This Disclosure document is being offered to you by Price Financial Group Wealth Management,
Inc. (“Price Financial Group Wealth Management, Inc.” or “Firm”) about the investment advisory
services we provide. It discloses information about our services and the way those services are
made available to you, the client.
Our Firm will become a registered investment adviser in October 2022. Price Financial Group
Wealth Management, Inc. is wholly owned by Price Financial Group. Price Financial Group is
owned, by the following affiliated individuals: Robert Caldwell, Matthew Mai, and Mateusz Sudol.
Robert Caldwell is the Chief Compliance Officer.
We are committed to helping clients build, manage and preserve their wealth. Our Firm provides
services that help clients to achieve their stated financial goals. We will offer an initial
complimentary meeting upon our discretion; however, investment advisory services are initiated
only after you and Price Financial Group Wealth Management, Inc. execute an Investment
Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary basis. For discretionary accounts, once we have
determined a profile and investment plan with a client, we will execute the day-to-day
transactions without seeking prior client consent but within the expected investment guidelines.
We may accept accounts with certain restrictions, if circumstances warrant. We primarily allocate
client assets among cash, individual stocks, bonds, exchange traded funds (“ETFs”), structured
notes, CDs, equities, corporate bonds, municipal bonds, and U.S. Government Treasuries in
accordance with their stated investment objectives, and mutual funds. When appropriate, we
recommend Private Fund investments to certain suitable clients. We generally invest Client’s cash
balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial
paper and/or government backed debt instruments. Ultimately, we try to achieve the highest
return on our client’s cash balances through relatively low-risk and conservative investments. In
most cases, at least a partial cash balance will be maintained in a money market account so that
our firm may debit advisory fees for our services related to this service.
Portfolios will be designed to meet a particular investment goal, determined to be suitable to the
client’s circumstances. Once the appropriate portfolio has been determined, portfolios are
continuously and regularly monitored, and if necessary, rebalanced based upon the client’s
individual needs, stated goals and objectives.
During personal discussions with clients, we determine the client’s objectives, time horizons, risk
tolerance, and liquidity needs. As appropriate, we also review a client’s prior investment history,
as well as family composition and background. Based on client needs, we develop a client’s
personal profile and investment plan. We then create and manage the client’s investments based
on that policy and plan. It is the client’s obligation to notify us immediately if circumstances have
changed with respect to their goals.
Once we have determined the types of investments to be included in a client’s portfolio and have
allocated the assets, we provide ongoing investment review and management services.
With our discretionary relationship, we will make changes to the portfolio, as we deem
appropriate, to meet client financial objectives. We trade these portfolios based on the
combination of our market views and client objectives, using our investment process. We tailor
our advisory services to meet the needs of our clients and seek to ensure that your portfolio is
managed in a manner consistent with those needs and objectives. Clients have the ability to leave
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standing instructions with us to refrain from investing in particular industries or invest in limited
amounts of securities.
We do have limited authority to direct the Custodian to deduct our investment advisory fees from
your accounts, but only with the appropriate written authorization from clients.
Where appropriate, we provide advice about any type of legacy position held in client portfolios.
Typically, these are assets that are ineligible to be custodied at our primary custodian. Clients will
engage us to advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance, annuity contracts, and assets held in employer
sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
You are advised and are expected to understand that our past performance is not a guarantee of
future results. Certain market and economic risks exist that adversely affect an account’s
performance. This could result in capital losses in your account.
Use of Alternative Investments
Alternative Investments represent asset classes outside the realm of traditional stocks, bonds,
mutual funds, ETFS and cash equivalents and include, among other things, private equity, venture
capital, and funds of private funds. Where determined suitable for a client, Price Financial Group
Wealth Management, Inc. will utilize or otherwise recommend alternative investments.
FINANCIAL PLANNING
Through the financial planning process, our team strives to engage our clients in conversations
around the client’s goals, objectives, priorities, vision, and legacy – both for the near term as well
as for future generations. With the unique goals and circumstances of each client in mind, our
team will offer financial planning ideas and strategies to address the client’s holistic financial
picture, including estate, income tax, charitable, cash flow, wealth transfer, and client legacy
objectives. Our team partners with our client’s other advisors (CPAs, Enrolled Agents, Estate
Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the client’s
stated goals. Such services include various reports on specific goals and objectives or general
investment and/or planning recommendations, guidance to outside assets, and periodic updates.
Our specific services in preparing your plan may include:
o Review and clarification of your financial goals
o Assessment of your overall financial position including cash flow, balance sheet,
investment strategy, risk management, and estate planning
o Creation of a unique plan for each goal you have, including personal and business real
estate, education, retirement or financial independence, charitable giving, estate
planning, business succession, and other personal goals
o Development of a goal-oriented investment plan, with input from various advisors to our
clients around tax suggestions, asset allocation, expenses, risk, and liquidity factors for
each goal. This includes IRA and qualified plans, taxable, and trust accounts that require
special attention
o Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and
transfer, including liquidity as well as various insurance and possible company benefits;
and
o Crafting and implementation of, in conjunction with your estate and/or corporate
attorneys as tax adviser, an estate plan to provide for you and/or your heirs in the event
of an incapacity or death
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A written evaluation of each client's initial situation or Financial Plan is provided to the client. An
annual review will be provided by the Adviser, if indicated by the Client and Adviser per the
Agreement. More frequent reviews occur but are not necessarily communicated to the client
unless immediate changes are recommended.
THIRD PARTY MONEY MANAGERS (“TPMM”)
Our firm utilizes the services of a TPMM for the management of client accounts. Investment
advice and trading of securities will only be offered by or through the chosen TPMM. Our firm will
not offer advice on any specific
securities or other investments in connection with this service.
Prior to referring clients, our firm will provide initial due diligence on third party money managers
and ongoing reviews of their management of client accounts. In order to assist in the selection of
a TPMM, our firm will gather client information pertaining to financial situation, investment
objectives, and reasonable restrictions to be imposed upon the management of the account.
Our firm will periodically review third party money manager reports provided to the client at least
annually. Our firm will contact clients from time to time in order to review their financial situation
and objectives; communicate information to third party money managers as warranted; and,
assist the client in understanding and evaluating the services provided by the TPMM. Clients will
be expected to notify our firm of any changes in their financial situation, investment objectives,
or account restrictions that could affect their financial standing.
RETIREMENT PLAN SERVICES
Retirement Plan Advisory Services consists of helping employer plan sponsors to establish,
monitor and review their company's retirement plan. As the needs of the plan sponsor dictate,
areas of advising could include investment selection and monitoring, plan structure, and
participant education.
Pursuant to Section 402(c)(3) of ERISA, the client may appoint us as the Plan’s “investment
manager” with respect to the Plan’s portfolio of investment options. We acknowledge that we
are registered as an investment adviser under the SEC. Our firm acts as a “fiduciary” within the
meaning of Section 3(21) of ERISA with respect to the Plan. We offer advisory services to
employer sponsored retirement plans such as 401(k), 457, & 403(b). On the plan level, we manage
the investment line-up making changes as necessary as well as providing risk-based investment
models for the participants. On the individual participant level, we manage risk-based models
using the current investment lineup based on risk tolerance of the individual investor. For
employer-sponsored retirement plans with participant-directed investments, our firm provides
its advisory services as an investment advisor as defined under Section 3(21) of the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(21) investment adviser, the Plan Sponsor and our Firm share fiduciary
responsibility. The Plan Sponsor retains ultimate decision-making authority for the investments
and may accept or reject the recommendations in accordance with the terms of a separate ERISA
3(21) Plan Sponsor Investment Management Agreement between our Firm and the Plan
Sponsor. Under the 3(21) agreement, our Firm can provide the following services to the Plan
Sponsor:
• Review or Development of an Investment Policy Statement
• Perform Due Diligence on Money Managers
• Provide Initial Investment and Management Selection ‐ Our Firm typically uses
mutual funds/managed accounts/collective trusts/cash equivalents to structure
portfolios designed to meet client objectives and risk profiles.
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• Provide ongoing Performance Evaluation and Monitoring of Money Mangers
• Make Investment Recommendations when necessary
• Retirement Plan Services Analysis ‐ Our Firm will conduct an analysis of a client’s
retirement plan to evaluate the services currently provided to the client by third
parties. The areas of analysis may include asset management services, record
keeping, administration, customer service, participant education, etc. These services
may also include a cost/benefit analysis, recommendation of alternative vendors,
facilitation of the RFP process for solicitation of a new vendor, and/or assistance in
fee negotiations with proposed vendors.
• Provide Employee Education Services ‐ Our Firm will provide enrollment and
educational services the content of the program will be generic in nature.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in the
former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or
(iv) cash out the account value (which could, depending upon the client’s age, result in adverse
tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which
our Firm provides investment advisory services. As a result, our Firm and its representatives may
earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave
their plan assets with their previous employer or roll over the assets to a plan sponsored by a new
employer will generally result in no compensation to our Firm. Our Firm therefore has an
economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various factors
that our Firm will consider before recommending a rollover, including but not limited to: (i) the
investment options available in the plan versus the investment options available in an IRA, (ii) fees
and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and
responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of
assets from creditors and legal judgments, (v) required minimum distributions and age
considerations, and (vi) employer stock tax consequences, if any. All rollover recommendations
are reviewed by our Firm’s Chief Compliance Officer and remains available to address any
questions that a client or prospective client has regarding the oversight.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also 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.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests.
CONSULTING SERVICES
We also provide clients investment advice on a more-limited basis on one or more isolated areas
of concern such as estate planning, real estate, retirement planning, or any other specific topic.
Additionally, we provide advice on non-securities matters about the rendering of estate planning,
insurance, real estate, and/or annuity advice or any other business advisory / consulting services
for equity or debt investments in privately held businesses. In these cases, clients will be required
to select their own investment managers, custodian, and/or insurance companies for the
implementation of consulting recommendations. If client needs include brokerage and/or other
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financial services, we will recommend the use of one of several investment managers, brokers,
banks, custodians, insurance companies, or other financial professionals ("Firms"). Consulting
clients must independently evaluate these Firms before opening an account or transacting
business, and have the right to effect business through any firm they choose. Clients have the
right to choose whether or not to follow the consulting advice provided.
WRAP FEE PROGRAM
Our Firm does not sponsor a Wrap Fee Program.
ASSETS
As of December 31, 2022 our Firm manages $105,033,008 in regulatory assets under
management. Our Firm manages $105,033,008 in discretionary management and $0 in non-
discretionary management.