The Signature Wealth Management Partners Wrap Program (the “Program”) is an investment advisory
program sponsored by SWMP. In addition to the Program, the Firm offers a variety of advisory services,
which include financial planning, consulting, and investment management services under different
arrangements than those described herein. Prior to SWMP rendering any of the foregoing advisory services,
clients are required to enter into one or more written agreements with SWMP setting forth the relevant
terms and conditions of the advisory relationship (the “Advisory Agreement”).
SWMP filed for registration in July 2018 and is wholly owned by Elizabeth Emr and Gregory Emr. As of
December 29, 2023, SWMP had $332,619,634 in assets under management, all of which was managed on
a discretionary basis. While this brochure generally describes the business of SWMP, certain sections also
discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or
other persons occupying a similar status or performing similar functions), employees or any other person
who provides investment advice on SWMP’s behalf and is subject to the Firm’s supervision or control.
Description of the Program
The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain
investment products without incurring separate brokerage commissions or transaction charges. A wrap fee
program is considered any arrangement under which clients receive investment advisory services (which
may include portfolio management or advice concerning the selection of other investment advisers) and the
execution of client transactions for a specified fee or fees not based upon transactions in their accounts.
Clients must also open a new securities brokerage account and complete a new account agreement with
Schwab Advisor ServicesTM (“Schwab”), or another broker-dealer that SWMP approves under the Program
(collectively “Financial Institutions”).
At the onset of the Program, clients complete an investor profile describing their individual investment
objectives, liquidity and cash flow needs, time horizon and risk tolerance, as well as any other factors
pertinent to their specific financial situations. After an analysis of the relevant information, SWMP assists
its clients in developing an appropriate strategy for managing their assets. Clients’ investment portfolios are
generally managed on a discretionary basis by either SWMP’s investment adviser representatives or an
independent investment manager (collectively “Independent Managers”), as selected by SWMP. SWMP
and/or the Independent Managers generally allocate clients’ assets among the various investment products
available under the Program, as described further in Item 6 (below).
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Financial Planning and Consulting Services
SWMP offers clients a broad range of financial planning and consulting services, which includes any or all
of the following functions:
• Business Planning
• Cash Flow Analysis
•
Education Planning
• Trust and Estate Planning
• Investment Consulting
• Protection Planning (Insurance)
•
Retirement Projections and Planning
• Tax Analysis
While each of these services is available on a stand-alone basis, certain of them can also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, SWMP is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely
on such information. SWMP recommends certain clients engage the Firm for additional related services,
its Supervised Persons in their individual capacities as insurance agents or registered representatives of a
broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a
conflict of interest exists for the Firm to recommend that clients engage SWMP or its affiliates to provide
(or continue to provide) additional services for compensation, including investment management services.
Clients retain absolute discretion over all decisions regarding implementation and are under no obligation
to act upon any of the recommendations made by SWMP under a financial planning or consulting
engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any
change in their financial situation or investment objectives for the purpose of reviewing, evaluating or
revising SWMP’s recommendations and/or services.
Wealth Management Services
SWMP provides certain clients with wealth management services which includes a broad range of
comprehensive financial planning and consulting services as well as discretionary management of
investment portfolios.
SWMP primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”),
individual debt and equity securities, structured notes and certificates of deposit (“CDs”) and independent
investment managers (“Independent Managers”) in accordance with their stated investment objectives.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios. Clients can engage SWMP to manage and/or advise on certain investment products
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that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and
assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these
situations, SWMP directs or recommends the allocation of client assets among the various investment
options available with the product. These assets are generally maintained at the underwriting insurance
company or the custodian designated by the product’s provider.
SWMP tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.
SWMP consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios.
Clients are advised to promptly notify SWMP if there are changes in their financial situation or if they wish
to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions
or mandates on the management of their accounts if SWMP determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly burdensome to the
Firm’s management efforts.
Use of Independent Managers
As mentioned above, SWMP selects certain Independent Managers to actively manage a portion of its
clients’ assets. The specific terms and conditions under which a client engages an Independent Manager
may be set forth in a separate written agreement with the designated Independent Manager. In addition to
this brochure, clients may also receive the written disclosure documents of the respective Independent
Managers engaged to manage their assets.
SWMP evaluates a variety of information about Independent Managers, which includes the Independent
Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and
other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the
Independent Managers’ investment strategies, past performance and risk results in relation to its clients’
individual portfolio allocations and risk exposure. SWMP also takes into consideration each Independent
Manager’s management style, returns, reputation, financial strength, reporting, pricing and research
capabilities, among other factors.
SWMP continues to provide services relative to the discretionary selection of the Independent Managers.
On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent
Managers. SWMP seeks to ensure the Independent Managers’ strategies and target allocations remain
aligned with its clients’ investment objectives and overall best interests.
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Fees for Participation in the Program
The Program is offered on a fee basis, which includes fixed fees, as well as fees based upon assets under
management (sometimes referred to as the “Program Fee”). Additionally, certain of the Firm’s Supervised
Persons, in their individual capacities, offers securities brokerage services and/or insurance products under
a separate commission-based arrangement.
Financial Planning and Consulting Fees
SWMP charges a fixed fee for providing financial planning and consulting services under a stand-alone
engagement. These fees are negotiable, but range from $1,000 to $5,000, depending upon the scope and
complexity of the services and the professional rendering the financial planning and/or the consulting
services. If the client engages the Firm for additional investment advisory services, SWMP may offset all
or a portion of its fees for those services based upon the amount paid for the financial planning and/or
consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement and SWMP requires one-half of the fee (estimated hourly or fixed) payable upon
execution of the Advisory Agreement.
The outstanding balance is due upon delivery of the financial plan
or completion of the agreed upon services. The Firm does not, however, take receipt of $1,200 or more in
prepaid fees in excess of six months in advance of services rendered.
Wealth Management Fees
SWMP offers wealth management services for an annual fee based on the amount of assets under the Firm’s
management. This management fee varies in accordance with the following fee schedule:
PORTFOLIO VALUE BASE FEE
Up to $499,999 1.25%
$500,000 - $1,499,999 1.00%
$1,500,000 - $2,999,999 0.90%
$3,000,000 - $4,999,999 0.80%
$5,000,000 - $7,999,999 0.65%
$8,000,000 - $9,999,999 0.50%
$10,000,000 - $11,999,999 0.46%
$12,000,000 - $14,999,999 0.43%
$15,000,000 - $17,999,999 0.40%
Above $18,000,000 0.38%
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Alternatively, the Firm can be engaged to provide the wealth management services on a fixed fee basis for
certain clients, including those with less anticipated transactions and/or those with certain types of holding
such as fixed income, structured notes and certificates of deposit. Any fixed fee would be negotiated and
based upon the anticipated services and assets under management. The annual fee is prorated and charged
monthly, in advance, based upon the market value of the assets being managed by SWMP on the last day
of the previous month. If assets are deposited into or withdrawn from an account after the inception of a
billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio
value. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the
advisory agreement is terminated, the fee for the final billing period is prorated through the effective date
of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client,
as appropriate.
The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm
may, in its sole discretion, not include cash in determining the fee, especially where a client has a high
percentage of cash for reasons other than the Firm's investment management decision. Additionally, for
asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets,
accommodation accounts, alternative investments, etc.), SWMP may negotiate a fee rate that differs from
the range set forth above.
Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage SWMP
for additional services for compensation, including rolling over retirement accounts or moving other assets
to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the
Firm and are under no obligation to act upon any of the recommendations.
Fee Comparison
As referenced above, a portion of the fees paid to SWMP are used to cover certain securities brokerage
commissions and transactional costs attributed to the management of its clients’ portfolios.
Services provided through the Program may cost clients more or less than purchasing these services
separately. The number of transactions made in clients’ accounts, as well as the commissions charged for
each transaction, determines the relative cost of the Program versus paying for execution on a per transaction
basis and paying a separate fee for advisory services. Fees paid for the Program may also be higher or lower
than fees charged by other sponsors of comparable investment advisory programs. Because the Firm pays
for the brokerage fees, the Firm has an incentive to engage in less transactions, or transactions that cost less
to the Firm, including the use of mutual funds that do not have transaction charges, but have higher expenses
to the client. The Firm reviews the frequency and type of investments made in client accounts to act in the
client’s best interest.
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Fee Discretion
SWMP, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, pre-existing/legacy client relationship, account retention
and pro bono activities.
Other Charges
In addition to the advisory fees paid to SWMP, clients may also incur certain charges imposed by other third
parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These
additional charges include fees for trades executed away from Schwab (a conflict of interest exists where
the Firm avoids expenses by trading through a different Financial Institution), mark-ups and mark-downs on
fixed-income transactions (or it is overly burdensome to determine the amount of such mark-ups and mark-
downs), fees charged by the Independent Managers, fees attributable to alternative assets, reporting charges,
margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the
fund’s prospectus (e.g., fund Program Fees and other fund expenses), fees and commission for assets not
held with Schwab (such as 401(k) or 529 plan assets), deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees.
Direct Fee Debit
Clients generally provide SWMP and/or certain Independent Managers with the authority to directly debit
their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified
custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed
to send statements to clients not less than quarterly detailing all account transactions, including any amounts
paid to SWMP.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to SWMP’s right to
terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to
liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients
may withdraw account assets on notice to SWMP, subject to the usual and customary securities settlement
procedures. However, SWMP designs its portfolios as long-term investments and the withdrawal of assets
may impair the achievement of a client’s investment objectives. SWMP may consult with its clients about
the options and implications of transferring securities. Clients are advised that when transferred securities
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are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (e.g., contingent
deferred sales charge) and/or tax ramifications.
Charges for Recommendations of Securities
Clients can engage certain persons associated with SWMP (but not the Firm directly) to render securities
brokerage services under a separate commission-based arrangement. Clients are under no obligation to
engage such persons and may choose brokers or agents not affiliated with SWMP.
Under this arrangement, the Firm’s Supervised Persons, in their individual capacities as registered
representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”), may provide securities brokerage
services and implement securities transactions under a separate commission based arrangement. Supervised
Persons are entitled to a portion of the brokerage commissions paid to PKS, as well as a share of any
ongoing distribution or service (trail) fees from the sale of mutual funds. SWMP may also recommend no-
load or load-waived funds, where no sales charges are assessed. Prior to effecting any transactions, clients
are required to enter into a separate account agreement with PKS.
A conflict of interest exists to the extent that a Supervised Person of SWMP recommends the purchase or
sale of securities through a brokerage relationship where that Supervised Persons receives commissions or
other additional compensation as a result of that recommendation (the “Brokerage Relationship”). The
Firm has procedures in place to ensure that any recommendations made by such Supervised Persons to
engage in the Brokerage Relationship are in the best interest of that client. Because the Supervised Persons
may receive compensation in connection with the sale of mutual funds in the Brokerage Relationship, a
conflict of interest exists as such Supervised Persons, may have an incentive to recommend more expensive
mutual fund share classes to clients where such Supervised Persons earn more compensation with respect
to the sale of such mutual fund share classes. Clients should understand that the investments made in the
Brokerage Relationship are not receiving advisory services from the Firm. Therefore, the Firm does not
have a fiduciary duty over the Brokerage Relationship recommendations. For certain accounts covered by
the Employee Retirement Income Security Act of 1974 (“ERISA”) and such others that SWMP, in its sole
discretion, deems appropriate, SWMP provide its investment advisory services to certain clients on a fee-
offset basis. In this scenario, SWMP offsets its fees by an amount equal to the aggregate commissions and
12b-1 fees earned by the Firm’s Supervised Persons in their individual capacities as registered
representatives of PKS.
Compensation for Recommending the Program
SWMP has no internal arrangements in place whereby persons recommending the Program are entitled to
receive additional compensation as a result of clients’ participation. A person recommending the Program
will not earn more compensation than he or she would otherwise receive if a client elected another investment
management program.
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