A. Description of the Advisory Firm
CWM Partners (hereinafter “CWM”) is a Limited Liability Company organized in the State of
New York. The firm was formed in July 2013, and the principal owners are Michael Warszawski
and Cristina Markman.
CWM Partners LLC has voluntarily subscribed to the “Real Fiduciary™ Practices” published by
the Institute for the Fiduciary Standard. Real Fiduciary™ Practices offer a simple code of conduct
and outline a commitment to clients of subscribing financial advisors. They seek to clearly
articulate what a client can expect to receive from a subscribing financial advisor. These Real
Fiduciary™ Practices do not replace our regulatory compliance obligations or duties to clients
under relevant laws, rules, or regulations. The Institute for the Fiduciary Standard’s role is limited
to publishing the practices as well as maintaining a corresponding register of subscribing
financial advisors. You can verify our affirmation of Real Fiduciary™ Practices on our website or
at the Institute for the Fiduciary Standard website at www.thefiduciaryinstitute.org. The practices
can be found at
https://thefiduciaryinstitute.org/wp-content/uploads/2019/03/Real-
Fiduciary-Practices-2019-02-22.pdf"
B. Types of Advisory Services
CWM offers the following services to advisory clients:
Portfolio Management Services
CWM offers ongoing portfolio management services based on the individual goals, objectives,
time horizon, and risk tolerance of each client. CWM creates an Investment Policy Statement for
each client, which outlines the client’s current situation (income, tax levels, and risk tolerance
levels).
Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
CWM evaluates the current investments of each client with respect to their risk tolerance levels
and time horizon. CWM will request discretionary authority from clients in order to select
securities and execute transactions without permission from the client prior to each transaction.
Risk tolerance levels are documented in the Investment Policy Statement, which is given to each
client.
CWM seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of CWM’s economic, investment or other
financial
interests. To meet its fiduciary obligations, CWM attempts to avoid, among other things,
investment or trading practices that systematically advantage or disadvantage certain client
portfolios, and, accordingly, CWM’s policy is to seek fair and equitable allocation of investment
opportunities/transactions among its clients to avoid favoring one client over another over time.
It is CWM’s policy to allocate investment opportunities and transactions it identifies as being
appropriate and prudent, including initial public offerings (“IPOs”) and other investment
opportunities that might have a limited supply, among its clients on a fair and equitable basis
over time.
Selection of Other Advisers
CWM may direct clients to third-party investment advisers. CWM may recommend wrap fee
programs when appropriate based on the client's investment objectives. Before selecting other
advisers for clients, CWM will always ensure those other advisers are properly licensed or
registered as investment advisers.
Financial Planning
Financial plans and financial planning may include but are not limited to: investment planning;
life insurance; tax concerns; retirement planning; education planning; and debt/credit planning.
Services Limited to Specific Types of Investments
CWM generally limits its investment advice to mutual funds, equities, fixed income securities,
ETFs (including ETFs in the gold and precious metal sectors), real estate funds (including REITs),
non-U.S. securities, business development companies, private placements, and hedge funds. In
some situations, where appropriate, CWM may use other securities to help diversify a portfolio.
C. Client Tailored Services and Client Imposed Restrictions
CWM offers the same suite of services to all of its clients. However, specific client investment
strategies 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). Clients
may impose restrictions in investing in certain securities or types of securities in accordance with
their values or beliefs. However, if the restrictions prevent CWM from properly servicing the
client account, or if the restrictions would require CWM to deviate from its standard suite of
services, CWM reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and any other administrative fees.
CWM does not participate in any wrap fee programs.
E. Assets Under Management
Discretionary Amounts: Non-Discretionary Amounts: Date Calculated:
$ 4,442,735 $ 57,945,813 December 2023