Description of Firm Aaron Wealth Advisors LLC is a registered investment adviser based in Chicago, Illinois. We are organized as a limited liability company ("LLC") under the laws of the State of Illinois. We have been providing investment advisory services since September 20, 2018. We are owned by Gary Evan Hirschberg.
The following paragraphs describe our services and fees. 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 Aaron Wealth Advisors LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. We will also have discretion over the broker or dealer to be used for securities transactions, and over the commission rates to be paid. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.
We may also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
Aaron Wealth Advisors has entered into a contractual relationship with Dynasty Financial Partners, LLC ("Dynasty"), which provides our firm with operational and back-office support including access to a network of service providers. Through the Dynasty network of service providers, we may receive preferred pricing on trading technology, reporting, custody, brokerage, compliance and other related services. Dynasty charges a "Platform Fee," for which, unless otherwise disclosed, the client will be charged, separate from and in addition to such client's annual investment management fee, as described in Item 5 below. In addition, Dynasty's subsidiary, Dynasty Wealth Management, LLC ("DWM") is an SEC registered investment adviser, that provides access to a range of investment services including: separately managed accounts ("SMA"), mutual fund and ETF asset allocation strategies, and unified managed accounts ("UMA") managed by external third-party managers (collectively, the "Investment Programs"). Aaron Wealth Advisors and its clients may separately engage the services of Dynasty and/or its subsidiaries to access the Investment Programs. Under the SMA and UMA programs, we will maintain the ability to select the specific, underlying third-party managers that will, in turn, have day-to-day discretionary trading authority over the requisite client assets. DWM sponsors an investment management platform (the "Platform" or the "TAMP") that is available to the advisers in the Dynasty Network, such as Aaron Wealth Advisors. Through the Platform, DWM and Dynasty collectively provide certain technology, administrative, operations and advisory support services that allow advisers to manage their own portfolios and access independent third-party 4 managers that provide discretionary services in the form of traditional managed accounts and investment models. Advisers can allocate all or a portion of client assets among the different independent third-party managers via the Platform. We will maintain the direct contractual relationship with each client and obtain, through such agreements, the authority to engage independent third-party managers, DWM and/or Dynasty, as applicable, for services rendered through the Platform in service of such client. We may delegate discretionary trading authority to DWM and/or independent third-party managers to effect investment and reinvestment of client assets with the ability to buy, sell or otherwise effect investment transactions and allocate client assets. If a client is participating in certain Investment Programs, DWM or the designated manager, as applicable, is also authorized without prior consultation of Aaron Wealth Advisors or the client to buy, sell, trade or allocate such client's assets in accordance with the client's designated portfolio and to deliver instructions to the designated broker-dealer and/or custodian of such client's assets.
Financial Consulting Services We offer financial

consulting services that primarily involve advising clients on specific financial-related topics. The topics we address may include, but are not limited to, tax and estate planning, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation. Additionally, we may advise on assets held at another custodian or private equity and real estate. Mergers & Acquisitions Advisory Services We offer mergers and acquisitions advisory services to select individuals through our affiliate company, Aaron Wealth Consulting, LLC dba Aaron Wealth Liquidity Execution Group. This is an affiliate under common control and ownership which does not offer investment advisory or portfolio management services. Wrap Fee Programs We do not participate in any wrap fee program.
Types of Investments We offer advice on mutual fund shares, exchange traded funds, options contracts on securities, structured notes, limited partnerships and real estate.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
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: 5
•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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of February 20, 2024, our regulatory assets under management for which we provide continuous management services are as follows: we provide continuous management services for $1,667,330,967 in client assets managed on a discretionary basis, and $284,698,554 in client assets managed on a non-discretionary basis which totals $1,952,029,521 regulatory assets under management.
Aaron Wealth Advisors utilizes put writing and call writing strategies for a portion of our client base. In ADV filings prior to 2022, put and call writing strategies were not included in the calculation of regulatory assets under management. However, after consultation with and additional detail from various regulatory resources, the mandated notional value of option writing strategies is now included in the calculation of regulatory assets under management. The notional value trading limits of these option writing strategies are managed on a discretionary basis by Aaron Wealth Advisors and included in client AUM calculations when assessing fees for advisory services. This method will be used on a go-forward basis unless otherwise notated.
In some cases, Aaron Wealth Advisors is engaged by clients as an investment consultant. These contractual arrangements are for investment consulting services. Aaron Wealth Advisors acts on a non-discretionary basis, may or may not receive a fee, and does not provide continuous supervisory services for these specific engagements. However, because Aaron Wealth Advisors has an active contractual obligation to provide investment advice in the agreed upon framework, these assets are included in the calculation of our Assets Under Advisement.
Investment consultant engagements in which Aaron Wealth Advisors acts on a non-discretionary basis and provides continuous and regular supervisory services have been included in the calculation of Regulatory Assets Under Management.
The calculation for total client Assets Under Advisement and Management is as follows: Total Regulatory Assets Under Management = $1,952,029,521 Non-Discretionary, Investment Consultant Assets = $854,241,340 Total Assets Under Advisement and Management = $2,806,270,861 6