AWM Financial Services Inc. (hereinafter “AWM”) is a registered investment advisor based in The
Woodlands, Texas. We are a corporation under the laws of the State of Texas. We have been providing
investment advisory services since 2007. Matthew Stevenson is the President of AWM. D. Ryan Wheless
is the Founder, CEO and principal owner of AWM.
Currently, we offer the following investment advisory services, personalized to each individual client:
• Portfolio Management Services
• Selection of Third-Party Investment Advisers
• General Consulting Services
• Pension Consulting Services
The following paragraphs describe what we do and what we charge. Each investment advisory service is
listed below and describes how we tailor our advisory services to your individual needs. Also, you may
see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to
anyone from our Firm who is an officer, employee, and all individuals providing investment advice on
behalf of our Firm. Such persons are properly registered as investment adviser representatives in all
required jurisdictions.
Portfolio Management Services
Portfolio management refers to the management of money, including investments. Assets are usually
held in what is called a portfolio. Determining the types and quantities of securities to hold in a portfolio
is referred to as portfolio management.
Our Firm offers discretionary and non-discretionary portfolio management services to our clients and
prospective clients. Discretionary portfolio management means we will make investment decisions and
place buy or sell orders in your account without contacting you. These decisions would be made based
upon your stated investment objectives. Non-discretionary portfolio management means we will
contact you before a trading decision is taken and executed.
Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to
hire our Firm to manage your portfolio, we will meet with you to gather your financial information,
determine your goals, and decide how much risk you should take in your investments. The information
we gather will help us implement an asset allocation strategy that will be specific to your goals, whether
we are actively investing for you or simply providing you with advice.
There are a few ways we might create your investment portfolio depending on what we decide would
work best for you. We may customize a portfolio for you based the goals and risk we determined during
the information gathering process. Or, we might use a predetermined strategy rather than choosing
individual securities. Alternatively, it may be that one of the model portfolios developed by our Firm
would be the best fit for your needs.
Our Firm mainly uses equity securities, exchange traded funds, investment company products, private
placements, corporate securities, municipal securities and U.S. government securities in its portfolio
management programs.
However we construct your investment portfolio, we will monitor your portfolio’s performance on an
ongoing basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions,
your financial circumstances, or both.
As outlined above, we offer discretionary and non-discretionary portfolio management services.
Discretionary portfolio management services means that once the portfolio has been agreed upon, the
ongoing supervision and management of the portfolio will be our responsibility. You grant us this
authority in a written agreement, a limited power of attorney agreement, or trading authorization
form(s). This allows us to decide on the types and quantity of securities that we buy or sell for your
account without obtaining your approval for each transaction. You may limit this authority by setting a
limit on the type of securities that can be purchased for your account. Simply provide us with your
restrictions or guidelines in writing.
Non-discretionary portfolio management service means, as outlined above, that we must obtain your
approval prior to making any transactions in your account.
Selection of Third-Party Investment Advisers
AWM has entered into agreements with various third-party investment advisers for the provision of
certain investment advisory services. Factors considered in the selection of a third party advisor include
but may not be limited to: i) AWM’s preference for a particular third party advisor; ii) the client’s risk
tolerance, goals and objectives, as well as investment experience; and, iii) the amount of client assets
available for investment. In order to assist clients in the selection of a third party advisor, an Associated
Person of AWM will typically gather information from the client about the client’s financial situation,
investment objectives, and reasonable restrictions the client wants imposed on the management of the
account.
The third party advisor may customize the client's portfolio by blending traditional investment strategies
with an allocation to asset classes. The investment strategy adopted by the third party advisor may
embrace value, growth, or contrarian investing styles. Generally, securities transactions will be decided
upon and executed by the third party advisor on a discretionary basis. This means that the manager
selected will have the ability to buy and sell securities in your account without obtaining your approval.
AWM and its Associated Persons will not manage, or obtain discretionary authority over the assets in
accounts participating in these programs; however, clients may grant AWM the discretionary authority
to hire and fire such third party managers. Generally, clients may not impose restrictions on investing in
certain securities or types of securities in accounts managed by a third party advisor.
Associated Persons of AWM will periodically review reports provided to the client. An Associated Person
of AWM will contact the client at least annually, or more often as agreed upon with each client, to
review the client’s financial situation and objectives, communicate information to the third party advisor
managing the account as necessary, and to assist the client in understanding and evaluating the services
provided by the third party advisor. Clients will be expected to notify AWM of any changes in their
financial situation, investment objectives, or account restrictions.
The third party advisor may offer wrapped or non-wrapped pricing options. Wrap pricing structures
allow the client to pay an all-inclusive fee for management, brokerage, clearance, custody, and
administrative services. In a non-wrap pricing structure, the third party advisor’s fee may be separated
from the advisory fee charged by AWM. Transaction costs may also be charged for the execution and
clearance of advisory transactions directed by such Third Party Advisory Services. A complete
description of the programs and services provided, the amount of total fees, the payment structure,
termination provisions and other aspects of each program are detailed and disclosed in: i) the third
party advisor’s Form ADV Part 2A; ii) the program wrap brochure (if applicable) or other applicable
disclosure documents; iii) the disclosure documents of the portfolio manager(s) selected; or, iv) the third
party advisor’s account opening documents. A copy of all relevant disclosure documents of the third
party advisor and of the individual portfolio manager(s) will be provided to anyone interested in these
programs/managers.
General Consulting Services
AWM provides hourly consulting services that focus on the specific needs and concerns of the client.
Consulting services may include giving advice on investment and investment related matters. These
services include the identification of financial goals and objectives, collection and assessments of all
relevant data, identification of financial problems and formulation of solutions, and the preparation of a
financial plan in the form of specific written or verbal recommendations. The services provided by AWM
will typically focus on one or more of the following areas:
• Retirement Planning:
Retirement Planning is a process of determining retirement income goals and the actions and
decisions necessary to achieve those goals. Retirement planning includes identifying sources of
income, estimating expenses, implementing a savings program and managing assets. Future
cash flows are estimated to determine if the retirement income goal will be achieved.
• Investment Planning:
The goal of investment planning is to determine the investment mix and policy, matching
investments to objectives, asset allocation for individuals and institutions, and balancing risk
against performance. The process realizes strengths, weaknesses, opportunities and risks in the
choice of debt vs. equity, domestic vs. international, growth vs. safety, and many other tradeoffs
encountered in the attempt to maximize return at a given risk.
All of our advice is based on your financial situation and the financial information you provide to our
Firm. If your financial situation, goals, objectives, or needs change, you must notify us promptly.
We may also offer consultative services where we set an appointment to meet with you for financial
planning advice for an hourly fee.
You may choose to accept or reject our recommendations. If you decide to proceed with our
recommendations, you may do so either through our investment advisory services or by using the
advisory/brokerage firm of your choice.
Disclosures required by California Code of Regulations, 10 CCR Section 260.235.2: A conflict exists
between the interests of the investment adviser and the interests of the client, the client is under no
obligation to act upon the investment adviser's recommendation, and if the client elects to act on any of
the recommendations, the client is under no obligation to effect the transaction through the investment
adviser.
Pension Consulting Services
AWM provides several pension consulting related services separately or in combination. While the
primary clients for these services will be pension, profit sharing and 401(k) plans, AWM will also offer
these services, where appropriate, to individuals and trusts, estates and charitable organizations.
Pension consulting services are comprised of four distinct services. Clients may choose to use any or all
of these services:
Investment Policy Statement Preparation
AWM will meet with the client (in person or over the telephone) to determine the client's
investment needs and goals. AWM will then prepare a written Investment Policy Statement
(“IPS”) stating those needs and goals and creating a policy to help achieve these goals. The IPS
will also list the criteria for selection of investment vehicles and the procedures and timing
interval for monitoring of investment performance.
Selection of Investment Vehicles
AWM will review various investments, consisting of one or all of the following: individual
equities, bonds, other investment products, and mutual funds (both index and managed) to
determine which of these investments are appropriate to implement the client's IPS. The
number of investments to be recommended will be determined by the client, based on the
Investment Policy Statement.
Monitoring of Investment Performance
Client investments will be monitored continuously based on the procedures and timing intervals
outlined in the Investment Policy Statement. Although AWM will not be involved in any way in
the purchase or sale of these investments, AWM will supervise the client's portfolio and will
make recommendations to the client as market factors and the client's needs dictate.
Employee Communications
For pension, profit sharing and 401(k) plans where the individual account participant exercises
control over assets in his/her own account (hereinafter ''self-directed plans''), AWM also
provides educational support and investment workshops designed for the Plan participants. The
nature of the topics to be covered will be determined by AWM and the client under the
guidelines established in ERISA Section 404(c). The educational support and investment
workshops will NOT provide Plan participants with individualized, tailored investment advice or
individualized, tailored asset allocation recommendations.
Other pension consulting services are available on request. All of our pension consulting services,
whether general or customized, will be outlined in an agreement that shows the services that will be
provided and the fees that will be charged for those services.
Assets Under Management
As of December 31, 2023, we manage $198,000,000.00 in client assets on a discretionary basis, and $
0.00 in client assets on a non-discretionary basis.