FWA, branded as FamilyWealthsm, is a registered investment adviser that offers investment advice,
portfolio management, securities and other financial services to Clients. FWA is registered through and
regulated by the SEC.
FWA was founded with a vision to provide wealth management solutions through investment adviser
representatives (“IARs”) to its Clients, which includes individuals, high net worth individuals, trusts,
estates, corporate pension and profit-sharing plans, charitable organizations, foundations, endowments,
corporations and small businesses (collectively, “Clients”). FWA uses the FamilyWealth™ platform
(“Platform”) to provide its IARs with a comprehensive view of Clients’ portfolios. The Platform is built
upon third-party software, with additional Client Relationship Management (“CRM”) functionality. The
Platform also contemplates and makes available the Turnkey Asset Management Program models offered
by FWA’s related registered investment adviser, FamilyWealth Asset Management (“FWAM
”)1, as
explained in the subsection below entitled “Investment Programs.” The Platform enables the provision of
risk management techniques, facilitates a broad range of investment options, and supports better
relationships with Clients. The integrated Platform makes it easy to execute, manage and track Client
portfolios with:
• Client management: CRM technologies, Client profiling and asset allocation review;
• Investment management: Research, rebalancing, trade order and portfolio management;
• Performance monitoring: Data aggregation, reconciliation, performance reporting;
• Operational support: Back-office support, billing, compliance tools, websites and consultants; and
• Advisory Services Offerings.
The integrated Platform generally provides IARs:
• Access to multiple institutional asset allocation strategists (“Institutional Strategists”);
• Model portfolios designed to cover a number of standard risk/return profiles;
• Access to systems including tools for set-up of Client accounts, Client proposals, investment policy
statements, Client agreements and the ability to view and manage Client data;
• Research, timely information and recommendations regarding the qualifications, investment
philosophies, policies, and performance; and
• Preparation of periodic performance measurement reporting regarding Clients’ assets invested
through the Platform.
Dynamic asset management is a cornerstone of FWA’s investment philosophy. In practice, this means that
FWA creates investment strategies that cross over single asset class boundaries. This allows FWA to offer
1 FWAM refers to FamilyWealth Asset Management, LLC, which is FWA’s affiliated investment adviser that focuses
on operating the TAMP models. Such affiliation is also disclosed on FWA’s Form ADV Part I. Any Clients that utilize
the TAMP models should receive the Form ADV brochure of both FWAM and FWA.
portfolios that are structured so that a lack of performance in one asset class is offset by over-performance
in another asset class. We can invest in, and/or seek market opportunities in domestic and international
companies and markets, via direct or indirect market exposure/participation, to help FWA achieve global
diversification with the objective that no one market or asset impairs Clients’ ability to grow their capital.
By pairing dynamic asset management with the FamilyWealth™ Platform, we can better allocate a Client’s
investments across different classes and use excess returns in one asset class to protect against the
downsides in another asset class, without resorting to classes that have much higher volatility to achieve
desired returns.
The FamilyWealth™ Platform also provides retirement plan consulting and retirement plan management
services. These services encompass plan design, investment policy reviews, ERISA fiduciary services and
participant services, among other services.
We also may recommend insurance products as part of our overall advisory service.
We manage accounts on a discretionary and non-discretionary basis. If we manage your account on a
discretionary basis, then you have given us the authority to determine the following without your consent
for each transaction:
• Securities to be bought or sold for the account; and
• The amount of securities to be bought or sold for the account.
While we may have trading discretion on your account (e.g., placing trades in your account without your
approval), we are not authorized to withdraw any money, securities or other property from your account.
We may have to trade in your account to meet initial allocation targets, after substantial cash deposits
that require investment allocation, and/or after your request for a withdrawal that requires liquidation of
a position. Also, if there is inadequate cash balance in your account to pay for our investment adviser fees,
other liquidations may need to occur. Aside from deductions from the account for our fees, any monies
or securities withdrawn from the account may only be sent to you, for your benefit. Additionally, your
account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of
your investment program allocation. You will be responsible for any and all tax consequences resulting
from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax
advice; however, we will work with your tax professionals to assist you with tax planning. You will have
the opportunity to meet with us periodically to review the assets in your account.
1. Asset Management Services
Asset management is the professional management of securities (stocks, bonds, mutual funds, Exchange-
Traded Funds (“ETFs”) and other securities) and advice on non-securities assets (e.g., real estate), which
form part of your overall wealth/financial condition, in order to meet your specified investment goals.
With a Separately Managed Account (“SMA”), Clients engage us to assist in developing a personalized
asset allocation program and portfolio designed to meet the Client’s investment objectives. The
investments in the SMA may include, but are not limited to, mutual funds, stocks, bonds, equity options
and ETFs.
We provide investment advisory services to both retail Clients (smaller accounts of individuals, IRAs, trusts
& employee benefit plans) and institutional Clients (larger accounts of corporate pension plans, public
funds, foundations, & other tax-exempt entities).
We believe that a flexible and opportunistic investment approach is vital for investors seeking a balance
of risk and return. We also believe that a multi-asset class investment solution that dynamically adjusts to
global market conditions fill this need.
Investment Philosophy
When the outlook for fundamental investment strategies evolves, portfolios must be able to evolve and
adjust in an opportunistic and flexible manner to take advantage of market conditions. Portfolio Managers
(“Managers”) need to deliver expertise and utilize sophisticated technology systems that can manage risk
on an intraday basis, with deep, high-quality research across asset classes. Managers with multi-asset
expertise are especially relevant in today’s environment when investors are confronted with low expected
returns, low growth, and relatively over-valued assets with higher levels of volatility.
One of our objectives is to construct portfolios in a manner similar to pension funds, by thinking about
the objective of payment liabilities. Our focus is not only on accumulation, but distribution, and whether
the Client’s asset level will meet their income objective as well as their objective for asset transfer to their
heirs or charity. To achieve this goal, our philosophy is to blend passive, active, and alternative strategies.
Passive investing offers the advantage of cost efficiency and ease of understanding, while active and
alternative investments have the opportunity to generate excess return against its objective benchmark
over time but are more expensive and complicated.
Based upon the Client’s risk exposure, we allocate into a passive exposure with low cost and pair it with a
high conviction, high active-share strategy. We use passive strategies in markets where there is potentially
less excess return opportunity – for instance, U.S. Large cap stocks. Then, we “spend” or apportion both
risk and fee budget in parts of the market where there is opportunity – emerging markets, small cap and
alternative investments. The potential for outperformance is not merely because the market (i) misprices
small caps or emerging market stocks and (ii) is less efficient. It is predominantly dispersion. Dispersion
can be thought of as the spread between the best and the worst performance in the market.
Active management allows us to manage risk and downside protection. Investors can get the benefit of
lower fees in their core assets and pay active management fees for true active management that may
produce returns that exceed the market or allow for downside protection. Our investment philosophy
allows for a shift toward considering absolute risk and return, and active and passive strategies can be
used together to produce returns with appropriate risk. We believe absolute risk is more important than
relative risk when moving to a higher conviction equity strategy.
Advisory Services
The FamilyWealth™ Platform will assist FWA in providing the following services when contracted to do so
by the Client:
• Review your present financial situation;
• Monitor and track assets under management;
• Provide portfolio statements, periodic rate of return reports, asset allocation statements and
rebalancing activity as needed;
• Advise on asset selection;
• Determine market divisions through asset allocation models;
• Provide research and information on performance and fund management changes;
• Build a risk management profile for you;
• Assist you in setting and monitoring goals and objectives; and
• Provide personal consultations as necessary upon your request or as needed.
The Client shall have the ability to impose reasonable restrictions on the management of accounts,
including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These
restrictions may relate to a specific company security, industry sector, asset class, or any other restriction
requested that can be implemented in practice. The more specific the request, the more effective any
implementation could be. For example, rather than instructing us to avoid investing in “sin stocks,” it
would be easier to obtain specific industry guidance such as avoiding investment in tobacco companies.
Also, since mutual funds have broad exposure in many cases, it would be useful to know whether an
investment that creates investment exposure to the tobacco industry that is less than some de minimis
percentage (e.g., less than 5% of gross income of the operating company invested in ….) would still be
acceptable.
The Client must notify FWA promptly when such Client’s financial situation, goals, objectives, or needs
change.
Under certain conditions, securities from outside accounts may be transferred into your advisory account.
However, we may recommend that the Client sell any security if FWA believes that such security is not
suitable for the current recommended investment strategy. The Client and FWA may agree to exclude
such “legacy” assets from FWA’s fee invoice if such assets are not subject to ongoing advice and
management but are rather assets that the Client does not want to sell for personal reasons. However, if
the Client agrees to sell such assets, then the Client is responsible for any taxable events in these instances.
We do not provide tax advice or tax management services. While your account can be managed in a tax-
sensitive manner, and since we do not provide tax advice or tax management services, Clients should
always consult with a tax advisor for specific tax advice. Certain assumptions may be made with respect
to interest and inflation rates and the use of past trends and performance of the market and economy.
However, past performance is not a guarantee of future performance.
If the Client decides to implement our recommendations, we will help the Client complete the necessary
paperwork to open custodial account(s). Clients must send funds directly to the custodian.
The identity of your custodian will be communicated to you before the account is opened. You will enter
into a separate custodial agreement with the custodian. This agreement, among other things, authorizes
the custodian to take instructions from us regarding all investment decisions for your account. We will
select the securities bought and sold and the amount to be bought and sold, within the parameters of the
objectives and risk tolerance of your account. The custodian will effect transactions, deliver securities,
make payments and do what FWA instructs regarding transactions. The ability to change your address
shall, however, remain within your control, and, for regulatory reasons, FWA shall take the necessary
steps to prevent it from having the authority to change your address- of-record with the custodian; such
instructions should come directly from you. Also, for regulatory reasons, you should forward any
payments and securities directly to the custodian, and NOT to FWA. All checks and payment orders should
be made payable to the custodian or the issuer (such as a mutual fund, if FWA operationally enables such
“Application-Way” business). You will at all times maintain full and complete ownership rights to all assets
held in your account, including the right to withdraw securities or cash, proxy voting and receiving
transaction confirmations.
You will receive, at least quarterly, a statement containing a description of all the activity in your account.
This statement lists the total value at the start of the month, itemizes all transaction activity during the
month, and specifies the types, amounts, and total value of securities held as of the end of the month.
Your statement may be in either printed or electronic form based upon your preferences. Clients are
encouraged to review the statements from the custodians and inform FWA if any errors or anomalies are
found. Also, any statement provided by FWA is NOT the official statement of your investments (e.g., such
as the quarterly performance statements referenced below), but are provided as a courtesy. The
statement provided by the custodian(s) are your official statements of your investment positions and you
are encouraged to review them upon receipt.
When reviewing your account with your IAR, you may be provided a quarterly performance report. These
statements give you additional feedback regarding performance, and helps your IAR educate you about
our long-term investment philosophy, describe any changes in current strategy and allocation, along with
the reasons for making any changes.
We are available during normal business hours either by telephone, email, or in person by appointment
to answer your questions. We will meet with you to discuss your financial circumstances, investment goals
and objectives, and to determine your risk tolerance. Our meeting will include your completion of a Risk
Tolerance Questionnaire and providing other information in order to generate an Investor Policy
Statement, which will assist us in defining/ascertaining your financial objectives and other relevant
parameters for us to advise or manage your account. We will ask you to provide statements summarizing
current investments, income and other earnings, recent tax returns, retirement plan information, other
assets and liabilities, wills and trusts, insurance policies, and other pertinent information as applicable.
Based on the information you share with us, we will analyze your situation and recommend an appropriate
asset allocation or investment strategy using the Platform. Once accounts have been set up, we have
access to comprehensive data, and can track Clients’ portfolios against their own goals, rather than just
broad benchmarks, while enhanced reporting allows us to revise or redirect plans and strategies along
the way.
Our recommendations and ongoing management are based upon your investment goals, objectives, risk
tolerance, and the investment portfolio you have selected. We will monitor the account, trade as
necessary, and communicate regularly with you. Your circumstances shall be monitored in quarterly and
annual account reviews by your IAR. These reviews will be conducted in person, by telephone conference,
and/or via a written inquiry/questionnaire. We will work with you on an ongoing basis to evaluate your
asset allocation, as well as rebalance your portfolio when warranted to maintain alignment with your
investment objectives. If the IAR determines that your portfolio materially deviates from the target
allocation or an allocation deemed more desirable in light of current market conditions, the IAR may
rebalance your portfolio.
2. Investment Programs
The Platform offers IARs an opportunity to provide Clients with an effective and efficient asset
management system and allows them to focus on Client service functions instead of managing individual
investments. Our investment programs can be considered as falling into the following service models:
The Platform helps IARs and advisers to deliver customized solutions, ranging from adviser–managed or
third-party managed solutions, including strategists and separate account managers. As a one stop
platform, the Platform makes it easy to execute, manage and track Client portfolios with:
FamilyWealth™ Portfolio Manager
TAMP
Third Party Institutional Strategists
Third Party Separate Account Managers
Overlay Management
Family CIO Services
Solicitors
Institutional Services
Financial Planning/Consulting
• Quarterly performance reports (branded with IAR or registered investment adviser firm
information when applicable);
• Investment Policy Statements (“IPS”) and proposal generator;
• Advisor as manager, including model level management; and
• Online pre-populated paperwork.
We obtain information from a wide variety of publicly available sources. We do not have any inside, non-
public information about any investments that are recommended. All recommendations developed by us
are based upon our professional judgment. We cannot guarantee the results of any of our
recommendations. If your account is management on a “non-discretionary” basis, choosing which advice
to follow is your decision. Also, for accounts managed on a discretionary basis, you can choose which
discretion, and how much discretion to provide to your IAR, and can revoke such decisions at any time by
written notification.
FamilyWealth™ Portfolio Manager
FamilyWealth offers access to several levels of asset management through the FamilyWealth™ Portfolio
Manager, also known as Rep as Portfolio Manager (“RPM”). These options offer greater or lesser degrees
of management and sophistication, and differ in terms of type of investments offered, the asset
management firm’s responsibilities, overlay capabilities, and costs. By offering each of these options
through a single platform, advisers and firms can efficiently service a broad spectrum of Clients, from
mass-market to mass-affluent and all the way up to ultra-high- net-worth individuals and households. The
FamilyWealth™ Platform makes sophisticated solutions a realistic option for nearly any investor and
provides IARs with the tools they need to reach many segments of the market with a high degree of choice.
In using the Platform, Clients pay a fee to use the Platform to FWAM, FWA’s affiliated investment adviser.
FWA provides certain services to Clients’ accounts that are opened through the Platform. These services
generally include:
• Exercising discretion on whether, how and when to implement transactions in a Client’s account
based on the Strategist(s), Manager(s), and type of account(s) selected by IAR and Client; and
• Arranging for the execution of trades in Clients’ accounts (except for accounts invested in
Separately Managed Account Portfolios.
A Client’s IAR is generally responsible for:
• Ensuring Client portfolios are not only suitable for the Client, but designed for the best interests
of the Client, considering the investment objectives, goals, risk tolerance, liquidity needs, etc.,
both initially and going forward; and
• Selecting and changing the Strategists and Managers in Clients’ accounts that we make available
through the Platform in accordance with such objectives and goals.
Clients should carefully review the executed investment management agreement with their IAR, FWA’s
disclosure brochure, and the brochure supplement of the IAR. Also, you should receive and review our
Form CRS, which is a succinct disclosure form required of registered investment advisers. The IAR is
responsible for delivering these items to each Client, in addition to determining the suitability of Platform
services, Strategists, Managers, and the type of accounts listed below for their Clients.
Mutual Fund Allocation Portfolio Strategy: The most basic type of portfolio is the mutual fund allocation,
in which multiple mutual funds are selected from a broad array (based on asset allocation guidelines) and
managed as a single account. This method provides transparency and simplicity, offering an alternative to
upfront commissions or surrender charges. In this approach, our investors may utilize the mutual
fund/TAMP platform of FWAM, our affiliated investment adviser, and pay a platform fee to FWAM to
access those mutual funds and any associated investment models and/or support services.
Exchange-Traded Fund (ETF) Allocation Portfolio Strategy: The next level of an outsourced portfolio
solution is the ETF portfolio strategy. In this type of account, investments are held solely in ETFs, while
portfolio construction is based on an asset allocation model and is monitored in light of market changes.
The fee is asset-based, and the adviser typically pays for transaction costs. ETFs often have lower expense
ratios than mutual funds and offer added benefits such as intraday trading and tax efficiencies.
Separately Managed Account (SMA): SMA is a portfolio of individual securities managed by a single
investment manager in a particular type of style and offered to the investor by a sponsoring firm. A fee-
based SMA program can utilize multiple SMAs, while a single SMA can also form a single “sleeve” within
a Unified Managed Account structure (discussed below). In general, the main difference between an SMA
and a mutual fund is that, in the former, the investor directly owns the securities instead of owning a
share in the pool of securities.
Unified Managed Account (UMA): Offering a much higher level of sophistication is the UMA, which is a
single fee-based account that combines numerous investment products within separate account sleeves.
Offering a UMA requires that the IAR manage the Client on a platform optimized for UMAs. Management
between sleeves can then be determined by an overlay process to help gain tax and trading efficiencies.
UMAs typically are held by a single custodian, but the FamilyWealth™ Platform allows for aggregation
across multiple custodians.
Unified Managed Household Account (UMHA): The last level is the UMHA, which is similar to the UMA
except that it brings together all aspects of a Client household’s wealth, not just that of a single individual.
UMHA platforms allow for a more holistic approach that better mirrors how a wealthy household tends
to think about its wealth. It can encompass all of the following: qualified and nonqualified accounts;
alternative investments; real estate; collectibles; oil and gas partnerships; limited partnerships; managed
futures accounts; and
more. The UMHA has a single registration and can aggregate across multiple
custodians and could be considered as the pinnacle of service in managed accounts. The holistic view that
is provided by this aggregation can allow advisers or IARs to charge fees on held-away assets that come
under their reporting and overview capabilities/responsibilities. Growth in both UMAs and UMHAs will
likely accelerate among high-net-worth Clients due to their preference for and the benefits of holistic
wealth management.
Turnkey Asset Management Program
Clients who use the FWAM Turnkey Asset Management Program (“TAMP”) models will be considered
Clients of both FWA and FWAM. FWAM operates the models and FWA either (i) serves as a portfolio
manager for the Clients using the models, or (ii) FWA could merely conduct initial Client profiling. Both
FWAM and FWA provide continuous and regular supervisory services. The Client can defer to FWAM for
ongoing services, such as acting as the portfolio manager and operator of the models, In other words,
when FWA recommends a Client use the FWAM TAMP program, IARs of FWA may serve as a portfolio
manager to make their own product recommendations to fulfill the model parameters (developing
customized portfolios), or may defer to FWAM (a) to manage the accounts according to the model’s
parameters and (b) select the products determined by FWAM to fulfill the model parameters. In both
cases, FWA would take care of the Client “onboarding,” assessment of the investment objectives, risk
tolerance and other customers-specific needs, whereas FWAM would have a relationship with the Client
insofar as it would implement the models for each account that utilizes the models.
The TAMP helps advisers/IARs to deliver customized solutions, whether they are adviser-managed or
third-party managed, including strategists and separate account managers. The TAMP makes it easy to
execute, manage and track Client portfolios with:
• Professional, private-labeled Website, plus proposals and quarterly performance reports branded
with separate registered investment adviser’s data or may be personalized for IARs of
FWA/FWAM Clients;
• Private-labeled proposal generator;
• IAR as manager, including model level management;
• Innovative time-savers, including an online proposal generator and pre-populated paperwork;
and
• Dynamic, private-labeled performance reporting.
Through this TAMP, we provide the following areas of expertise and the ability for registered investment
advisers to use in delivering high quality services to Clients:
• Client management: CRM technologies, Client profiling and asset allocation review;
• Investment management: Research, rebalancing, trade order and portfolio management;
• Performance monitoring: Data aggregation, reconciliation, performance reporting; and
• Operational support: Back-office support, billing, compliance tools, websites and leads to
consultants for additional support.
The Platform generally includes:
• Access to multiple Institutional Strategists;
• Model portfolios designed to cover a number of standard risk/return assumptions;
• Access to software including tools for onboarding Client accounts, Client proposals, Investment
Policy Statements, Client agreements and the ability to view and manage Client data;
• Research, timely information and recommendations regarding the qualifications, investment
philosophies, policies and performance;
• Preparation of periodic performance measurement reporting regarding Clients’ assets invested
through the TAMP.
FWAM provides certain services to the Client accounts that are opened through the TAMP. These services
include:
• Exercising discretion on whether, how and when to implement transactions in a Client’s
account based on the model(s) selected by adviser or IAR and the Client; and
• Arranging for the execution of trades in Client’s accounts (except for accounts invested in SMA
portfolios.
A Client’s IARs are generally responsible for:
• Ensuring Client suitability and determining Client investment objectives and goals, both initially
and on an ongoing basis; and
• Selecting and changing the individual securities or model portfolio(s) in Client's account(s) that
we make available through the TAMP in accordance with such objectives and goals.
Clients should carefully review the executed investment management agreement with their IAR, as well
as the brochure for the registered investment adviser that introduced the account to FWAM and the
TAMP models. The IAR is responsible for delivering these items to each Client.
FWAM manages the TAMP models. FWAM’s Investment Committee evaluates and selects the
investments to be used by the models, including target allocation and cash levels as determined by the
portfolio’s investment guidelines.
These models offer investment opportunities for particular asset allocation strategies. Assets may be
invested in a range of market sectors and/or asset classes (e.g., large cap, small/med cap, international or
high yield income) represented by any number of underlying funds (typically at least five at any given
time).
It is anticipated that any given time, the underlying funds in which the model invests may fall anywhere
on the entire spectrum of asset classes and sectors currently available. At any given time, an underlying
equity fund in which the models invest may buy “growth” or “value” stocks, or some combination of both.
FWAM reviews and rebalances the underlying funds in which the model invests, as may be necessary, to
reflect its current analysis of the approximate mix of assets among and within asset classes and sectors.
FWAM monitors the investment objectives at the model level and assesses model effectiveness and
predictable and reliable investment results. As a means to pursue various investment objectives, the
models themselves are intended to be used so that invested assets remain fully invested in shares of
underlying investment companies at all times, unless or until, of course, they are no longer suitable for
the underlying investor. The models may, however, pursue an investment strategy of investing its assets
directly in securities in lieu of indirect investment through other investment companies. The model’s
direct investment will remain consistent with its asset allocation strategy and, in the case of collectively
managed investments such as mutual funds, will typically be close or identical to those securities held by
one or more of the underlying funds in which the models currently invest. In addition, under adverse
market or other conditions, the models may adopt a temporary defensive position and invest a portion of
its assets in cash or similar investments.
These models may be appropriate for advisers and Clients that do not have the time or the experience to
choose from a list of mutual funds and create their own portfolios that offer a single investment option
blended with stocks, bonds, and short-term investments. Choosing a managed portfolio can provide an
easy solution to Clients who want the convenience of professional management, including asset
rebalancing and professional oversight.
Third Party Institutional Strategists
Some of the Managers available on the Platform are accessed through the use of Third-Party Institutional
Strategists (“Strategists”) where an asset manager constructs an asset allocation and selects the
investments for each portfolio model. FWA may provide overlay management by implementing trade
orders and periodically updating and rebalancing the models per the direction of the third-party manager.
Strategists are subject to change and may not always be available on the Platform.
Third Party Separate Account Managers
SMA Managers construct portfolios of individual securities with a specific objective, style and risk. Clients
may utilize multiple SMA Managers, while a single SMA can also form a single “sleeve” within an UMA
structure. FWA may provide overlay management by implementing trade orders and periodically updating
and rebalancing the models per the direction of the third-party manager. Third Party SMA Managers are
subject to change and may not always be available on the Platform.
Overlay Management
FWA provides overlay management services utilizing the Platform to track a Client’s combined position
from the separately managed accounts. Clients utilizing different Managers can create inefficiencies and
increase the risk to the overall portfolio, have negative tax effects, or unbalance the Client’s positions.
Any possible portfolio adjustment will be analyzed by the Platform, which ensures the overall portfolio
will remain in balance and prevent any inefficient transactions from occurring.
Family CIO Services
By monitoring the household account, FWA can address the complexities of high-net-worth families
working with different custodians and advisers. We will diligently advise and manage aggregate household
wealth as well as serve as sleeve and portfolio managers in each account. FWA may or may not make
tactical investment allocations for certain parts of the overall household assets, but by maintaining a view
of how the disparate parts are affecting each other, we can help families make important decisions for
household asset allocation.
Solicitors
For Clients referred to us by a solicitor, the Client will enter into an investment management agreement
directly with FWA and FWA will be the adviser. If FWA utilizes a solicitor, and pays a fee for such
solicitations, then you should receive from the IAR/solicitor a separate “Solicitor Disclosure Statement”
regarding the arrangement and the fees. For these Clients, FWA will provide the services outlined above,
which include, but are not limited to:
• Determining suitability of the Strategist(s), Manager(s), and type of accounts selected by the
Client;
• Exercising discretion regarding whether, how and when to implement transactions in a Client’s
account based on the Strategist(s) and Manager(s) selected by the Client;
• Arranging for the execution of trades in Clients’ accounts (except for accounts invested in SMAs,
as described above); and
• The complete services provided by FWA as the adviser will be explained in the
• Agreement executed between FWA and the Client.
Depending on the type of arrangement made between FamilyWealth℠ and the Solicitor, the Solicitor may
assist the Client in completing account applications and other applicable forms and submit them to FWA.
The Solicitor, if properly licensed to provide advice, may obtain information from the Client regarding the
Client’s investment objectives and financial situation and may assist the Client in determining a suitable
Strategist(s), Manager(s), and type of account(s) based on such objectives and financial information. On
the other hand, if the Solicitor is not registered (meaning the Solicitor is not an IAR), then the Solicitor
may only provide Solicitor disclosure information and then “step away” – referring the Client to FWA. In
either case, the Client is ultimately responsible for making the final selection of Strategist(s), Manager(s),
and type of account(s). The Client is further responsible for promptly notifying FamilyWealth℠ in writing
of any change in the Client’s investment objectives, financial situation, and/or the selection of
Strategist(s), Manager(s) and type of account(s).
For Clients referred to FWA by a Solicitor, FWA reserves the right not to accept and/or terminate the
account if FWA believes at any time, based on information provided by the Client, that the Strategist(s),
Manager(s), and type of account(s) selected by the Client is neither suitable, nor in the best interest of
the Client. Furthermore, FWA will honor the Client’s decision to not change the selection of Strategist(s),
Manager(s), or account types, at the Client’s sole discretion.
Institutional Services
If you are an institutional Client, your accounts are managed in accordance with the investment objectives,
guidelines & restrictions you establish. Purchases and sales of securities for your accounts are executed
by either broker-dealer firms we select or broker-dealers that you request. We generally impose a
minimum dollar amount of $500,000 of assets for institutional accounts, although smaller accounts may
be accepted depending upon the specific circumstances of an account.
Financial Planning/Consulting
We do not have a significant amount of Clients seeking comprehensive financial planning, but, in select
cases, we provide comprehensive financial planning, estate planning, business planning and educational
planning. Fee-based financial planning is a comprehensive relationship that incorporates many different
aspects of your financial status into an overall plan that is tailored to meet your goals and objectives. The
financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or
your other advisors (attorneys, accountants, etc.), as necessary. If you utilize only financial planning
services, and not continuous and regular management services, then the fiduciary duty of FWA ceases
upon the delivery of the financial plan. If FWA is being requested to make an initial asset allocation based
upon the financial plan, but not provide continuous and regulatory management services, then the
fiduciary duty ceases upon making the initial asset allocation.
In performing financial planning services, we typically examine and analyze your overall financial situation,
which may include issues such as taxes, insurance needs, overall debt, credit, business planning,
retirement savings and reviewing your current investment program. Our services may focus on all or only
one of these areas depending upon the scope of our engagement with you.
It is essential that you provide the information and documentation we request regarding your income,
investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and
goals, but you are obligated to inform us of any changes. We do not verify any information obtained from
you, your attorney, accountant or other professionals.
If we engage in such services in the future, and if you engage us to perform these services, you will receive
a written agreement detailing the services, fees, terms and conditions of the relationship. You will also
receive this brochure. You are under no obligation to implement recommendations through us. You may
implement your financial plan through any financial organization of your choice.
Other Services
Through our IARs who may be licensed independently as an insurance agent, or through Family Wealth
Agency, LLC (“FW Agency”), Client may purchase insurance products. FW Agency is a separate, but
affiliated company of FWA. Through one of those two (2) avenues, our personnel may recommend and
sell life, annuity, disability, and long-term care insurance. In those cases, either the IAR, as an independent
insurance agent, or FW Agency will receive the usual and customary commissions associated with these
sales from the insurance company. You will not pay a separate investment advisory fee for these
assets/products. Also, your advisory fee will not be reduced by any payments we receive from these sales.
3. Retirement Plan Consulting
For FWA’s Retirement Plan accounts, our service begins with an analysis of the current retirement plan
structure, custodian, third party administrator, daily recordkeeper, investments, managed investment
models, and fees. The analysis is designed to determine if we are able to add value to the plan and, if so,
in what areas. We also comment if we feel the plan maybe deficient from both a regulatory perspective
and from a financial advisory perspective.
We will offer you one or more of the following services:
• Plan design and asset selection consultation;
• Develop and annually review an IPS;
• Develop an investment menu according to the IPS;
• Review plan sponsor’s stated financial criteria for each investment option;
• Monitor each investment option according to the IPS;
• Quarterly portfolio statements, rate of return reports, asset allocation statements;
• Provide investment research and performance information on investment options;
• Investment option replacement guidance;
• Personal consultations with the plan sponsor, as necessary;
• Advise on or develop and plan the Investment Committee Charter, as needed;
• Fiduciary due diligence assistance;
• Attendance at Plan Committee and other meetings;
• Annual Fiduciary Plan Review;
• Fiduciary education services to Plan Committee;
• Participant education, guidance, and enrollment;
• Vendor coordination assistance; and
• Benchmarking services.
ERISA Fiduciary Services
When delivering Employee Retirement Income Security Act of 1974, as amended (“ERISA”) fiduciary
services, we will perform those services for the retirement plan (“Plan”) as a fiduciary under ERISA Section
3(21)(A)(ii) or 3(38) and will act in good faith and with the degree of diligence, care and skill that a prudent
person rendering similar services would exercise under similar circumstances. Such Plan fiduciary
designation must be reflected by the Plan Administrator or by the Plan itself in a formal designation of
role, and, in those cases, FWA requires a separate Plan Fiduciary Agreement.
In our capacity as an ERISA Plan fiduciary, we will conduct research to determine the core investment
options for the Plan. We will consider the size of the Plan, number of participants, and the demographics
of the employees to assist the Plan sponsor in determining the appropriate investment(s) options for the
Plan.
In our capacity as a Plan fiduciary, we will select a diverse core of investment options. We will monitor
and change the investment options included in the Plan offered to Plan Participants from time-to-time as
determined by us, solely in our discretion. The investment options will generally include multiple asset
classes of mutual funds, SMAs and ETFs.
We also encourage Plan sponsors to consult with other professional advisors since we do not provide tax
or legal advice that may affect asset classes or allocations. We will apply any guidelines our Client supplies,
as directed. However, compliance with these restrictions or guidelines is our Client’s responsibility.
Plan Structure
We will assist our Client in evaluating the current Plan’s structure to determine if a change in the design
of the Plan better suits the needs of Plan participants. We will facilitate any changes with the appropriate
parties, including the third-party administrator, recordkeeper, and custodian, as well as facilitating the
execution of the required Plan document amendments or new Plan documents. However, we will not
draft any Plan amendments; a Third-Party Administrator (“TPA”) will need to perform this service.
Investment Committee
If FWA deems that the establishment of an Investment Committee (“Committee”) is appropriate for you,
FWA will assist you in establishing such Committee, in addition to establishing a formal Committee
Charter, delineating Committee responsibilities, determining fiduciary roles and the scope of such roles.
The Committee may be charged with the fiduciary responsibility of the prudent selection and oversight of
the investment options, selecting and retaining professional advisors for the Plan, including investment
managers, recordkeeper, custodians, TPAs, and the establishment, execution, and interpretation of an IPS
for the Plan.
Investment Policy Statement Service
FamilyWealth’s Investment Policy Statement Service is designed to assist you in creating a written IPS to
document the Plan’s investment criteria, demographics, goals and objectives, as well as certain policies
governing the investment of assets. The IPS serves as a guide to assist the Committee in effectively
supervising, monitoring, and evaluating the investment of the Plan’s assets.
It is the Client’s responsibility to provide all necessary information for the preparation of the IPS,
particularly any limitations imposed by law or otherwise. This draft IPS is then submitted to you for review
and approval. It is the Client’s responsibility to confirm the Committee’s acceptance of the IPS, and it is
the Committee’s responsibility to adhere to the IPS in managing the Plan. We encourage you to review
accounts periodically to verify Committee’s compliance with the IPS.
Investment Selection, Monitoring, and Replacement
As the fiduciary under ERISA Section 3(21)(A)(ii) or 3(38) to the Plan, we will assist the Committee in
selecting the core investment line up, including evaluating SMA Managers, mutual funds, ETFs, Collective
Investment Trusts and money market funds which may be retained or replaced.
Past performance of the core investment options and the indices that correspond to the core investment
options may not be representative of actual performance, or indicative of future performance. Before a
specific investment is selected, other factors such as fiscal and economic trends, which may influence the
choice of investments and risk tolerance, should be considered. We have the responsibility and authority
to recommend the investment options/recommendations, including evaluating investment managers and
SMA Managers, mutual funds, ETFs, Collective Investment Trusts, and money market funds, which may
be retained or replaced. The Plan sponsor has the responsibility and authority to make the final decision
regarding which investments to include in the model portfolio and when to add or exclude a specific
security.
It is the Client’s responsibility to select the final mix and to determine whether to implement any strategy.
We will apply guidelines you supply, as directed; however, compliance with these restrictions or guidelines
is the Client’s responsibility.
We will also monitor the current core investment options, including the investment’s performance,
performance compared to an applicable benchmark index, fees, management changes, style and
fundamental investment strategy changes, and fund composition to determine if an investment no longer
meets the criteria defined in the IPS. If the Committee determines that a core investment option no longer
meets the IPS criteria, we will advise the Committee on possible alternatives and assist in the selection of
a replacement investment.
Participant Meetings
We may conduct Plan participant meetings when a change is made either to the structure of the Plan or
if the investment options being recommended/considered would change as a result of the decisions of
the Committee. We will:
• detail the changes being made or proposed;
• assess how they affect the current participants;
• review the current investment opportunities;
• assess how participants may make changes to their investment selections; and
• Strive to provide meaningful answers to any and all questions a participant may have.
Reporting
We will send an annual Plan criteria report detailing the overall performance of the Plan’s core investment
options and a detailed list of investments passing or failing the IPS criteria.
4. Assets Under Management
As of December 31, 2023, we had approximately $316,315,560 in assets under management, of which
$107,911,487 were managed in a discretionary manner, and $208,404,073 were managed in a non-
discretionary manner.
5. ERISA Fiduciary
FWA understands and attests that they are an ERISA fiduciary as defined in the Fiduciary Rule under ERISA
and the Internal Revenue Code of 1986. FamilyWealthsm adheres to Best Interest and Impartial Conduct
Standards.
FWA may act as a discretionary investment manager of a Plan as defined in Section 3(38) of ERISA.
FWA may act as a non-discretionary investment manager of a Plan as defined in Section 3(21) of ERISA.