A. Firm Information
Maimon Wealth Management Ltd. (“MWM” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”) and the Israel Securities Authority (“ISA”). The Advisor is
organized as a Corporation under the laws of Israel. MWM was founded in May 2015, and is owned by Maimon
Wealth Associates Ltd. The Advisor is operated by Bension “Ben” S. Maimon (Chief Executive Officer and Chief
Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by MWM. This Disclosure Brochure pertains to the Advisor’s
registration with the SEC.
B. Advisory Services Offered
MWM offers investment advisory services to individuals, high net worth individuals, trusts and estates in Israel,
the United States and other countries (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. MWM’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.
Investment Management Services
MWM provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related
advisory services. MWM 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. MWM primarily utilizes low-cost
mutual funds and, exchange-traded funds (“ETFs”), and/or individual equity bond securities in constructing Client
portfolios. The Advisor employs a low-fee, low turnover approach through well-diversified portfolios for most
Clients. The Advisor may utilize and advise upon individual stocks, individual bonds, and other types of
investments, as appropriate, to meet the needs of the Client. The Advisor may retain certain legacy positions of
the Client due to tax considerations and overall portfolio fit. Clients in the U.S. will typically have core investments
[mutual funds, ETFs, and equities] based in the U.S. Non-U.S. Clients will often have non-U.S. core investments.
MWM’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. MWM
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.
MWM evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. MWM may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. MWM 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. MWM 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 Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance. The Advisor generally reviews the universe of relevant funds for
exposures, fees, and performance. Foreign (ILS) portfolios are generally direct stocks and bonds to avoid
passive foreign investment company (“PFIC”) issues for U.S. investors.
At no time will MWM 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 the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices for
additional information.
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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
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
MWM will typically provide a variety of financial planning and consulting services to Clients, either as a
component of investment management services or pursuant to a written financial planning agreement. 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, education savings 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.
MWM 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 the 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 (6) 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.
C. Client Account Management
Prior to engaging MWM to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
• Establishing an Investment Strategy – MWM, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – MWM will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk of each Client.
• Portfolio Construction – MWM will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
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• Investment Management and Supervision – MWM will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
MWM does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by MWM.
E. Assets Under Management
As of December 31, 2023, MWM managed $89,718,029 in Client assets, $89,642,071 of which are managed on
a discretionary basis and $75,985 on a non-discretionary basis. Clients may request more current information at
any time by contacting the Advisor.