Overview
A. Description of the Advisory Firm
B. Types of Advisory Services
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synthetic exposures and private placements. PWW may use other securities as well to help
diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special
rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
PWW offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client goals and
objectives, which are outlined in various meeting notes and CRM profiles (income, tax
levels, and risk tolerance levels, etc.). 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 PWW from properly servicing the client account, or if the restrictions
would require PWW to deviate from its standard suite of services, PWW reserves the right
to end the relationship.
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. PWW does not participate in or offer
wrap fee programs.
C. Client Tailored Services and Client Imposed Restrictions
D. Wrap Fee Programs
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PWW has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$207,692,748 $0 December 2023
Portfolio Management Fees
Total Assets Under Management Annual Fees
All Assets 1.50%
The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period.
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of PWW's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract
immediately upon written notice.
Payment of Portfolio Management Fees
Asset-based portfolio management fees are typically withdrawn directly from the client's
accounts with client's written authorization on a quarterly basis, or may be invoiced and
billed directly to the client on a quarterly basis. Clients may select the method in which they
are billed. Fees are paid in advance.
Clients are responsible for the payment of all third-party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by PWW. Please see Item 12 of this brochure
regarding broker-dealer/custodian.
E. Assets Under Management