A. Firm Information
Affinity Wealth Management LLC (“AWM” or the “Advisor”) is a registered investment advisor with the U.S
Securities and Exchange Commission (“SEC”). AWM is organized as a Limited Liability Company (LLC) under
the laws of the State of Delaware. AWM was founded in October 2017, and is owned by The Wealth Design
Group, Inc. AWM is operated by Michael Sicuranza, CFP® (Chief Executive Officer and Chief Compliance
Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by AWM.
B. Advisory Services Offered
AWM offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
corporations, and retirement plans (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. AWM’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
AWM provides wealth management services for its Clients. These services generally include a broad range of
comprehensive financial planning in connection with discretionary investment management of Client portfolios.
These services are described below.
Investment Management Services- AWM provides customized investment advisory solutions for its Clients. This
is achieved through continuous personal Client contact and interaction while providing discretionary and non-
discretionary investment management and related advisory services. AWM 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. AWM will either construct a portfolio or place assets in investment models, consisting of mutual
funds, exchange-traded funds (“ETFs”), bonds, and/or individual stocks to achieve the Client’s investment goals.
The Advisor may also utilize CDs, foreign securities, REITs and other investments to meet the needs of its
Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
AWM’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. AWM
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.
AWM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. AWM may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. AWM may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement. AWM 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.
At no time will AWM 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 their designated account[s] at the
Custodian, pursuant to the Client investment advisory 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
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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 - AWM will typically provide a variety of financial planning and consulting services to
Clients, pursuant to a written financial planning agreement or part of its overall wealth management service.
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, estate planning, cash flow analysis, education savings, insurance needs 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, establish education savings and/or charitable giving programs.
AWM 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 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 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.
Financial Institution Consulting Services
AWM provides investment consulting services to brokerage customers (herein “Brokerage Customers”) of Mutual
Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s consulting
services, pursuant to a written agreement with AWM. Consulting services are strictly on products where MSI
serves as the broker-dealer. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional
details.
Retirement Plan Advisory Services
AWM provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”), pursuant to the terms of the retirement plan advisory agreement. The Advisor’s
retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to
the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally
include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
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• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight Services (ERISA 3(21))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
Retirement plan advisory services are provided by AWM 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 AWM‘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 AWM to provide investment advisory services, each Client is required to enter into one or more
agreements 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 – AWM, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – AWM will develop a strategic asset allocation or place assets in appropriate model
portfolios that are targeted to meet the investment objectives, time horizon, financial situation and
tolerance for risk for each Client.
• Portfolio Construction and Model Portfolios – AWM will develop a custom portfolio for the Client or place
assets in a model portfolio that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – AWM will provide investment management and ongoing
oversight of the Client’s relationship’s investment portfolio.
D. Wrap Fee Programs
The Advisor no longer offers a Wrap Fee Program to new Clients, however, the Advisor has certain legacy
Clients where securities transaction fees are combined with investment advisory fee into a single asset-based
fee. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor sponsors
the AWM Wrap Fee Program 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 a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2023, AWM manages $699,596,531 in Client assets, $675,853,185 of which are managed
on a discretionary basis and $23,743,346 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.