Description of Firm
Howard Wealth Management, LLC is a registered investment adviser primarily based in Madison,
Connecticut. We are organized as a limited liability company ("LLC") under the laws of the State of
Connecticut. We have been providing investment advisory services since November 2018. Howard
Wealth Management, LLC is owned by Justin Howard and Brett Howard.
Howard Wealth Management serves as a fiduciary to Clients, as defined under applicable laws and
regulations. As a fiduciary Howard Wealth Management upholds a duty of loyalty, fairness and good
faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment
is further described in our Code of Ethics. For more information regarding our Code of Ethics, please
see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
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 Howard Wealth Management,
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 provide customized investment advisory solutions for our Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary investment
management and related advisory services. Howard Wealth Management works 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. Howard Wealth Management will then construct a portfolio, consisting of
low-cost, diversified mutual funds and/or exchange-traded funds ("ETFs") to achieve the Client's
investment goals. We may also utilize individual stocks, bonds and alternative investments to meet the
needs of its Clients.
If you engage us for discretionary portfolio management services, we will require you to grant us
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, as well as the amount of securities to be purchased or sold for your account
without your approval prior to each transaction. Discretionary authority is typically granted by the
investment advisory agreement you sign with our firm and the appropriate 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.
We evaluate and select investments for inclusion in Client portfolios only after applying our internal due
diligence process. We may recommend, on occasion, redistributing investment allocations to diversify
the portfolio. We may recommend specific positions to increase sector or asset class weightings and
may recommend employing cash positions as a possible hedge against market movement. We may
also recommend selling positions for reasons that include, but are not limited to, harvesting capital
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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 Client,
generating cash to meet Client needs, or any risk deemed unacceptable for the Client's risk tolerance.
At no time will we accept or maintain custody of a Client's funds or securities. All Client assets will be
managed within their designated account(s) at the Custodian, pursuant to the Client investment
advisory agreement. For additional information, please see Item 12 – Brokerage Practices and Item
15 – Custody.
Asset Allocation Services
We offer asset allocation services that are tailored to meet our Clients' needs and investment
objectives. Once you have retained our firm for asset allocation services, we will gather information
about your financial situation and objectives, and assist you in determining your investment goals,
objectives, risk tolerance, and retirement plan time horizon. We will initially provide you with
recommendations as to how to allocate your investments among categories of assets. We will then
review your account on a periodic basis. Where appropriate, we may provide you with
recommendations to change your asset allocation in an effort to remain consistent with your stated
financial objectives. You are free at all times to accept or reject any of our investment
recommendations. You are solely responsible for implementing our recommendations. Unless you
separately retain us for portfolio management services, we will not execute any transactions or
changes in asset allocation on your behalf.
Financial Planning Services
Howard Wealth Management will typically provide a variety of financial planning services to individuals
and families, pursuant to a written financial planning agreement. Services are offered in several areas
of a Client's financial situation, depending on their goals, objectives and financial situation.
Generally, such financial planning services will involve preparing a financial plan or rendering a
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, insurance needs, and other areas of a
Client's financial outlook.
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 their retirement savings, establish education savings and/or charitable giving
programs. We may also refer Clients to an accountant, attorney or another specialist, as appropriate
for their unique situation. Depending on the arrangements made at the inception of the engagement, a
comprehensive written financial plan may or may not be included. For certain financial planning
engagements, we will provide a written summary of Client's financial situation, observations, and
recommendations. For consulting, or ad-hoc, engagements we 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 may pose a potential conflict between our
interests and the interests of the Client. For example, a recommendation to engage us for investment
management services or to increase the level of investment assets with us would pose a conflict, as it
would increase the advisory fees paid to us. Clients are not obligated to implement any
recommendations made by us. Clients are also not obligated to maintain an ongoing relationship with
us. If the Client elects to act on any of the recommendations made by us, the Client is under no
obligation to implement the transaction through us.
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Financial Consulting Services
We offer financial consulting services to individuals, owners, and key employees of closely-held
companies that primarily involves advising clients on specific financial-related topics. The topics we
address may include, but are not limited to, business succession and exit planning, strategic planning,
risk assessment/management, investment planning, financial organization, or financial decision
making/negotiation.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services may include an existing plan review and analysis, plan-level advice regarding fund selection
and investment options, education services to plan participants, investment performance monitoring,
and/or ongoing consulting. These pension consulting services will generally be non-discretionary and
advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor
or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as:
•Diversification
•Asset allocation
•Risk tolerance
•Time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services) shall be detailed in a written agreement and be consistent with the parameters set forth in the
plan documents.
Either party to the pension consulting agreement may terminate the agreement upon written notice to
the other party in accordance with the terms of the agreement for services. The pension consulting
fees will be prorated for the quarter in which the termination notice is given and any unearned fees will
be refunded to the client.
Family Office and Wealth Planning Services
We offer Family Office and Wealth Planning Services designed to help our clients organize their
financial situation and plan for the successful transfer of wealth to the next generation in the most tax-
advantaged manner. Such services generally include financial planning in the following areas:
•Family Continuity
•Estate Planning and Trustee Oversight
•Integrated Tax and Financial Planning
•Lifestyle Management
•Family Philanthropy
•Risk Management
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Educational Seminars and Workshops
Employers may also engage us to provide educational seminars or workshops for their employees in
order to explain various types of investments and the securities industry generally. In that event, the
individual employees are not considered to be clients of the firm unless they engage us separately. In
addition, we also provide educational discussions related to financial planning in general which may
include, but is not limited to: retirement planning, estate planning, tax planning and debt management.
Types of Investments
We offer advice on equity securities, corporate debt securities (other than commercial paper),
commercial paper, certificates of deposit, municipal securities, mutual fund shares, United States
government securities, money market funds, real estate investment trusts ("REITs"), structured notes
and exchange traded funds ("ETFs").
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:
•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 an ERISA account to an account that we
manage or provide investment advice to, because the assets increase our Assets Under Management
and, in turn, our advisory fees. In contrast, we receive less, or no, compensation if assets remain in the
current plan or are rolled over to another Company's plan in which you may participate.
Assets Under Management
As of February 12, 2024, we provide continuous management services for $290,500,000 in client
assets on a discretionary basis, and $0 in client assets on a non-discretionary basis.
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