Description of the Advisory Firm
AMJ Financial Wealth Management LLC is a Limited Liability Company organized in the
state of Virginia. This firm was formed in February of 2012, and the principal owners are
Angela M. Bender and Brett Bender.
Types of Advisory Services
Advisory Services
Our Firm offers a variety of advisory services, which include discretionary investment
management. Before rendering any preceding advisory services, Clients must enter into
one or more written Investment Advisory Contract (“Agreements”), setting forth the
relevant terms and conditions of the advisory relationship.
We do not provide tax or legal advice. Clients should consult with an expert on tax or
legal issues.
Our Firm manages portfolios for individuals, high-net-worth individuals and families,
estates, trusts, partnerships, retirement plans, corporations, and charitable foundations.
We provide advisory services to multi-generational families using separately managed
accounts under a custodial relationship with an independent brokerage firm.
With our discretionary relationship, we will change the portfolio as appropriate to help
meet your financial objectives. We trade Client portfolios based on our Firm’s market
views and the Client’s financial goals.
When engaging with AMJ for Advisory Services clients have access to Financial Planning
and Investment Management.
The Financial Planning process includes:
· Analyze client current situation
· Identify and articulate client goals
· Develop complete financial plan
· Periodic updates as situations change (income, expenses, goals, etc)
The services you receive around the Financial Planning process can include:
· Financial Planning
· Tax Planning
· Retirement Planning
· Estate Planning
· Education Planning
· Risk Management
· Asset Allocation
· Income Planning
· Debt Management
· Major expense planning
AMJ offers ongoing Investment Management based on the individual goals, objectives,
time horizon, and risk tolerance of each client. AMJ creates an Investment Policy
Statement for each client, which outlines the client’s current situation (income, tax levels,
and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to
aid in the selection of a portfolio that matches each client’s specific situation.
Investment Management Services include, but are not limited to, the following:
· Investment strategy
· Personal investment policy
· Asset allocation
· Asset selection
· Risk tolerance
· Regular portfolio monitoring
AMJ evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. Risk tolerance levels are documented in the Investment Policy
Statement, which is available by request by the client.
Portfolio Rebalancing
AMJ uses portfolio rebalancing software to model and allocate securities to client accounts.
This software is utilized in the process of determining position sizing and to allocate block
trades to individual accounts. This software provides the dollars/shares of a given security
to purchase based on the size of the account and the percent allocation of that security for
the relevant model. The software ensures necessary cash is available and prevents accounts
from being overbought. Members of the AMJ Portfolio Management team reviews all
orders before execution. AMJ uses block trading for instruments with variable inter day
pricing to facilitate best execution and to ensure all clients receive identical pricing when
being allocated the same security on the same day.
Retirement Plan Advisory Services
Retirement Plan Advisory Services consists of helping employer plan sponsors to
establish, monitor and review their company's retirement plan. As the needs of the plan
sponsor dictate, areas of advising could include: investment selection and monitoring,
plan structure, and participant education. Pursuant to Section 402(c)(3) of ERISA, the
client may appoint us as the Plan’s “investment manager” with respect to the Plan’s
portfolio of investment options. Our firm acts as a “fiduciary” within the meaning of
Section 3(21) and 3(38) of ERISA with respect to the Plan.
When serving as an ERISA 3(21) investment adviser, the Plan Sponsor and our Firm share
fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for
the investments and may accept or reject the recommendations in accordance with the
terms of a separate ERISA 3(21) Plan Sponsor Investment Management Agreement
between our Firm and the Plan Sponsor. Under the 3(21) agreement, our Firm can provide
the following services to the Plan Sponsor:
§ Review or Development of an Investment Policy Statement
§ Perform Due Diligence on Money Managers
§ Provide Initial Investment and Management Selection - Our Firm typically uses
mutual funds/managed accounts/collective trusts/cash equivalents to structure
portfolios designed to meet client objectives and risk profiles.
§ Provide ongoing Performance Evaluation and Monitoring of Money Mangers
§ Make Investment Recommendations when necessary
§ Retirement Plan Services Analysis - Our Firm will conduct an analysis of a client’s
retirement plan to evaluate the services currently provided to the client by third
parties. The areas of analysis may include asset management services, record
keeping, administration, customer service, participant education, etc. These services
may also include a cost/benefit analysis, recommendation of alternative vendors,
facilitation of the RFP process for solicitation of a new vendor, and/or assistance in
fee negotiations with proposed vendors.
§ Provide Employee Education Services - Our Firm will provide enrollment and
educational services the content of the program will be generic in nature.
As a result of the 3(38) appointment, we are granted full trading authority over the
Plan and have the responsibility for the selection and monitoring of all investment
options offered under the Plan in accordance with the investment policy statement
and its underlying investment objectives and strategies for the Plan. Plan
participants have the ability to exercise control over the assets in their account, and
we have no authority or discretion to direct the investment of assets of any
participant’s account under the Plan.
Disclosure Regarding Rollover Recommendations
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also 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. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual
Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences). Our Firm may recommend an
investor roll over plan assets to an IRA for which our Firm provides investment advisory
services. As a result, our Firm and its representatives may earn an asset-based advisory
fee. In contrast, a recommendation that a client or prospective client leave their plan assets
with their previous employer or roll over the assets to a plan sponsored by a new
employer will generally result in no compensation to our Firm. Our Firm therefore has an
economic incentive to encourage a client to roll plan assets into an IRA that our Firm will
manage, which presents a conflict of interest. To mitigate the conflict of interest, there are
various factors that our Firm will consider before recommending a rollover, including but
not limited to: (i) the investment options available in the plan versus the investment
options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses
in an IRA, (iii) the services and responsiveness of the plan’s investment professionals
versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v)
required minimum distributions and age considerations, and (vi) employer stock tax
consequences, if any. Our Firm’s Chief Compliance Officer remains available to address
any questions that a client or prospective client has regarding the oversight.
Participant One-on-Ones
We can also be engaged to provide financial education to plan participants. The scope of
education provided to participants will not constitute “investment advice” within the
meaning of ERISA and participant education will relate to general principles for investing
and information about the investment options currently in the plan.
As part of our advisory services, our Investment Adviser Representative (“IAR”) can
make recommendations to plan participants regarding the rollover of employer
sponsored retirement plan assets. In the case where an IAR recommends a retirement plan
rollover into our individual wealth management advisory program, the IAR will earn a
portion of the advisory fee. This presents a conflict of interest because IARs have an
economic incentive to recommend you to rollover your retirement plan assets into our
advisory services at our Firm. Plan participants are under no obligation to rollover
retirement plan assets to an IRA with our Firm and should carefully consider all relevant
factors, such as penalty-free withdrawals, whether loans are permitted, legal protections,
required minimum distributions, fees and expenses, service levels, available investment
options, employer stock considerations and state taxes.
Small Business Consulting Services
We provide experienced financial management to small and medium sized companies.
Consulting services include but are not limited to the following: virtual CFO services,
business planning, strategic planning, cash planning, organizational structure analysis,
accounting system analysis, accounting system implementation, business insurance
analysis, lease negotiation, tax review and fundraising.
Educational Workshops
Occasionally AMJ offers educational workshops for our clients and prospects. Workshops
will vary on general financial topics and can include: financial planning, retirement plan
distribution strategies, and other current topics of interest. There are no fees for attending
these workshops.
Services Limited to Specific Types of Investments
AMJ generally provides investment advice and/or money management to mutual funds,
equities, bonds, fixed income, debt securities, options, ETFs, real estate, hedge funds,
REITs, insurance products including annuities, private placements, and government
securities.
AMJ may use other securities as well to help diversify a portfolio when
applicable.
Legacy Management Services
Our Firm may advise a Client about legacy positions or other investments in Client
portfolios. Clients can limit or restrict our trading in these positions.
Client Tailored Services and Client Imposed Restrictions
AMJ offers the same suite of advisory services to all of its clients. However, specific client
financial plans and their implementation are dependent upon the client Investment Policy
Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels) and is used to construct a client specific plan to aid in the selection of a
portfolio that matches restrictions, needs, and targets. We primarily allocate client assets
among various stocks, bonds, Exchange Traded Funds (“ETFs”), Exchange Traded Notes
(“ETNs”), no-load or load-waived mutual funds, US Government Treasuries, alternative
investments, cash and money market funds in accordance with their stated investment
objectives. All of which are considered asset allocation categories for the client’s
investment strategy.
Our advisory services are tailored to meet your individual needs. You will have the ability
to leave standing instructions with us to refrain from investing in particular industries or
invest in limited amounts of securities.
While our advisory services are tailored to you as an individual, when using mutual funds
or Exchange Traded Funds (“ETFs”) this multi-fund manager approach makes it difficult
for us to ensure that your portfolio will not invest in a particular industry or security.
However, we are happy to discuss your preferences regarding socially conscious
investment concerns and, we’ll try as much as possible, to accommodate them.
Wrap Fee Programs
We also provide advisory services on a wrap fee basis as a wrap program sponsor. Under
our wrap program, you will receive advisory services, financial planning services, the
execution of securities brokerage transactions, custody and reporting services for a single
specified advisory fee. The benefits under a wrap fee program depend, in part, upon the
size of the account, the costs associated with managing the account, and the frequency or
type of securities transactions executed in the account. A wrap fee program may not be
suitable for all accounts, including but not limited to accounts holding primarily, and for
any substantial period of time, cash or cash equivalent investments, fixed income
securities or no-transaction-fee mutual funds, or any other type of security that can be
traded without commissions or other transaction fees. The terms and conditions of a wrap
program engagement are more fully discussed in our Wrap Fee Program Brochure.
We manage wrap accounts on a discretionary basis. When managing a client’s account on
a wrap fee basis, we receive as compensation for our advisory services, the balance of the
total wrap fee you pay after custodial, trading, and other management costs (including
execution and transaction fees) have been deducted. Accordingly, we have a conflict of
interest because we have a financial incentive to maximize our compensation by seeking
to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee.
Schwab and other custodians have eliminated commissions for online trades of U.S.
equities, ETFs, and options (subject to a $0.65 per contract fee). This means that, in most
cases, when we buy and sell these types of securities, we will not have to pay any
commissions to the Custodian. We encourage you to review the Custodian’s pricing to
compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee
arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest
could exceed the cost of paying for brokerage and advisory services separately.
Amounts Under Management
As of December 31, 2023, our regulatory assets under management are:
Discretionary $ 334,599,266
Non-discretionary $ 0
Total Regulatory Assets $ 334,599,266
Additional Assets Under Advisement $ 4,716,528