A. Firm Information
Principle Wealth Partners LLC (“PWP” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). PWP was organized as a Limited Liability Company (“LLC”)
under the laws of the State of Connecticut in 2017. PWP is owned and operated by Robert S. Paolucci (Founder
and Chief Executive Officer). This Disclosure Brochure provides information regarding the qualifications,
business practices, and the advisory services provided by PWP. For information regarding this Disclosure
Brochure, please contact Michael J. Castiello, Chief Compliance Officer, at (203) 318-8892 or by email at
[email protected].
B. Advisory Services Offered
PWP offers investment advisory services to individuals, high net-worth individuals, trusts, estates, retirement
plans and corporations (each referred to as a “Client”).
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 towards each Client and seeks to mitigate potential
conflicts of interest. PWP’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.
Wealth Management Services
PWP may provide Clients with wealth management services, which generally includes a broad range of
comprehensive financial planning and consulting services in connection with discretionary management of
investment portfolios. These services are described below.
Investment Management Services – PWP provides customized investment advisory solutions for its Clients. This
is achieved through continuous personal Client contact and interaction while providing investment management
and related advisory services. PWP 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. PWP will then
construct an investment portfolio, consisting of diversified mutual funds, exchange-traded funds (“ETFs”) and
individual stocks to achieve the Client’s investment goals. The Advisor may also utilize bonds, alternative
investments and margin to meet the needs of its Clients. The Advisor may retain certain legacy investments
based on portfolio fit and/or tax considerations.
PWP, in very limited circumstances, will retain mutual funds on a fund by fund basis. Due to specific custodial,
platform and/or mutual fund company constraints and/or material tax consideration, PWP will retain a mutual
fund share class that does not have trading costs, but do have higher internal expense ratios than institutional
share classes. PWP 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.
PWP’s investment approach is primarily long-term focused, but 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. PWP
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.
PWP evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. The Advisor may recommend employing cash positions as a possible hedge against market
movement. PWP may recommend selling 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.
Phone: (203) 318-8892 * Fax: (203) 318-8898
https://principlewealthpartners.com
Page 5
At no time will PWP 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 agreement, please see Item 12 – Brokerage Practices.
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 a 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 will earn a
new (or increase 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.
Financial Planning Services – PWP will typically provide a variety of financial planning and consulting services to
Clients, as part of its wealth management services. PWP may also provide standalone financial
planning
pursuant to a written 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 and other areas of a Client’s financial situation.
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, insurance needs, goal based planning, tax and estate planning, establish education savings
and/or charitable giving programs.
PWP may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. 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 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.
Use of Independent Managers – When deemed to be in the Client’s best interest, PWP will recommend that a
Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent
Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to
authorize and enter into an advisory agreement with the Independent Manager[s] that defines the terms in which
the Independent Manager[s] will provide investment management and related services. The Advisor may also
assist in the development of the initial policy recommendations and managing the ongoing Client relationship.
The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent
Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’
investment objectives and overall best interests. The Client, prior to entering into an agreement with an
Madison, CT 06443
Phone: (203) 318-8892 * Fax: (203) 318-8898
https://principlewealthpartners.com
Page 6
Independent Manager, will be provided with the Independent Manager’s Form ADV 2A (or a brochure that makes
the appropriate disclosures).
Retirement Plan Advisory Services
PWP 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 and its Plan Participants. 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 (“IPS”) Design and Monitoring
• Investment Management Services (ERISA 3(38))
• Investment Oversight Services (ERISA 3(21))
• Ongoing Investment Recommendation and Assistance
These services are provided by PWP serving in the capacity as 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 PWP’s fiduciary status, the specific services to be rendered and
all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging PWP to provide investment advisory services, each Client is required to enter into an
agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
• Establishing an Investment Strategy – PWP, in connection with the Client, may develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – PWP will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance of risk for each Client.
• Portfolio Construction – PWP will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – PWP will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
PWP does not manage or place Client assets into a wrap fee program
E. Assets Under Management
As of December 31, 2023, PWP manages $2,222,598,130 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.