A. Firm Information
Harbour Wealth Management Group, Inc. (“HWMG” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission. The Advisor is organized as a Corporation under the laws of the State
of South Carolina. HWMG was founded in March 2021 and is owned and operated by Matthew Pardieck (Managing
Principal) and Christopher Corley (Managing Director). This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by HWMG.
B. Advisory Services Offered
HWMG offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
charitable organizations, and retirement plans (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. HWMG'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
HWMG provides customized investment management services for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management services in
connection with a broad range of comprehensive financial planning services. HWMG works closely with each Client
to identify their investment goals, objectives, risk tolerance and financial situation in order to create a portfolio
strategy utilizing one of the Advisor’s model portfolios or independent managers. The Advisor’s model portfolios
primarily consist of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”). The Advisor may also
utilize individual stocks, bonds, options contracts, or independent managers to meet the needs of its Clients. The
Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
HWMG’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. HWMG 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.
HWMG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. HWMG may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. HWMG 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. HWMG 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.
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.
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At no time will HWMG 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.
Financial Planning Services
HWMG will typically provide financial planning services as part of its investment management services described
above. HWMG may also provide standalone financial planning and consulting services to Clients, pursuant to a
written financial planning agreement. For standalone financial planning, services may be offered on a project-based
engagement or annual ongoing engagement. 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, business succession
planning 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.
HWMG 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.
Use of Independent Managers
HWMG may 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 certain instances, the Client may be required to authorize and enter into an investment
management agreement with the Independent Manager[s] that defines the terms in which the Independent
Manager[s] 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 Client’s investment objectives and overall
best interests. The Advisor will also assist the Client in the development of the initial portfolio 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).
Retirement Plan Advisory Services
HWMG 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 Oversight Services (ERISA 3(21))
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• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
These services are provided by the Advisor 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 the Advisor’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 HWMG 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 – HWMG, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – HWMG 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.
• Investment Management and Supervision – HWMG will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
HWMG includes the securities transaction fees and custodial costs (herein “Covered Costs”) together with its
investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”.
The Advisor customizes its investment management services for its Clients. The Advisor sponsors the HWMG
Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level
of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than
if the Client paid its own securities transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which
is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2022, HWMG manages approximately $149,129,580 in Client assets, $115,892,344 of which
are managed on a discretionary basis and $33,237,236 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.