A. Firm Information
DWS is registered as an investment Adviser with the U.S. Securities and Exchange Commission
("SEC"). The Adviser is organized as a Limited Liability Company ("LLC") under the laws of the State of
Florida. DWS was founded in January 2023 and is a wholly-owned subsidiary of Creative Wealth
Collaboration LLC, a Delaware LLC, which, in turn, is wholly-owned by Joseph Cefalu.
This Disclosure Brochure provides information regarding the qualifications, business practices, and
Advisory services provided by DWS.
B. Advisory Services Offered
DWS offers Advisory services to individuals, high-net-worth individuals, families, trusts, estates,
businesses, and endowments (each referred to as a "Client").
The Adviser serves as a fiduciary in accordance with applicable laws and regulations. As a fiduciary, the
Adviser upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate
conflicts of interest. DWS's fiduciary commitment is further described in the Adviser's Code of Ethics.
For more information regarding the Code of Ethics, please see Item 11.
Wealth Management Services
DWS provides customized wealth management solutions for its Clients. This is achieved through regular
personal Client contact and interaction while providing discretionary or non-discretionary wealth
management and financial planning services. DWS works closely with each Client to identify their
investment goals and objectives as well as risk tolerance and financial situation in order to design a
portfolio strategy. DWS then constructs an investment portfolio consisting of individual equities,
exchange-traded funds ("ETFs"), open-end mutual funds, and/or individual bonds to achieve the Client's
investment goals. The Adviser may also utilize other types of investments, as appropriate, to meet the
needs of the Client. The Adviser may retain certain legacy investments based on portfolio fit and/or tax
considerations.
DWS will select, recommend, and/or retain mutual funds on a fund-by-fund basis. Due to specific
custodial and/or mutual fund company constraints, material tax considerations, and/or systematic
investment plans, DWS will select, recommend, and/or retain mutual fund share classes that do not
have trading costs when possible. These will in most cases be institutional share classes but in some
cases may be share classes with higher internal expense ratios than institutional share classes. DWS
will seek to select the lowest-cost share class available that is in the best interest of each Client,
weighing the expected investment pattern, expense ratios, and potential ticket charges, and will ensure
the selection aligns with the Client's financial objectives and stated investment guidelines.
DWS's investment approach is primarily long-term focused, but the Adviser 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. DWS 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
portfolios, subject to acceptance by the Adviser.
DWS evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. DWS may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. DWS may recommend specific positions to increase sector or asset class
weightings. The Adviser may recommend employing cash positions as a possible hedge against market
movement. DWS 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, a change in risk tolerance of
the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client's risk
tolerance.
Financial Planning Services
DWS typically includes financial planning services as part of its overall wealth management services
and fee arrangement.
Financial planning and consulting topics address several areas of a Client's financial situation,
depending on the client's goals and objectives. This planning or consulting may encompass one or more
areas of need, including but not limited to, investment planning, family planning, retirement planning,
large purchase advice, and/or other areas of a Client's financial situation.
C. Client Account Management
Prior to engaging DWS to provide Advisory services, each Client is required to enter into a written
Advisory agreement with the Adviser that defines the terms, conditions, authority, and responsibilities of
the Adviser and the Client. These services may include:
• Establishing an Investment Strategy - DWS, in connection with the Client, will develop a strategy
that seeks to achieve the Client's goals and objectives.
• Asset Allocation - DWS 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 or
unique client goal.
• Portfolio Construction - DWS will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Wealth Management and Supervision - DWS will provide wealth management and ongoing
oversight of the Client's investment portfolio.
D. Wrap Fee Programs
DWS does not manage or place Client assets into any wrap fee programs. Investment management
services are provided directly by DWS.
E. Assets Under Management
As of March 8, 2024, DWS manages approximately $886,324,113 in total assets under
management, of which approximately $19,964,510 are assets managed on a discretionary basis,
and approximately $866,359,603 is managed on a non-discretionary basis.