's
proprietary model portfolios, a custom designed portfolio, or any combination thereof. Once we create or
select a model portfolio or third-party manager, we will monitor your portfolio's performance on an
ongoing basis, and have your portfolio rebalanced as required by changes in market conditions and in
your financial circumstances.
If you participate in a third-party program, a manager on the third party's platform will be appointed to
place trades in accordance with the strategy or model that the manager uses. In that regard, the manager
takes discretion over the investment decisions related to your account. This means that manager has the
discretion over the selection and amount of securities to be purchased or sold for your account(s) without
obtaining your consent or approval prior to each transaction. See Selection of Other Advisers below.
Financial Planning Services
We offer financial planning services which typically involve providing a variety of advisory services to
clients regarding the management of their financial resources based upon an analysis of their individual
needs. These services can range from broad, comprehensive, financial planning to consultative or single
subject planning. We also offer hourly financial consulting as well. If you retain our firm for financial
planning services, we will meet with you to gather information about your financial circumstances and
objectives. We may also use financial planning software to determine your current financial position and
to define and quantify your long-term goals and objectives. Once we specify those long-term objectives
(both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and
analyze the information you provide to our firm and the data derived from our financial planning software,
Form ADV Part 2A for NWM Page 6 of 24
we will deliver a written plan to you, designed to help you achieve your stated financial goals and
objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to us. You must promptly notify our firm if your financial situation, goals,
objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act
on any of our recommendations, you are not obligated to implement the financial plan through any of our
other investment advisory services. Moreover, you may act on our recommendations by placing securities
transactions with any brokerage firm.
Investment Consulting and Portfolio Review Services
We provide non-discretionary portfolio review, asset allocation analysis, and investment
recommendations for assets not directly under the management of Noble Wealth Management. These
accounts could include participant directed plans, such as 401Ks and 403Bs, or other qualified plans, and
may also include assets invested with other custodians. After an initial review and analysis of each
account receiving this service, and depending on the specifics of each account, the services may include
specific investment recommendations, general advice and direction, allocation education and
consultation, and ongoing review and/or other services as agreed upon in writing by the advisor and the
client. The advisor is not responsible for implementing any recommendations for these services and will
not be involved in any way in the purchase or sale of any specific investments being recommended using
this service.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services may include an existing plan review and analysis, plan-level advice regarding fund selection and
investment options, education services to plan participants, investment performance monitoring, and/or
ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in
nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other
named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as:
• Diversification
• Asset allocation
• Risk tolerance
• Time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services) shall be detailed in a written agreement and be consistent with the parameters set forth in the
plan documents.
Party to the pension consulting agreement may terminate the agreement upon written notice to the other
party in accordance with the terms of the agreement for services. The pension consulting fees will be
prorated for the quarter in which the termination notice is given, and any unearned fees will be refunded
to the client.
Form ADV Part 2A for NWM Page 7 of 24
Retirement Plan Participant Account Management (Discretionary)
via Pontera® Held Away
Accounts Service
In certain instances, NWM will provide an additional service for client’s held away accounts through the
third-party platform, Pontera Solutions, Inc. (“Pontera”). The accounts, such as defined contribution
retirement plan participant accounts, are not directly held in our custody (i.e., held away), but are ones
wherein NWM still has discretion, and may leverage an Order Management System to implement tax-
efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily
401(k) accounts, HSAs, and other assets NWM does not custody and cannot manage through its portfolio
management service. If NWM offers a client this service, and upon client’s consent, then a link will be
provided to the client allowing them to connect an account(s) to the platform. Once the client’s account(s)
are connected to the platform, NWM will review their current account allocations. Client account(s) will be
reviewed at least quarterly and allocation changes will be made as deemed necessary. NWM will
rebalance the account considering client 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. NWM may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between our firm and the client. Clients are advised
that held away accounts, like defined contribution retirement plan accounts, may provide a limited choice
of investment options. NWM’s discretionary or non-discretionary services (as agreed upon with the client)
with respect to such accounts will be limited to the investment options made available under the held
away account.
NWM is not affiliated with Pontera in any way and receives no compensation from Pontera. See Item 5
below for details on any fees associated with the Pontera platform.
Acknowledgment of Fiduciary Status under ERISA
On occasion, NWM’s investment professionals may recommend rollovers to retirement plan participants,
including; (i) from an ERISA plan to another ERISA plan or to an IRA; (ii) from an IRA to another IRA; or
(iii) from one type of account to another, such as a commission-based account to a fee-based account.
In such cases, NWM’s investment professionals would be providing ERISA fiduciary advice when it
discusses specific investment products or advice with a client prior to the rollover, and the clients and
NWM’s investment professionals have a mutual understanding that NWM’s investment professionals will
be providing investment advice on a regular basis after the rollover.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this
special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest
Form ADV Part 2A for NWM Page 8 of 24
Selection of Other Advisers
As part of our investment advisory services, we may recommend that you use the services of a third-party
money manager ("MM") to manage all, or a portion of, your investment portfolio. After gathering
information about your financial situation and objectives, we will recommend that you engage a specific
MM or investment program. Factors that we take into consideration when making our recommendation(s)
include, but are not limited to, the following: the MM's performance, methods of analysis, fees, your
financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor
the MM(s)' performance to ensure its management and investment style remains aligned with your
investment goals and objectives.
At present, we utilize SEI's Managed Accounts Program (the "Program"). To participate in the Program,
our firm, SEI Investment Management Corporation (hereinafter "SIMC") and the individual investor
executes a tri-party agreement (hereinafter, a "Managed Account Agreement") providing for the
management of certain investor assets in accordance with the terms thereof. Pursuant to a Managed
Accounts Agreement, the investor appoints our firm as its investment adviser to assist the investor in
selecting an asset allocation strategy, which would include the percentage of investor assets allocated to
designated portfolio of separate securities (each, a "Managed Account Portfolio") and may include the
percentage of assets allocated to a portfolio of mutual funds sponsored by SIMC or an affiliate thereof.
The investor appoints SIMC to manage the assets in each Managed Account Portfolio in accordance with
a strategy selected by the investor together with our firm. SIMC may delegate its responsibility for
selecting particular securities to one or more portfolio managers. The Program seeks to provide a globally
diversified portfolio in order to meet an investor's long-term goals. The MM takes discretion over the
investment decisions related to your account. This means that the MM has the discretion over the
selection and amount of securities to be purchased or sold for your account(s) without obtaining your
consent or approval prior to each transaction. By reason of the MM having discretion to make trades, and
our ability to hire and fire the MM if we believe it is in your best interests, we also effectively have
discretion over your account. You may specify investment objectives, guidelines, and/or impose certain
conditions or investment parameters for your account(s). For example, you may specify that the
investment in any particular stock or industry should not exceed specified percentages of the value of the
portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or
security.
Before selecting other advisers, we will review the MM's registration status to ensure the MM is properly
licensed or registered as an investment adviser.
Wrap Fee Program
NWM does not participate in a wrap fee program at this time.
Assets under Management
As of December 31, 2023, the amount of client assets under advisement is calculated as follows:
Discretionary: $ 166,258,066 (603 Accounts)
Non-discretionary: $ 9,276,866 (26 Accounts)
Total $ 175,534,932 (629 Accounts)
NWM’s method for computing the amount of “client assets you manage” is the same method for
computing “assets under management.” The amount as disclosed above is rounded to the nearest
$100,000. The date of the calculation above is not more than ninety (90) days before the date NWM last
updated its brochure.
Form ADV Part 2A for NWM Page 9 of 24