A. Firm Information
Tower Wealth Partners, Inc. (“Tower Wealth” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”). The Advisor is organized as a Corporation under the laws of the Commonwealth of
Pennsylvania. The firm was initially named Koss Financial Group, Inc. and renamed to Tower Wealth Partners, Inc. in
August 2020. Tower Wealth was founded in January 2005 and became a registered investment advisor in September
2020. Tower Wealth is owned and operated by Darin M. Koss (Managing Partner and Chief Compliance Officer) and
Jared F. Kohl (Partner). This Disclosure Brochure provides information regarding the qualifications, business practices,
and the advisory services provided by Tower Wealth.
B. Advisory Services Offered
Tower Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates, and
businesses (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. Tower Wealth'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.
Wealth Management Services
Tower Wealth offers Clients wealth management services, which include a broad range of financial planning and
consulting services in connection with discretionary investment management services. These services are described
below.
Investment Management Services
Tower Wealth 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. Tower Wealth 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. Tower Wealth will then construct an investment
portfolio, consisting of diversified mutual funds, exchange-traded funds (“ETFs”), individual stocks and individual bonds to
achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options contracts to meet
the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy investments
based on portfolio fit and/or tax considerations.
Tower Wealth’s investment strategies are 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.
Tower Wealth 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.
Tower Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Tower Wealth may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Tower Wealth 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. Tower Wealth 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 the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the
Client’s risk tolerance.
Under certain circumstances, Tower Wealth may accept or maintain custody of a Client’s funds or securities. Please see
Item 15 – Custody for more information. 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.
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.
Use of Independent Managers
Tower Wealth when appropriate recommend that Clients utilize one or more unaffiliated investment managers or
investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on
the Client’s needs and objectives. In such instances,
the Client will be required to authorize and enter into an investment
management agreement with an Independent Manager that defines the terms in which the Independent Manager will
provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent
Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor
will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client
relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the
Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning Services
Tower Wealth will typically provide a variety of financial planning and consulting services to Clients, 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, insurance needs, 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.
Tower Wealth 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.
Retirement Plan Advisory Services
Tower Wealth provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in
meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the
Plan and Plan Sponsor. Services generally include:
● Vendor Analysis
● Plan Participant Enrollment and Education Tracking
● Investment Policy Statement (“IPS”) Design and Monitoring
● Investment Management Services (ERISA 3(38))
● Ongoing Investment Recommendation and Assistance (ERISA 3(21))
● Benchmarking Services
● ERISA 404(c) Assistance
These services are provided by Tower Wealth serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is
provided with a written description of Tower Wealth’s fiduciary status, the specific services to be rendered and all direct
and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Tower Wealth 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 – Tower Wealth, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Tower Wealth will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Tower Wealth will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – Tower Wealth will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Tower Wealth does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by Tower Wealth.
E. Assets Under Management
As of December 31, 2022, Tower Wealth manages $259,248,147 in Client assets, $241,841,946 are managed on a
discretionary basis and $17,406,201 on a non-discretionary basis. Clients may request more current information at any
time by contacting the Advisor.